This Privacy Policy lays down how the controller Engage Factory Ltd. and its affiliates (also referred to as “we”, “us”, or “our”), collects, stores, uses and protects your information when you use our solutions (the “Solutions”) that hyperlinks to this Privacy Policy and is available on the website (engagefactory.com) (“Website”), or any other websites, pages, features, or content owned and operated by Engage Factory Ltd. (collectively, including the Website and the Solutions, the “Service”).
By accessing, visiting or using our Service, you warrant and represent that you have read and understood and by clicking “Accept and Enable” button, you agree to this Privacy Policy. If you disagree with anything in this Privacy Policy, please refrain from using or accessing the Service.
We may occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. We may also periodically make changes to this Privacy Policy as we update or expand our Service. We will notify you of any material changes to this Privacy Policy on our Website or within the Solutions. If you do not agree to the changes, you should discontinue your use of the Service prior to the time the modified Privacy Policy takes effect.
The most current version of the Privacy Policy that governs our use of your information will be available on our Website.
In this Privacy Policy the term “personal data” or “personal information” shall mean any information relating to an identified or identifiable natural person. An “identifiable natural person” shall mean the one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The term "processing" shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Most of the information that we collect about you comes directly from you through automatic means when you use our Service and may be your personal data. In general, we collect technical information that may uniquely identify your device through its identifiers (so called device identifiers or persistent identifiers such as IP address, IDFA, IDFV, Android Ad ID). Those identifiers identify the device you use and not you as a user personally, but are considered as personal information according to some data protection legislations e.g. EEA (European Economic Area) data protection legislation.
The information we collect about you relates to the type of device you are using, various characteristics that help us identify your device, and how you use our Service on your device.
Technical information: If you access our Services through a device, we shall collect technical information about your device that is required for your use of our Service. Such technical information enables us to maintain and analyze the functioning of our Service, to adjust the content of the Service and also to display advertisements. Information about your device that we automatically collect include the following:
device type, device ID, operating system (OS) type, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, device capabilities etc.
Information about your usage of the Solutions;
IP address;
Country or region (but not precise geolocation data);
IDFAs, IDFVs, Mobile device advertising IDs;
Time zone, session start/stop time;
Network status (WiFi, etc.), browser plug-in types and versions;
Language; Locale (specific location where a given language is spoken);
Other keyboard settings including which settings has been switched on/off;
User agent string (UA), platform, SDK version, timestamp;
Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications).
Cookies: We also use cookies to collect information about your interactions with our Service. Such information is used for delivering and improving our service, analytics purposes and advertising.
Information you share on third-party websites or through social media services: The Solutions may include connections and links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information and share the content you created within the Solutions. Please note that while using such third-party websites and social media services, you are using sites, products and services developed and administered by people or companies not affiliated with or controlled by us and your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We do not collect, process, store and/or share those information, but we encourage you to review the privacy policies, personal data collecting, processing and sharing practices and settings of those third-party websites and social media services to make sure you understand which your personal information may be collected and processed by those third-party websites and social media services.
You are always able to limit the amount of information collected from your device by adjusting your device.
To provide our services to you and to improve our services: We require certain information from you in order to provide you with the services you requested. We use your information for constantly developing, delivering and improving our Service and contents, tailoring our products and services, providing updates, technical trouble shooting, understanding and analyzing trends in connection with usage of the Service, and administering the Service, all to make sure we provide you with the best experience.
To display advertisements: We use your information for showing you interest-based advertisements in our Solutions (Please see more in “Advertising” and “How we share your information with third parties” Sections of this Privacy Policy).
For delivering newsletters: Furthermore we use some of your personal information such as your email address to send you newsletters that contain non-promotional content such as Solutions related information, administrative and account-related information to keep you updated about our Service, inform you of relevant security issues or updates, etc. We will use your email address with the purpose of sending you newsletters only on the basis of your explicit consent.
For tracking and fraud prevention: We use your information for tracking the performance of our ad-campaigns and for identifying and preventing fraud for our advertising campaigns. Also, we use your information for the purposes of tracking performance, ad visibility and privacy compliance of third-party advertising campaigns in our Solution and other services.
For analytics and research: We use your information for understanding and analyzing trends in relation to the usage of the Solutions, gathering demographic information about our user base, etc. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Solutions and services, or to test our new game features and content.
For security measures, authentication/verification and registration: We use your information to enhance the safety and security of our Solutions, products and services - combat spam, malware, malicious activities or security risks. We require and use some of your personal information also to provide you with the confirmation of your registration for raffles, sweepstakes and other, and to monitor and verify your identity so that unauthorised users do not access your account with us.
For customer support: We use your personal information when you contact us to help you with any questions, concerns, disputes issues, inquiries or to provide us with your feedback. Without your personal information, we cannot respond to you to ensure your continued use of the Service.
To fulfil legal obligations and requirements: We use your information when we are required to do so by law. We process your personal information to fulfil our business obligations and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.
Your personal data will be disclosed to our employees authorised for processing of your personal data for the purposes set out in this Privacy Policy, to our contracted partners (data processors) that process your personal data on our behalf, as well as to public authorities, other state authorities and persons with powers conferred by public law to whom personal data is disclosed, when so required by the applicable legislation.
Providing you with our services may in certain cases also require and take place through contracted partners that ensure smooth functioning of our services:
our cloud service providers: Information we collect from you are stored on servers provided by Microsoft Corporation’s Microsoft Azure. Servers are located and therefore your personal data is stored within the EU and USA. Microsoft has adopted appropriate safeguards in the form of standard contractual clauses, which are always available to the user in the Data Protection Addendum on the following website: https://www.microsoft.com/en-licensing/products and https://www.microsoftvolumelicensing.com/DocumentSearch.aspx?Mode=3&DocumentTypeId=67.
For our website we use SIEL d.o.o. as a cloud service provider established within the EU and with which an appropriate contract for the processing of personal data has been concluded;
advertising partners: We use third-party advertising networks and ad providers that assist us in delivering advertising to you (Please see more in “Advertising” and “Children” Sections of this Privacy Policy).
We only use data processors that provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing meets the requirements of the applicable law and ensure the protection of your rights as the data subject. Given the larger scale of our advertising contract partners, you can obtain more information about the partners and their applied safeguards (mostly in a form of Standard Contractual Clauses) by contacting us in the manner set out in the last section of this Privacy Policy. Please be as specific as possible when making your request, as we may be able to refuse unreasonable requests or charge you a fee to comply with them in accordance with the provisions of the GDPR.
If you choose to use our Service or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Please note that not all of the countries have the same data protection laws as your own country, but we will always take appropriate steps to protect the privacy of your personal information. Where we transfer your personal data outside the European Union (EU) / European Economic Area (EEA) to which GDPR (General Data Protection Regulation) applies, we will ensure that your personal data will be protected in a manner consistent with the legal requirements, applicable to the personal data, such as:
the country to which we transfer your personal data is approved by the European Commission that it ensures adequate level of protection of personal data;
the recipient of your personal data ensures adequate level of protection, provides appropriate safeguards and has signed a contract based on standard contractual clauses, laid down by the European Commission that governs the processing of (your) personal data.
In other circumstances, the law may permit us to otherwise transfer your personal data outside the European Economic Area. In all cases, however, any transfer of your personal data will be compliant with the applicable data protection legislation.
PLEASE NOTE THAT WE DO NOT AND WILL NOT SELL PERSONAL INFORMATION OF OUR USERS TO THIRD PARTIES. We have also not sold any personal information to third parties in the preceding twelve (12) months.
Interest-based advertising
In our Solutions, we also allow advertising. We collect the abovementioned information from you and based on such information we build filtered audiences. Such audiences may be used in order to target and optimize advertising and promotions in our Solutions, and based on such profiles we are able to show you a tailored selection of ads that better match your interests (interest-based ads), but only if you give us your explicit consent to do so.
We also engage third-party ad providers and share some personal information with them. For the purpose of interest-based advertising we only use and share information you provide us voluntarily through different questionnaires, information about your age (based on a chosen birth year), your country of residence and information that is collected from you automatically through your device (including the persistent identifiers) with our advertising partners, based on your explicit consent. We will ask you for your consent before sharing any of the abovementioned personal information.
We show interest-based ads and we allow our advertising partners to show such ads to you if you are not less than 16 years old and you have provided us with an explicit consent for your personal information to be collected and processed for the purposes of interest-based advertising.
The Solutions are aimed at general audiences. Although there is nothing inappropriate in our Solutions and/or in our other contents we display, we pay a special attention to children’s privacy. We require from our users to provide us with information about their year of birth. If a chosen year of birth indicates the user is less than 16 years old, some restrictions will apply to him/her. Although some jurisdictions allow providers to collect and process personal data from younger users, our age gate is at 16 years of age.
We do not store the chosen year of birth of users who have identified themselves as below the age of 16 in our Solutions, but only the information that their device ID did not pass the age gate.
The features enabling potential collection and processing of personally identifiable information, with the exception of technical information automatically collected from the users through their use of our services are disabled for users who have identified themselves as below the age of 16. When collecting and processing the mentioned technical information (described in “Information automatically collected from you through the services” Section) we will not contact users under the age of 16 (no push notifications, no newsletters, no other e-mails, etc.), display interest-based advertising to them, nor do any user tracking. The underage users will not be able to participate in raffles, prize draws, sweepstakes or other promotional activities. The only personal information we collect from users who have identified themselves as below the age of 16 for the purposes of offering our services are device identifiers or persistent identifiers such as IP address, IDFA, IDFV, Android Ad ID.
Please note that ads may be displayed also to users of less than 16 years of age, but these ads will not be interest-based and will be served only from ad networks which are in compliance with The Children’s Online Privacy Protection Act (COPPA) and with Google Play’s ad network requirements.
If we discover that we collected personal information from a child under 16 years of age, other than the technical information automatically collected from the users through their use of our services, we will take reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at dpo@engagefactory.com.
Security of our users’ information is our priority and we have implemented appropriate technical and organizational measures to protect confidentiality, security and integrity of the collected information and to prevent unauthorized access and the use of information contrary to this Privacy Policy. In addition, we require that our service providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us.
Even so, no security measure is perfect and we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.
We store your personal data you give us for as long as needed to provide you with our services or until you ask us to delete them, unless otherwise set out in this Privacy Policy. In case you request us to delete your data, we will proceed do so in accordance with your right to erasure described below (see also »Your rights« Section). We may retain your personal data beyond that period if necessary, for legal, operational or other legitimate reasons. You can also unregister and delete the Solution from your mobile device and consequently delete associated personal data at any time through.
We may store non-personal information (device information, information about application usage etc.) for an unlimited period of time. Some non-personal information is combined with personal information, but only until the personal data is not deleted. When your personal data is deleted, non-personal information related to your usage of application is anonymized.
As our user, you have the rights explained in this section in accordance with applicable laws. If you want to exercise any of your rights or receive further explanation about them, please contact us via the contact details at the bottom of this Privacy Policy. Please note that some of these rights may be connected to certain statutory preconditions and thus might not be applicable to you and your specific situation.
Right of access: You may have the right to confirm that we are processing and gain access to your personal data. Should you have any questions regarding the processing, or would you like to have more insight in the personal data about you that we process, you are always welcome to contact us, and we will provide you with further information. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may limit your access if such access would adversely affect the right and freedoms of other individuals. We will try to respond to any request for a right of access without undue delay and free of charge, except where we are permitted by law to charge a fee.
Right to object: You have the right to object to the processing of your personal information. If you choose to object to our processing activities, you might not be able to use all of our services. However, we reserve the right to continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law. You are always free to opt-out from the future collection of your personal information by us and our partners by uninstalling all the Solution from each of your computing devices.
Right to rectification: We try to keep the information that we hold about you accurate and up to date. In case you realize that any of the information that we hold about you is incorrect, please contact us and we will correct it without undue delay. You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Please note that we may limit your access if such access would adversely affect the rights and freedoms of other individuals.
Right to withdraw consent: Where our processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right to erasure (right to be forgotten): You may have the right to request from us to permanently delete your personal data. You can make such a request if you, for example, believe that the personal data is no longer necessary in relation to the purpose for which your personal data was collected or otherwise processed. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in a pseudonymized form.
Right to restrict the processing activities: You have the right to request a restriction of the processing of your personal information, but please note that if you choose to restrict our processing activities as it relates to providing the Service, you might not be able to use them.
Right to data portability: You have the right to request that we provide you with the personal information which you have provided to us in a structured, commonly used and machine-readable format, so you can transfer this information to another data controller.
Right to lodge a complaint: If you are unsatisfied with the way we treat your personal data and you believe we have infringed or violated your privacy rights, please contact us so that we can work to resolve your concerns. You also have a right to lodge a complaint and to do so, contact the supervisory authority in your country of residence. In accordance with the GDPR's jurisdictional provisions, individuals whose personal data is being processed may lodge a complaint with the supervisory authority competent in the individual Member State of the individual. The contact details of the supervisory authorities in each Member State can be found at the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
The legal bases on which we rely on to process your personal information include:
Your consent (article 6(a) GDPR): We ask for your consent to use your data for a particular purpose, especially but not only for interest-based advertising, sending newsletters and push notifications. Where we ask for your consent, we will make this clear at the point of collection of your personal data.
Necessity of the performance and enforcement of our terms (article 6(b) GDPR): This covers information that is processed by us in order to provide you with our Service, to improve our services, to provide customer support, to deliver special features in our Solutions. Please note that with using our Service, you enter into contractual relationship with us.
Necessity for the purposes of the legitimate interests (article 6(f) GDPR): This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue legitimate interests in order to ensure you have the best experience when using our Service, to make sure your information is secure and to provide our Service free of charge or at a low cost. We pay special attention to your data protection rights, making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications and advertising purposes.
Necessity of compliance with a legal obligation (article 6(c) GDPR): This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.
The controller of personal data processed in accordance with this Privacy Policy is Engage Factory Ltd, a limited liability company, incorporated under the laws of the Republic of Slovenia (member of the European Union), with registered office at Trg komandanta Staneta 8, 1000 Ljubljana, and registered in Slovenian Business Register and Court Register under the registration number 9336664000.
If you have any questions, comments or concerns about this Privacy Policy or our practices, please contact us by writing to:
Data Protection Officer - dpo@engagefactory.com
or our local Data Protection Authority by writing to:
Informacijski pooblaščenec
Dunajska cesta 22, 1000 Ljubljana, Slovenija
or gp.ip@ip-rs.si or by calling to +386 1 230 97 30
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