Last Revised: September 2020
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
- Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services (as detailed in Sections 4 and 6 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 7 below). Such data consists of connectivity, technical or aggregated usage data, such as IP address, unique advertising ID, non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, and in-App events. We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 4 below.
- Data received from you: you may provide us Personal Data voluntarily, such as when you contact us (through Facebook, Messenger, e-mail or any other channel, including any support services), when you post on our public forums or groups, when you provide us your e-mail address (such as when you sign-up to receive e-mail updates or gifts), when you place any purchases in any of our App, when you interact with other users or when you choose to connect your Facebook account to any of our App Services.
- Transaction Data: In-App purchases will typically be processed by the relevant platform provider (e.g. Apple or Google), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Apps and through other channels, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.
Accordingly, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our players, and allow them access to additional features;
- To provide our users with customer care, assistance and technical support services;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-App progress and activity, based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;
- To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as App updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
Our Apps include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Such data includes your device advertising identifiers (e.g. IDFA or Advertising ID to the extent available), data related to your connected Facebook profile (if any, such as your gender, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis.
The ads we or our advertising partners deliver may be shown within our Apps, our Services, or through other channels, such as third party websites and applications.
How to adjust your preferences regarding interest-based advertising
If you wish to prevent the use of your device’s advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users).
Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see aApp, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the App, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
Your Personal Data may be maintained, processed, accessed and stored by Dragon Intelligence Inc. and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. Dragon Intelligence Inc. is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, Dragon Intelligence Inc. has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction. Where we transfer Personal Data of EEA users to countries outside the EEA which are not considered by the European Commission to offer adequate protection, we generally make such transfers subject to approved data transfer agreements, or in the case of transfers to the USA, we transfer to recipients which are Privacy Shield certified.
We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates - but only in accordance with this policy:
- Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
- Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook account to a certain App or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple or Google) - so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
- Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Dragon Intelligence Inc., any of our users or any members of the general public.
- Dragon Intelligence Inc. Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Policy. In addition, should Dragon Intelligence Inc. or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
For the removal of doubt, Dragon Intelligence Inc. may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Websites and Services as a whole.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you wish not to receive such promotional communications, you may notify Dragon Intelligence Inc. at any time by e-mailing us at email@example.com or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
In case we process Personal Data about you and if you are an EU resident or the resident of another jurisdiction that affords you with the below rights you:
- Have the right to know what Personal Data we maintain about you.
- May, at any time, access, correct, request deletion, request restriction of our process of your Personal Data or object to the processing of your Personal Data, as set by applicable law.
Please note that if you ask us to delete or restrict how we use or process your Personal Data, subject to applicable law, we may not be able to provide you with all of our Services and customer support or the quality of the Services may be diminished.
- May ask to transfer your Personal Data in accordance with your right to data portability.
- Have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) please contact us at firstname.lastname@example.org.
Please note that your request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we processed Personal Data or an authorized representative.
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Please note that the above mentioned rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
If you wish to manage the information we receive about you from a third-party application or platform where you use our App, such as Apple or Google, please follow the third-party application’s instructions for updating your information and changing your privacy settings.
The App and Services are available only to individuals who are the greater of Thirteen (13) years of age or the age of legal majority in your jurisdiction. We reserve the right to request proof of age at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Apps, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us.
If you believe that we might have any such data, please contact us at email@example.com.
In accordance with the CCPA, you have the right to request: (i) that we disclose what Personal Data we collect, use or disclose, (ii) the deletion of your Personal Data as collected or maintained by us; (iii) to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA – in accordance with the CCPA, using the methods we made available herein.
You can designate an authorized agent to make a request under the CCPA on your behalf, in accordance with the CCPA, using the methods we made available herein.
Selling Personal Data