OVERVIEW

White crow game studio provides free mobile games and will process your personal information when you play our games.  If you have any questions about our data practices, your rights or have any concerns or complaints, you can contact us at support@whitecrowgames.org

We collect personal information from you directly, e.g. when you play games, and also generate information about your use of our games, including game play and log data. If you log in to a game with your social media account, we will receive information about you including your basic profile information, profile picture and friends list. We also receive information from third parties such as social media platforms and fraud detection providers.

We use your information to provide you with our games, support and analyze your use, and improve them. We will also use your information to respond to your questions. We use your information to show you ads targeted to you in our games.  You can choose to stop receiving these at any time, by opting out or changing your device settings. 

We rely on third parties for the purposes set out in the privacy policy, including support services, such as support ticketing and game analytics.  We also work with certain advertising partners to show you ads. Additionally, we share your information within our group and as required by law. 

We are located in Ukraine where we process your information.  Some of our providers are located in the EEA or the United States.

You may have rights to access, receive a copy of, or delete, your information or restrict processing of your data, and you also have the right to object to our use of your information for certain purposes, including tailored marketing and advertising. 

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you in-Game.

Thank you for playing our games! This Privacy Policy (“Policy”) describes the way we collect and use your Information (as defined below) and informs you of your choices in relation to your Information. In this Policy, “White Crow game studio”, “we” or “us” refers to White crow game studio.

For the purpose of this Privacy Policy, “Information” means any information relating to an identified or identifiable individual.  This includes Information relating to your use of: (a) our mobile (“Mobile Games”); and (b) our games which can be accessed through Facebook (“Facebook Games”).  When you use the Mobile Games or Facebook Games (the “Game”), you accept our rules and policies which describe how we handle your Information, and you understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy.

Information you may provide us such as:

• Contact Information (such as name and email address) if you contact us for support
• Your messages to the Game (such as chat logs and player support tickets)
• Other Information you choose to give us (such as to identify a lost account)
• Information we collect automatically or that is generated about you when you play the Games:
• Information regarding your use of the Game: such as data about your use of the Game, for example, game progress, gameplay data and your interactions with other players inside the Game.
• Identifiers: such as your IP address, device ID and White crow game studio specific ID.
• Cookies and similar technologies: Information we collect with cookies and similar technologies. We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using the Games. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies or instruct the device or web browser to provide notice at the time of installation of cookies or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed. 

1. What is a cookie?

Cookies are text files containing small amounts of information which are placed onto your device when you visit a website. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website as to generally improve the user experience.

Functions usually performed by a cookie can also be achieved by other similar technologies, such as log files, pixel tags, web beacons, clear GIFs, device IDs. In this Cookie Policy we will be referring to them collectively together as “Cookies”.

2. How do we use Cookies?

Our website uses cookies necessary to make it work, and to analyze how our website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve our website.   

3. What types of Cookies do we use?

• The types of Cookies used by us and our partners in connection with our website are necessary ‘Analytic Cookies’. 

We use Google Analytics on our Website to analyze your use and current IP address. This information will be transmitted by Google to its servers in the US and other countries. On our behalf, Google will use this information to evaluate your use of the website. The IP address collected will not be associated with any other data held by Google. 

4. How to control or delete Cookies.You do not have to accept all of the cookies used by our website. If you reject certain cookies, however, you may not be able to use some of the features of our website. Your browser may be configured to allow you to refuse or delete cookies or to be notified when a cookie is stored on your device. To change your web browser for cookies, you can follow the instructions in the help section of your web browser or visit allaboutcookies.org.

Please note that by deleting or blocking cookies that are strictly necessary for the performance of our website, it may not function correctly, and you may not be able to access certain areas of the website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

5. Contact us support@whitecrowgames.org

• Information collected from advertising partners: device ID and information on your interactions with advertising shown in our  Mobile Games.
• Information from mobile measurement partners: we receive information from third parties to allow us to track performance of our marketing campaigns and to detect fraud in such campaigns.  This includes advertising ID, IP address, device ID, device name and operating system, language and location.
• Analytics information: we receive analytic information from third party analytics providers regarding our Mobile Games to optimize user interaction with our Mobile Games.
• Information regarding your use of the Game: such as details regarding profile visits, as detailed in the section “Multiple Devices” below.
• Information regarding confirmation of payment from App Stores when you purchase boosters, coins  or bundles in our games we receive confirmation of your purchases from Google Play or the IOS App Store. The purchase confirmation includes your device ID, confirmation number and details of the boosters, coins or bundles that you purchased.  

Multiple Devices – Information we receive from third party platforms:  You can choose to link a third party tool with the Game (such as logging in with your Facebook account or another social network or third-party account) (“Third Party Services”). Depending on your settings, we will receive some of your Facebook or other social network or third-party login account information such as basic profile information you have already provided to any third party log-in service and/or app store and/or play store and/or the Amazon Appstore, when accessing our Games and may be able to offer you additional functionalities, including inviting friends, seeing their Game progress and private messaging with other players. In addition, you will be able to log in on multiple devices and synchronize your progress in our Games, across multiple devices on multiple platforms.  To enable us to provide these in-game social features we will receive and process your geolocation, service provider, VPN and Game behavior such as current level, number of times it takes to complete each level and other behavior directly related to Game play.

If you access any games through  Third Party Services, you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the Games) in accordance with their own terms and privacy policies.  The privacy practices described in this Policy do not apply to Third Party Services.

• Provide you with the Games: To perform our contractual obligation towards you to allow you to play the Games (and interact with other players, if applicable), we process necessary Information including Information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, information regarding your use of the Games and information regarding your in Game purchases.
• Improve the Games: It is in our legitimate interests to improve our Games for our players. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device.
• Provide you with support and to respond to your requests or complaints: If you reach out to us for support, we will use your Information to open a support ticket, respond to your emails and resolve your queries and complaints and to facilitate support (e.g. retrieval of Game level). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your identifiers, White Crow game studio specific ID, where you are located and any other information about you collected via our player support channels.
• Conduct analytics: It is in our legitimate interests to analyze the use of and form, our Games and advertising campaigns, and any other interaction or interest in the same. When doing so we will process information we automatically collect or is generated about you when you play the Games or interact with our advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; (c) conduct predictive analytics about your interests; (d) to determine the levels  you have played and how may times it took to complete a level in order to improve player satisfaction and  improve level design.  
• Provide you with advertising: We will present you with ads and suggestions in our Games and elsewhere. These may be ads relating to our own Games or other services you may be interested in.  These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent.  In situations where your consent is not required, or where we provide contextual advertising, we do so on the basis of our legitimate interests. 
• Prevent fraud, enforce our terms and to comply with our legal obligations: It is in our legitimate interest to protect our interests and to keep the Games and their social features safe and fair by (1) analyzing and monitoring Game use to detect fraud or any other user behavior which prejudices the integrity of our Games, (2) taking steps to remedy such fraud and behavior and (3) enforcing our terms and policies. When doing so, we will process the relevant Information, including Information you provide us, Information we automatically collect about you, and Information which is provided to us by third parties.
• Send you updates about in-Game offers and our other Games and services that may be of interest to you. We will send you promotional offers, and information about other products and services that may be of interest to you via push notification or in Game.  Where it is required, we will only do so where we have your consent.  When doing so, we process the analytics information above. Your consent can be withdrawn at any time by adjusting your device settings for push notifications. In addition, we will send you information regarding updates and/or security alerts in Game.
• Provide social features. We may offer Game competitions and other social features such as team play, chat, sharing lives with teammates and other cooperative team activities. The information we process to provide you with social features includes your chat name, chat history, teammate and game play information.

We share your Information with selected third parties, including:

• Other players and users: Because social features are a core component of our Games, other players and users may see your profile information and in-game activities, as well as any other information you choose to share with them, such as chat data.
• Vendors and service providers we rely on for the provision of the Games, for example:
• Cloud service providers who we rely on for data storage, including Amazon Web Services who are based in the U.S.;
• App Stores to allow you to make purchases via Google Play, IOS App Store, and maintain a record of such purchases. The information we are provided with includes your device ID and the in app purchase activity to enable us to provide you with the items you purchase from such App Stores.
• Player support solution providers, who help us manage and respond to our player questions and complaints. This includes HelpShift, Inc. who is based in the U.S. and who hosts our player support function;
• Analytics providers: We work with a number of analytics, segmentation and mobile measurement service providers who help us understand our user base. This includes DeltaDNA, who is based in the United Kingdom,  and AppsFlyer and Firebase, who are based in the United States;
• Social media: Should you play our Games via Facebook, social media interaction tools may be utilized to enhance social media features in the game such as accessing your friends list and displaying your profile picture;
• User acquisition: We work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your personal information to participate in Custom Audience and Lookalike Audience programmes, which enable us to display adverts to both existing and prospective players when they visit one of our partners’ websites. 
• Advertising partners: Our Games are supported by ads. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities.
• Law enforcement agencies, public authorities or other judicial bodies and organizations:  We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).
• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

Our service is global by nature and your Information can be collected from players anywhere in the world. Currently your Information is processed by our employees and service providers in the European Economic Area (“EEA”), and the USA. Israel and the UK are countries which the European Commission has decided offer an adequate level of data protection. Because countries outside of the EEA may have different data protection laws, we take steps to ensure that all transfers are protected by adequate safeguards, including the use of standard contractual clauses approved by the European Commission.

You can opt-out of interest-based advertising in our Games by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android). For personalized in-Game offers opt-out, you can use the options provided in the Game settings.

If you are based in the EEA, Switzerland or are a legal resident of California in the United States, you have certain rights in relation to your Information. For California residents, please refer to Addendum 1 – California Privacy Rights. For EEA and Switzerland based, you will find more information below on when which rights can apply.

• Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals. To exercise this right, please email us at support@whitecrowgames.org with details of what Information you would like access to and include your player ID which is located in the lower left corner of the “Settings” screen of our Games.
• Erasure. If you would like us to erase your Information, please contact us at support@whitecrowgames.org.  We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defense of legal claims, to respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case.

Note that where the Information is held by a third party data controller, such as an advertising partner, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your Information containing personal data is erased.

• Objection and withdrawal of consent. You may have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests.
• Correction. You have the right to correct any Information held about you that is inaccurate.
• Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.
• Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.

• Security Safeguards: In order to help ensure a secure and safe player experience, we are continuously developing and implementing organizational, technical and physical security measures to protect your Information from unauthorized access or against loss, misuse or alteration. These measures include hashing of Information, segregating and limiting access to Information and requiring two factor authentication to access Information.
• Retention: We retain your Information for as long as needed to provide you the Games and up to three (3) years from the date on which you stop interacting with the Games.

Our Games are not intended for or targeted at children. We do not knowingly collect or solicit Information about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to play our Games. If you are under 13, do not play our Games or use or provide any information on our Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@whitecrowgames.org.

We welcome questions, comments and requests regarding this Policy. These should be addressed to support@whitecrowgames.org.    

If you wish to make a complaint about how we process your Information, please contact us at support@whitecrowgames.org and we will endeavor to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the Website and in Game. Your continued use of our Website and/or Mobile Games after the effective date of any changes will be subject to the new Policy.

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act (“CCPA”) and related applicable laws.

Collection and Disclosure of Personal Information

Over the past 12 months, through your use of the Games, we may have collected and disclosed the following categories of personal information, as defined in the CCPA, from or about you:

• Identifiers, including IP address, device identifiers, advertising ID and White Crow game studio specific ID. This information is collected directly from you or your device. 
• Internet or other electronic network activity information, including your use of in-game features and events and information on your in-game activity, and information on your interactions with advertising shown in on our Games. This information is collected from our selected third party analytics providers and advertising partners.
• Geolocation data, including city level location data. This information is collected directly from your device.

We collect personal information for the following purposes:

• To operate and administer the Games;
• To improve the Games;
• To communicate with you;
• To serve advertising;
• For security and verification purposes, including to prevent and detect fraudulent activity; and
• To address and remediate technical issues and bugs.

We may disclose personal information to the following types of entities:

• Other players and users should you choose to share chat data via a Game with a chat feature;
• Our affiliate companies within our corporate group who process personal information in order to operate the Games;
• Marketing and advertising partners who use your information to serve you ads in the Games and on other sites;
• Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us;
• Regulators, judicial authorities and law enforcement agencies;
• Entities that acquire all or substantially all of our business.

Over the past 12 months, we have used third party advertising and other tracking technologies on our Games to collect information about you, your device(s), and your use of our Games.  We share that information with selected third parties such as advertising partners who use it to target advertisements to you online.  To opt out of the sale of personal information please contact us at support@whitecrowgames.org.

The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:

• Request we disclose to you, free of charge, the following information covering the 12 months preceding your request:
  • the categories of personal information about you that we collected;
  • the categories of sources from which the personal information was collected;
  • the purpose for collecting personal information about you;
  • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
  • the specific pieces of personal information we collected about you;
• Request we delete personal information we collected from you; and
• Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.  

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

You can exercise your rights, including opting out from the sale of personal information (Do Not Sell My Personal Information) by emailing us at support@whitecrowgames.org.

The Lei Geral de Proteção de Dados (the “LGPD”) provides residents of Brazil with certain legal rights; these rights are not absolute and are subject to exemptions. For Brazilian players, these provisions supersede any other possibly divergent or conflicting provisions contained in this Policy.
This part of the document uses the term “personal information” as it is defined in the LGPD.

Categories of personal information collected and processed

How we use your personal information

Your rights under the LGPD

You have the right to:

• Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
• Request that personal information be corrected.
• Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
• Obtain information on the possibility of refusing consent and the consequences of doing so.
• Obtain information about the third parties with whom we share your personal information.
• Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
• Revoke your consent at any time.
• Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.

You can file your request to exercise your rights free from any charge, at any time, by contacting us at support@whitecrowgames.org.

Last updated December 9th, 2023