Privacy Policy – Cleverside

Last Updated: 30 June 2023

This Privacy Policy applies to Cleverside’s games and website available via https://www.cleverside.com (together the “Services” or “games”, “websites” for individual categories). This Privacy Policy explains how we, and affiliated companies (collectively, “Cleverside” or “we”, “us”, “our”) collect, use, secure, and/or disclose or otherwise processes your Personal Data when you use our Services.

The data controller is Cleverside Ltd, with a registered address at 228, Makariou Avenue, Block A, office 113A, 3030, Limassol, Cyprus, e-mail: privacy@cleverside.com.

1. PERSONAL DATA WE COLLECT AND HOW WE USE YOUR PERSONAL DATA

1.1 While using our Services, we may ask you to provide us with certain personal data that can be used to identify you (“Personal Data”). We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing.

1.2 We described below the ways in which we use your Personal Data, categories of Personal Data we process, the legal bases we rely upon to do so.

How do we handle the Personal Data of game users?

(1) Purpose of the processing: to provide you with the game, check and improve the quality of games content, monitor and troubleshoot issues

Type of Personal Data:

Technical data, such as IP address; device name; OS name; device model; time zone of device; language of device; device ID advertiser ID (“Technical data”);
Usage data, such asdate and time you used the Services; features the you have used; interaction with advertisements; game progress, scores, achievements; other data generated when using the Services (“Usage data”)

Legal basis for the processing: Contract (Terms of Use)

(2) Purpose of the processing: to consider and reply to your support requests and other comments and questions that you sent to us via the games

Type of Personal Data:

Name
Email
Technical data
Other data that you provide in your query

Legal basis for the processing:

Legitimate interest

your interest is in receiving response to your query;
our interest is in ensuring good customer service, and providing you with the prompt personalized reply to your query

(3) Purpose of the processing: to better understand the users of our games and learn about your preferences

Type of Personal Data:

Technical data;
Usage data;
General location, namely country and state through your IP address (“Location”)

Legal basis for the processing:

Legitimate interest:

your interest is to play the games that best suit your interests
our interest is to understand our audience in order to attract and keep users

(4) Purpose of the processing: to serve advertisements, including personalized advertisements using third-party advertising networks

Type of Personal Data:

Technical data
Usage data (for personalized advertisements)

Legal basis for the processing:

Legitimate interest

your interest is in playing games fully or partially for free;
our interest is in monetize games while providing them to you fully or partially free

Consent – to show personalized advertisements

Please note that we do not process your payment information. Such data is processed by the respective app store from which you downloaded the game.

How do we handle the Personal Data of visitors of the website?

(5) Purpose of the processing: to ensure the normal operation of the website, to monitor technical problems in the webwork of the site and fix them

Type of Personal Data:

Technical data;
Usage data

Legal basis for the processing:

Legitimate interest:

your interest is in using our website free from any bugs;
our interest is in keep the website up and running

(6) Purpose of the processing: to consider and reply to your comments, questions and requests that you sent via the form Contact us

Type of Personal Data:

Name
Email
Other data that you provide in your query

Legal basis for the processing:

Legitimate interest

your interest is in receiving response to your query;
our interest is in ensuring good customer service, and providing you with the prompt personalised reply to your query

(7) Purpose of the processing: to better understand the visitors of our website and learn about your preferences

Type of Personal Data:

Technical data;
Usage data;
Location

Legal basis for the processing:

Legitimate interest

your interest is that our website is the best fit for your needs;
our interest is to understand our audience in order to attract new visitors to our site

2. RETENTION OF PERSONAL DATA

2.1 We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. In any case, we will retain your Personal Data for a maximum period of 3 years from your last interaction with the relevant Services or as long as it is necessary to respond to the query and 3 years after. At the end of the retention period, we will either anonymize your personal data or securely delete it from our systems, unless further retention is necessary as described below.

2. In certain circumstances, we may be required to retain your Personal Data for a longer duration as mandated by applicable laws or regulatory requirements. This could include, but is not limited to, situations involving legal proceedings, investigations, or government requests. We will only retain your data for as long as necessary to fulfill these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.

3. THIRD PARTIES PROCESSING YOUR PERSONAL DATA

3.1 We may engage third-party service providers to process your Personal Data for the purposes as described below:

Advertising Networks: We may partner with advertising networks to display advertisements, including personalized, within our games or on external platforms. These networks may collect certain information about your interactions with our game or other websites and applications to provide targeted advertising based on your interests and preferences. The list of such networks is provided in APPENDIX A below.

Analytics Platforms: To improve our Services nd enhance the user experience, we may utilize analytics platforms that collect and analyze data on our behalf. These platforms help us gather insights into user behavior, game performance, and demographic information. The data collected is aggregated and anonymized to ensure your privacy is protected. The insights obtained from these analytics platforms assist us in making informed decisions to optimize our game and provide better services. The list of such platforms is provided in APPENDIX B below.

Hosting Providers: We rely on trusted hosting providers to store and process your personal data securely. These providers ensure the availability and reliability of our game infrastructure, including servers, databases, and storage systems. While hosting providers may have limited access to your personal data, they are contractually bound to handle it in accordance with applicable privacy laws and regulations. The data center that we use is located in Canada, but despite the fact that this transfer is cross-border Canada is one of the countries that provide an adequate level of data protection.

Development Partners: We may collaborate with external partners who assist us in various aspects of game development, such as design, programming, testing, and localization. These partners may have access to your personal data only to the extent necessary to perform their respective tasks. We ensure that all our partners adhere to strict confidentiality and data protection standards.

3.2 We take appropriate measures to ensure that any third parties with whom we share your personal data maintain adequate safeguards to protect it from unauthorized access, disclosure, or misuse. We enter into contractual agreements with these parties to ensure they handle your data in compliance with applicable privacy laws and regulations.

3.3 We may disclose your personal data to third parties if required by law, regulation, or legal process. Additionally, in the event of a merger, acquisition, or other business transaction, your personal data may be transferred to the acquiring entity or other relevant third parties.

3.4 Please note that while we strive to work with reputable third parties, we do not have control over their activities or the information they collect. We encourage you to review the privacy policies of these third parties to understand how they handle your personal data.

4. COOKIES AND SIMILAR TECHNOLOGY

4.1 This section explains the use of cookies and similar technologies on our website. We use Google Analytics as the primary analytics tool to gather information about how visitors interact with our site. Please read this section to understand how these technologies work and how they may affect your privacy.

4.2 Cookies are small text files that are placed on your device when you visit a website. They serve various purposes, such as remembering your preferences, analyzing website traffic, and enabling personalized content.

4.3 We use Google Analytics to collect information about your interactions with our website. Google Analytics utilizes cookies to track and analyze data such as your IP address, browser type, device information, and website pages visited. This information helps us understand user behavior, improve our website, and enhance the user experience.

4.4 When you visit our website for the first time, we request your consent to use cookies. You have the option to manage your cookie preferences through your browser settings or by using the cookie banner provided on our website. Please note that disabling certain types of cookies may impact the functionality and performance of our website.

4.5 We may allow certain third-party service providers, such as Google Analytics, to place cookies on your device. These cookies are used solely for the purpose of collecting analytics data and are subject to the respective third party’s privacy policies. We do not have control over the information collected by these cookies or how it is used by third parties.

4.6 The information collected through cookies and similar technologies is used for statistical analysis, improving our website’s performance, and understanding user preferences. It is anonymized and aggregated to ensure your privacy is protected. We do not use this information to personally identify individuals unless required by law or for fraud prevention purposes.

4.7 If you wish to opt-out of Google Analytics tracking, you can install the Google Analytics Opt-Out Browser Add-on. This add-on prevents your data from being collected and used by Google Analytics for all websites you visit. You can find more information about opting out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

4.8 In addition to cookies, we may also use other tracking technologies, such as web beacons or pixel tags, to collect information about your interactions with our website. These technologies help us analyze trends, administer the site, track user movements, and gather demographic information.

5. OPT-OUT OF TARGETED ADVERTISING

5.1 We value your privacy and strive to provide you with transparent information about our data collection and usage practices. This clause outlines your rights and options regarding targeted advertising while using the Services.

5.2 Our Services may display advertisements tailored to your interests based on the data we collect about you and your device. This data includes the one described above in section 1 above. Targeted advertising allows us to deliver more relevant and personalized content to enhance your user experience.

5.3 You can opt-out of targeted advertising by adjusting your mobile app settings. Follow the steps below to modify your advertising preferences:

Open the mobile app on your device.
Navigate to the “Settings” or “Preferences” section.
Look for an option related to “Privacy” or “Advertising.”
Within the Privacy or Advertising settings, locate the “Targeted Advertising” or “Personalized Ads” option.
Toggle the switch or checkbox to disable targeted advertising.
Save or apply the changes

5.4 Please note that the specific steps may vary depending on your mobile device’s operating system and the version of our Services. If you encounter any difficulties or need further assistance, please contact us using the details provided above, however, we may redirect you to make the request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

5.5 Remember, opting out of targeted advertising does not eliminate all advertisements from the Services. It only reduces the level of personalization based on your interests.

6. AGE LIMITS

6.1 We recognize the importance of providing additional privacy protections for users who are minors. Our Services are designed for a general audience and are intended for individuals aged 16 years and older. Therefore, children under the age of 16 should refrain from downloading or using our Services. We do not knowingly collect personal information from children under the age of 16. If you believe that we may have inadvertently collected personal information from a child under the age of 16, or if you have any other relevant concerns, please contact us at the provided address, and we will take appropriate measures to promptly delete such personal data from our records.

7. YOUR RIGHTS AND OPTIONS

7.1 You have the following rights regarding your Personal Data:

Right of Access: You have the right to access a copy of the Personal Data we hold about you, along with any supplementary information.

Right to Rectification: You have the right to request the correction of incomplete or inaccurate Personal Data.

Right to Erasure: You can request the deletion or removal of your Personal Data in certain circumstances.

Right to Restrict Processing: You can request the restriction of processing your Personal Data under specific conditions, such as when its accuracy is contested, when the processing is unlawful, when we no longer need the data, or when you have objected to the processing.

Right to Data Portability: This right applies to information processed based on your consent or a contract. You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, and, if technically feasible, transmit it to another data controller.

Right to Object: If we rely on legitimate interests for processing your Personal Data, you have the right to object to such processing based on your specific situation. We will cease processing your Personal Data unless we demonstrate compelling legitimate grounds or for legal claims.

Right to Withdraw Consent: If you provided explicit consent for the processing of your Personal Data, you have the right to withdraw your consent at any time. If we have no other legal basis for processing your Personal Data, we will cease processing it upon receiving your withdrawal request.

Right to Lodge a Complaint: If you believe that our processing of your Personal Data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

7.2 Please note that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us using the provided contact information.

8. CALIFORNIA PRIVACY RIGHTS

8.1 This section applies to California residents and provides information about their rights under the California Consumer Privacy Act (CCPA):

Right to Know: California residents have the right to request that we disclose the categories and specific pieces of personal information that we have collected about them, the categories of sources from which the information was collected, the purposes for which the information was collected, and the categories of third parties with whom we have shared the information.

Right to Delete: California residents have the right to request the deletion of their personal information that we have collected, subject to certain exceptions as permitted by law.

Right to Opt-Out: California residents have the right to opt-out of the sale of their personal information. However, please, note, that we do not sell personal information to third parties.

8.2 We will not discriminate against California residents for exercising their rights under the CCPA. This means that we will not deny services, charge different prices, or provide a different level or quality of services based on their exercise of CCPA rights, unless permitted by applicable laws.

8.3 California residents may designate an authorized agent to make requests on their behalf. The authorized agent must provide written authorization, and we may require the California resident to verify their identity directly with us.

8.4 To exercise any of the rights described above, California residents may contact us using the contact information provided at the end of this Privacy Policy. We will respond to verifiable requests received from California residents as required by law.

8.5 We may request additional information to verify the identity of the individual making the request. This may include requesting information to match against information we have previously collected.

9. LINKS TO OTHER SITES

9.1 Our Privacy Policy may include links to websites operated by third parties that are not under our control. If you click on a link to a third-party website, you will be redirected to that website. We recommend reviewing the privacy terms of each website you visit. We have no control over and do not assume any responsibility for the content, privacy terms, or practices of third-party websites or services.

10. CHANGES TO THIS PRIVACY POLICY

10.1 We may periodically update this Privacy Policy. Your continued use of the Services after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously).

APPENDIX A – Advertising networks and their partners

AdColony

AdColony is an advertising service provided by AdColony Inc. (USA)

Amazon Developer

Amazon Developer is an advertising service provided by Amazon, Inc. (USA)

You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs

AppLovin and their partners

AppLovin is an advertising service provided by AppLovin Corporation (USA)

Facebook Audience Network

Facebook Audience Network is an advertising service provided by Meta Platforms Inc. (USA) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service, except for users who are based in California and exercise their right to opt-out.

You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.

Fyber

Fyber is an advertising service provided by Fyber Group. (Israel)

Google AdMob and their partners

AdMob by Google is provided by Google Inc. (USA)

For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/

For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903

You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

Google AdSense and Ad Manager

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/

HyprMX

HyprMX is an advertising service provided by HyprMX Mobile LLC (USA)

Note: It is used only for users in the USA

InMobi

InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)

Opt-out: https://www.inmobi.com/page/opt-out/

IronSource

IronSource is an advertising service provided by IronSource, Inc. (USA) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.

Maio

Maio is an advertising service provided by i-mobile Co., Ltd. (Japan)

MoPub and their partners

MoPub is provided by MoPub, Inc. (USA)

For more information on what information MoPub collects and how it’s used, please read MoPub Privacy Policy: https://www.mopub.com/legal/privacy/

For more information on MoPub Partners, please visit: https://www.mopub.com/legal/partners/

You can opt-out from MoPub service by following the instructions on MoPub Opt-out page: https://www.mopub.com/optout/

MyTarget

MyTarget is an advertising service provided by My.Com B.V (Netherlands)

Nend

Nend is an advertising service provided by F@N Communications, Inc. (Japan)

Ogury

Ogury is an advertising service provided by Ogury Ltd (UK)

Pangle

Pangle is an advertising service provided by Bytedance Pte. Ltd. (Singapore)

Smaato and their vendors

Smaato is an advertising service provided by Smaato, Inc. (USA)

Privacy Policy: https://www.smaato.com/privacy/ For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/

Snapchat

Snapchat is an advertising service provided by Snap Inc. (USA)

Unity Ads

Unity Ads is an advertising service provided by Unity Ads Inc. (USA)

Vungle

Vungle is provided by Vungle, Inc. (USA)

You can opt-out from Vungle service by following the instructions as described by Vungle on their Privacy Policy page: https://vungle.com/privacy/

Yandex

Yandex is an advertising service provided by Yandex LLC (Russia)

Note: It is used only for users in Russia

Liftoff

Liftoff is an advertising service provided by Liftoff Mobile, Inc. (USA)

Digital Turbine Exchange

Digital Turbine Exchange is an advertising service provided by Digital Turbine, Inc. (USA)

Bidmachine

Bidmachineis is an advertising service provided by BidMachine, Inc. (USA)

LoopMe and partners

LoopMe is an advertising service provided by LoopMe Limited (England)

Mintegral

Mintegral is an advertising service provided by Mobvista (Guangzhou) Technology Company Limited (China)

MobileFuse

MobileFuse is an advertising service provided by MobileFuse LLC (USA)

Moloco

Moloco is an advertising service provided by Moloco Inc. (USA)

Verve Group – PubNative

Verve Group – PubNative is an advertising service provided by Verve Group Europe GmbH. (Germany)

Yahoo Inc

Yahoo Inc is an advertising service provided by Yahoo Inc (USA)

Acuity Ads

Acuity Ads is an advertising service provided by AcuityAds Inc. (USA)

You can opt-out from Acuity Ads service by following the instructions on Acuity Ads Opt-out page: https://privacy.acuityads.com/opt-out-success.html

Ad Generation

Ad Generation is an advertising service provided by Supership Co., Ltd. (Japan)

Start.IO

Start.IO is an advertising service provided by Start.io Inc. (USA)

Beachfront

Beachfront is an advertising service provided by Beachfront Media, LLC (USA)

Sharethrough

Sharethrough is an advertising service provided by Sharethrough, Inc. (USA)

You can opt-out from Sharethrough service by following the instructions on Sharethrough Opt-out page: https://privacy-center.sharethrough.com/en/do-not-sell-my-personal-information/

VRTCAL

VRTCAL is an advertising service provided by VRTCAL Markets, Inc. (USA)

You can opt-out from VRTCAL service by following the instructions on VRTCAL Opt-out page: https://www.vrtcal.com/opt-out/

TripleLift

TripleLift is an advertising service provided by Triple Lift, Inc. (USA)

APPENDIX B – Analytics and other service providers

Appsflyer

Appsflyer is analytics service provided by Appsflyer LLC (USA)

Facebook Ads conversion

Facebook Ads conversion tracking is an analytics service provided by Meta Platforms Inc. (USA) that connects data from the Facebook advertising network with actions performed on the Services.

Facebook Event Manager

Facebook Analytics is an analytics tool provided by Meta Platforms Inc. (USA) that may collect or receive information from our apps and other apps and use that information to provide measurement services.

Firebase

Firebase is an analytics service provided by Google Inc. (USA)

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy Policy: https://www.google.com/intl/en/policies/privacy/

Google Analytics

Google Analytics is an analytics service provided by Google Inc.

Google Cloud

Google Cloud is cloud computing services provided by Google LLC (USA)

Yandex App Metrica

Yandex Appmetrica is an analytics service provided by Yandex LLC. (RU)

Policy Policy: https://yandex.com/legal/confidential/index.html

Linode

Linode is cloud computing services provided by Linode LLC (USA)

Policy Policy: https://www.linode.com/legal-privacy/