A. GENERAL
This Privacy Policy ("Privacy Policy") describes how we, Soft Game Studios, collect, use, disclose, and safeguard information when you (“User”, “you” or “your”) download, access, or use our mobile application, together with any related content, features, and services (collectively, the “App”).
This Privacy Policy is incorporated into, and constitutes a part of, our Terms of Service and/or any other applicable terms of use (“Terms”) governing your use of the App. Any capitalized terms used in this Privacy Policy that are not defined here have the meanings assigned to them in the Terms. To the extent permitted by applicable law, if there is any inconsistency between this Privacy Policy and the Terms, the Terms will control.
In this Privacy Policy, where applicable law differentiates between privacy roles (for example, a "Controller" under the GDPR or a "Business" under certain U.S. state privacy laws), we are the party that determines the purposes and means of the processing described in this Privacy Policy.
This Privacy Policy applies globally to any individual who downloads, accesses, or otherwise uses the App. Some jurisdictions, including the European Economic Area and U.S. states such as California, grant additional privacy rights and impose additional disclosure requirements. Where relevant, those additional notices are provided in the applicable sections below.
B. DATA WE PROCESS
This section explains the categories of data we process, including the data we collect, the purposes for which we process it, the lawful bases we rely on (where applicable), and how the data is processed. Depending on how you interact with us, we may collect the following categories of information:
Non-Personal Data
While you interact with our App, we may collect aggregated information that does not identify a specific individual and cannot reasonably be used to do so (“Non-Personal Data“). Non-Personal Data may be collected automatically in connection with your access to and use of the App, and may include aggregated metrics, and similar information.
The Non-Personal Data we collect may include certain software and hardware information, as follows:
We may share or disclose Non-Personal Data with third parties as described below, and solely where applicable.
Personal Data
In addition, during your access to or interaction with the App, we may collect information that identifies an individual or that could, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The categories of Personal Data we collect and the purposes for which we process such data are set out below.
For clarity, you may use the App without providing any contact information. We also collect your IP address when you use the App. Although an IP address is not treated as personally identifiable information in many jurisdictions, in some jurisdictions (such as the EU) it may be considered Personal Data. Accordingly, we treat your IP address as Personal Data in accordance with applicable law.
If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.
We do not knowingly collect or process Personal Data that constitutes or reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor do we knowingly collect genetic data, biometric data, data concerning a person's health, or data concerning a person’s sex life or sexual orientation.
The table below sets out the Personal Data we collect and how it is processed, including the purposes, lawful bases, and processing operations:
DATA SETS | PURPOSE AND OPERATIONS | LAWFUL BASIS UNDER THE GDPR |
|---|---|---|
Contact Information: If you voluntarily contact us for support or other inquiries, you may be required to provide us with certain Personal Data, such as your name, email address, etc. | We process this data to deliver the support you requested and/or to reply to your inquiry. We may also process and retain our communications with you to improve customer service and, where we reasonably consider ongoing retention necessary, for example, in connection with potential claims or to provide additional assistance (if applicable). | We process this data based on our legitimate interests, except where you contact us for support, in which case providing that support forms part of our contractual obligations to you. |
Online Identifiers and usage data: When you access our App, certain information about your use of the App is collected automatically, including how you interact with the App. | We process this data to operate and maintain the App, help detect and prevent fraudulent activity, and support the security of the Users. | Where this data is collected for operational and security purposes, we process it on the basis of our legitimate interest. |
Device Information: When you use the App, we automatically collect certain information about your device, including your device model, device ID, IP address, device token, cellular network details, and similar data. | We use this information to operate and maintain the App, help prevent fraudulent activity, and support Users’ security. | Where this information is collected for operational and security purposes, we process it based on our legitimate interests. |
Permission Data: Some features of the App require access to device permissions ("Permissions"). The specific Permissions we request depend on the feature you choose to use and may include: (i) Software Inventory Permission - list of applications installed on your device; (ii) Telephony Permission - access to your call history and contacts; (iii) Data Storage Permission - collecting information from your device storage; (iv) Network Permission - access to your network settings, including detected devices and networks, and your connection history. | We use this data to enable and operate the relevant App features. | We process your data based on your consent, as provided through the in-app permission notice and Google native permissions screens. |
SDK Data: By using third-party software development kits (“SDK”), we may display certain promotional content within the App (“Ads”). As a result, we or our advertising partners may process various data about you, including your IP address, browsing/activity information within the App, advertising ID, and similar identifiers. | We use this data to display Ads, including personalized Ads where permitted, and to measure and improve advertising performance. We may share the advertising ID with advertising partners to help deliver and measure Ads across different apps and services, where applicable. | We will process this data subject to your consent, where required by applicable law. |
Please note that the specific processing operation applicable to each purpose of use and lawful basis set out in the table above may differ. In most cases, a processing operation consists of a series of automated activities, such as collecting, storing, using, disclosing by transmission, erasing, or destroying data. The transfer of Personal Data to third-party countries, as described further, is carried out based on the same lawful basis specified in the table above.
In addition, we may process certain Personal Data to help prevent potentially prohibited or unlawful conduct, fraud, misappropriation, infringement, identity theft, and other misuse of the App; to enforce the Terms; and to protect the security and integrity of our databases and the App, including by taking precautions to reduce legal exposure. This processing is performed on the basis of our legitimate interests.
C. DATA COLLECTION
Based on the nature of your interaction with the App, we may collect information in the following ways:
D. COOKIES AND SIMILAR TECHNOLOGIES
We and/or our service providers and partners may deploy SDKs, cookies, pixels, and comparable technologies (“Tracking Technologies”) in order to:
Advertising ID Controls: Depending on your device settings, you may be able to reset your advertising identifier or restrict its use through your device's privacy/ad settings.
E. DISCLOSING DATA TO THIRD PARTIES
We may share your Personal Data with the recipient categories set out below:
Service providers and contractors (for example, cloud hosting, analytics, crash reporting, customer support tools, marketing tools, fraud prevention providers). They may process Personal Data to the extent necessary to provide services to us and are generally subject to contractual obligations relating to data protection and security.
Advertising and measurement partners, to show ads and to measure advertising performance, and, where applicable, to facilitate interest-based/personalized advertising.
Government authorities and other lawful requesters, where disclosure is required or permitted by law and where needed to protect rights, safety, and security.
Affiliates (if any), for internal operations, support, and improvements, in a manner consistent with this Privacy Policy.
Counterparties to corporate transactions, in connection with an actual or potential merger, acquisition, financing, asset sale, or similar transaction.
After we share information with a third party, that third party's privacy practices may also apply to the information.
F. DATA RETENTION
We retain Personal Data for the period reasonably necessary to:
When information is no longer required, we may delete, de-identify, or anonymize it, unless applicable law requires its retention.
G. SECURITY MEASURES
We maintain physical, technical, and organizational safeguards intended to reduce the risk of unauthorized access to, use of, alteration of, disclosure of, or loss of Personal Data. However, no security measure is perfect, and we cannot guarantee absolute security.
Please contact us at softgametech24@gmail.com if you believe your privacy was not handled appropriately, in a way that breaches this Privacy Policy, or if you become aware of a third party's attempt to obtain unauthorized access to any of your Personal Data. If we discover a security incident involving your Personal Data, we will make reasonable efforts to notify you and the relevant authorities (where required by applicable law).
We may implement what we consider appropriate practices for data collection, storage, processing, and security.
H. INTERNATIONAL DATA TRANSFERS
If we need to transfer your Personal Data outside your jurisdiction, we will take appropriate steps to ensure your Personal Data is provided an adequate level of protection, as required under applicable law. In addition, where Personal Data collected within the European Economic Area ("EEA") is transferred outside the EEA to a country that has not received an adequacy decision from the European Commission, we will take the necessary measures to ensure appropriate safeguards are in place for such transfers, in line with the standard contractual clauses approved by the European Union. Accordingly, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections pre-approved by EEA and UK regulators to ensure your data is protected (known as standard contractual clauses), or we will rely on adequacy decisions adopted by the European Commission. Certain assurances may also take the form of well-recognized certification schemes.
To request more information about these safeguards, contact us at softgametech24@gmail.com.
I. YOUR RIGHTS REGARDING PERSONAL DATA
We recognize that privacy concerns and preferences vary among individuals. Our aim is to explain, in a transparent manner, what information we collect so you can make informed and meaningful decisions about how that information is used. We enable you to exercise certain choices, rights, and controls in relation to your information. Depending on your relationship with us, your jurisdiction, and the applicable data protection laws, you may have the right to request that certain rights be exercised or that certain limitations apply.
The table below allows you to review your rights based on how you interact with us, the ways to exercise those rights, and how you may appeal a decision we make on such requests. Any geo-location or territory-specific details are provided beneath the table.
Right to be informed, right to know | You are entitled to receive information about how we collect Personal Data and about our privacy practices. These matters are described in this Privacy Policy. |
|---|---|
Right to access and correct | You have the right to request access to the Personal Data we hold about you and to ask that it be corrected if it is inaccurate or incomplete. |
Right to correction | You may request that we rectify any inaccuracies in your Personal Data, considering the nature of the data and the purposes of the relevant processing activities. |
Right to deletion, objection, and withdrawal | You may have the right to request deletion of your Personal Data, to object to or restrict certain processing of your Personal Data, and to withdraw your consent at any time (where we rely on consent). If you have questions about data protection or wish to make a request relating to your Personal Data, we encourage you to contact us first so we can respond as promptly as possible. We will respond to all requests within a reasonable timeframe. |
Right to portability | You may request, at any time and using the methods described below, a copy of the Personal Data associated with you that we currently maintain. Upon request, we will provide this information in an electronic format within thirty (30) days. |
The right to opt out of advertising and/or marketing materials | You can opt out of receiving advertising and/or marketing messages by following the opt-out instructions included in those communications or by using the relevant options available in your device settings. |
Right to appeal or complaint | You have the right to lodge a complaint with the relevant supervisory authority in your country of residence. |
Non-discrimination | Such discrimination can include refusing to provide a service, offering a different level or quality of service, or charging different prices. We do not discriminate against our customers or Users. |
Additional rights for US residents are described below.
J. JURISDICTION-SPECIFIC NOTICES
Additional Notice To California Residents
This section applies solely to California residents, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the California Privacy Rights Act, effective January 1, 2023.
This section does not address or apply to publicly available or to Personal Information that is otherwise exempt under the CCPA.
Categories of Personal Information Collected and Disclosed
While our processing of Personal Information depends on our relationship and interactions with you, the table below sets out the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we disclosed Personal Information for a business or commercial purpose.
Categories of personal Information | Do we collect this data? | Third-Party |
|---|---|---|
Identifiers | Yes: Online Identifier; Internet Protocol address | Affiliates Advisors and agents Advertising networks Data Analytics providers Social networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
F. Internet or other similar network activity. | Yes: information on a consumer’s interaction with a website | Affiliates Advisors and agents Advertising networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
G. Geolocation Data | Yes: approximate location derived from IP address | Affiliates Advisors and agents Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
Sources of Personal Information
As a general matter, we obtain Personal Information from the following source categories: directly and indirectly from you; affiliates; business partners; vendors and service providers; operating systems and platforms; and marketing and data analytics providers.
Purposes of Collection, Use, and Disclosure
As explained above, we may collect, use, disclose, and otherwise process Personal Data as described above for the following business or commercial purposes and as otherwise directed or consented to by you:
Sales and Sharing of Personal Information
The CCPA defines a "sale" as disclosing or otherwise making Personal Information available to a third party in exchange for monetary or other valuable consideration. The CCPA also defines “sharing” as disclosing or making available Personal Information to a third party for cross-context behavioral advertising purposes.
While we do not disclose Personal Information to third parties in return for monetary compensation, we may “sell” or “share” (as such terms are defined under the CCPA) the following categories of Personal Data in the following limited circumstances: We may “sell” or “share” Identifiers for purposes of cross-context behavioral advertising with third-party ad networks.
California Consumer Rights
California law provides consumers with certain rights and also restricts certain business practices, as described below. California consumers may request that we disclose the Personal Information we collect, use, disclose, and sell about you.
You may have the right to opt-out of the “sale” or “sharing” of your Personal Information. You can opt out of the sale/sharing of your Personal Information by emailing us at softgametech24@gmail.com
Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see "Submitting Requests" for instructions on how to exercise your rights.
You may exercise your rights by emailing us at [EMAIL]. When you submit a request, we will take steps to try to verify your identity. We will attempt to match the details in your request with the Personal Information we maintain about you. As part of the verification process, we may ask you to provide additional information and may use identity verification services to assist us. Please note that, depending on the request type, and in order to protect the privacy and security of your Personal Information, we will fulfill the request only if we are satisfied that your identity has been verified to an appropriate level of certainty. We will use reasonable efforts to respond within 45 days after receiving a verified request. If we cannot meet this deadline, we will respond as soon as practicable within an additional 45-day period.
Incentives and Discrimination
The CCPA prohibits discrimination against California consumers who exercise their rights under the CCPA and also sets requirements for any financial incentives offered to California consumers in connection with their Personal Information.
Discrimination: If consumers exercise their rights under the CCPA, businesses may not discriminate against them, including by denying goods or services, providing a different level or quality of goods or services, or charging or indicating that a business will charge different prices or rates or impose penalties, unless the differential treatment is reasonably related to the value provided to the business by the consumer’s data.
California’s Shine-The-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us with certain Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information we have shared (if any) with third parties for those third parties' own direct marketing purposes. Such requests may be submitted once per calendar year and relate to any relevant third-party sharing during the prior calendar year. If you are a California resident and wish to submit such a request, please send your request in writing to [EMAIL]. In your request, please attest to the fact that you are a California resident. This right is included solely to satisfy legal and regulatory notice obligations, and we do not share your Personal Information with third parties for their own direct marketing purposes.
ADDITIONAL NOTICE FOR U.S. RESIDENTS
Depending on your state of residence, you may be entitled to additional disclosures and/or privacy rights under applicable U.S. state privacy laws. If you believe you may be entitled to additional disclosures or rights under applicable law, please contact us at [EMAIL], and we will provide you with the relevant information and instructions on how to exercise such rights, as required by applicable law.
K. HOW TO EXERCISE YOUR RIGHTS
If you would like to exercise any of the rights described in section 6 above, you can contact us at any time by email at softgametech24@gmail.com.
Because the App does not allow you to create an account and you do not provide information to us directly (we collect information automatically), we may use limited verification methods. In general, we will verify your identity by matching the information in our systems with the information we are able to process when you submit your request. In certain cases, we may refuse to act on a request, primarily where we cannot verify your identity, for example, if you have disabled cookies, changed the device you used to access the App, or have already asked us to delete your personal data.
L. LINKS TO THIRD-PARTY SERVICES
The App may contain links to third-party websites, applications, or online services. We do not manage or control third-party practices and are not responsible for their policies or conduct. We encourage you to review the applicable privacy policies of any third-party services before using or interacting with them.
M. CHILDREN
The App is not intended for and may not be used by children under 16 years of age. We do not knowingly collect or otherwise process Personal Data from children under 16. As a general rule, we do not process children's Personal Data on the basis of consent. If we learn that we have collected or otherwise processed Personal Data from a child under 16, we will take reasonable steps to delete such Personal Data, or, where required by applicable law, promptly obtain verifiable parental (or legal guardian) consent for the collection and processing. If you believe a child under 16 has provided us with Personal Data, please contact us at softgametech24@gmail.com.
N. PRIVACY POLICY UPDATES
We may update this Policy from time to time. The revised version will be posted together with an updated "Last Updated" date. If we make material changes, we will take reasonable steps to notify you and, where required, obtain your consent. Changes take effect upon posting or as otherwise stated in the notice.
O. CONTACT US
If you have any questions, requests, or complaints related to privacy, you can contact us at softgametech24@gmail.com.