Last Updated: June 12, 2023, with Effective Date June 12, 2023
Freeplay LLC (“we”, “us” or “our”) respects your privacy. This Privacy Policy (“Privacy Policy”) clarifies our privacy practices and describes how we collect, use, disclose, and otherwise process different types of information when you access and/or use the Website available at https://freeplay.io/ (hereinafter, the “Website”), and explains the rights and choices available to you with respect to your personal information.
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social status.
Our Privacy Policy applies to all users and others who access the Website (ʺUsersʺ).
PLEASE READ CAREFULLY THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, AND YOUR CHOICES REGARDING YOUR PERSONAL DATA. WHEN YOU USE THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.
Following the EU General Data Protection Policy (EU-GDPR) and the UK General Data Protection Regulation (UK-GDPR), we are the data controller unless otherwise stated.
Depending on the circumstances mentioned below, the following general categories of personal information may be collected and otherwise processed:
| A.Identifiers | A real name, postal code, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. |
| B.Geolocation Data | Physical location or movements. |
| C.Internet or other similar network activity | Information on your interaction with Website, or advertisement. |
| D.Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We obtain the categories of personal information listed above from the following categories of sources:
We may collect, store and otherwise process some information about you when you voluntarily provide such information to us using the following contact forms available on the Website (hereinafter – “Contact Forms”):
If you decide to make a request via the “Send a Response” form, the following categories of information are voluntarily provided by you: your First Name, your Second Name, your e-mail address, your LinkedIn page, and any information that you provide, including the contents of the messages or attachments;
If you decide to make a request via the “Submit Your Game” form, the following categories of information are voluntarily provided by you: Studio/Developer Name, your e-mail address, Link to Game/Portfolio, and any information that you provide, including the contents of the messages or attachments;
If you decide to make a request via the “Submit Your Privacy Request” form, the following categories of information are voluntarily provided by you: your Name, your e-mail address, and any information that you provide, including the contents of the messages or attachments.
We use the services of Advanced Hosters B.V. in order to collect, store and process the information that you provide us via the Contact Forms. We use the information submitted by you via the Contact Forms solely for the purpose of considering and responding to your requests (if necessary).
When you access and/or use the Website, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our Website and giving our users the best experience. If we do not access such data we may not be able to provide you with all features of the Website.
We use third-party automatic data processing technologies to analyze certain information sent by your device via our Website (analytics or advertising tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular, to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first-time access the Website.
The following are the types of information we may collect indirectly from you:
Information provided automatically to analytics or advertising tools does not generally come under our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility.
Our mission is to constantly improve our Website and provide you with better user experiences. As part of this mission, we use your information for the following purposes:
If any new purpose for processing your data arises, we will let you know when we start to process the information for that other purpose by introducing the corresponding changes to this Privacy Policy.
We will not rent or sell your personal data to third parties, but we may share your information obtained via tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technologies for the Website. We do not control or influence these third parties tracking technologies or how they may be used.
Please note that while we partner solely with third parties that gave us assurance of the application of necessary technical and organizational measures to protect your data, we cannot guarantee the security of any information transmitted from the Website directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your data through the fault of third parties.
We may engage the following categories of recipients for a variety of business purposes and only in the ways and contexts that are described in this Privacy Policy:
We may engage the following third-party service providers in order to provide us with the necessary infrastructure for the delivery and improvement of our Website:
| ENTITY NAME | Advanced Hosters B.V. | Google LLC |
| SERVICES PERFORMED | Cloud service provider | Google Analytics (tool for analysing Website traffic) Google reCAPTCHA (analytics engine for protection the Website from fraud and abuse, protection of Website users from bots) |
| ENTITY LOCATION | Netherlands | U.S.A. |
| LINK TO PRIVACY POLICY | https://advancedhosting.com/en/documents/privacyPolicy | Google Privacy Policy: https://policies.google.com/privacy?hl=en How Google uses information from sites or apps that use its services: https://policies.google.com/technologies/partner-sites?hl=en https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’) |
Please note that all third-party service providers that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purposes.
As it is indicated above we use such services as Google Analytics that track and report the Website traffic. This service uses different types of cookies to analyze user activity. If you want to learn more about the categories of data collected and processed by Google Analytics please consult the corresponding website of Google Analytics as well as its privacy policy and other documents concerning data protection. Note that we are not responsible for any usage of your data by the abovementioned third-party service providers in violation of our instructions.
If you don’t want Google Analytics to use cookies you can block data collection by following the instructions provided in Section XI of the present Privacy Policy.
Our Website may contain links to third-party sites/services. You also may visit the Website following a link from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).
We may disclose your personal information if needed for objective reasons, due to public interest, or in other unforeseen circumstances:
We work in the cross-border area and provide our Website to Users around the world.
We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on the protection of such information.
By using the Website, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data – if possible – before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
In particular, we recourse to the services of Advanced Hosters B.V. that have adopted technical and organizational measures to protect your personal data against unauthorized/unlawful processing and accidental loss, destruction, or other damage..
We will generally keep your personal information for as long as we need it for a lawful purpose: to perform the contract between you and us (enforce our Terms of Use) and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase it.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) with the purpose of compliance with certain legal obligations (such as taxation, accounting, and audit), maintenance of safety, and data backup settings or prevention of fraud or other malicious acts.
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of our Website, you can contact us at [email protected].
Our Website is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under the age of 18 may provide any personal information to the Website. If you are under 18, do not use or provide any information on this Website or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the age of 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
If you are a resident of the European Economic Area or the UK, your rights to access, edit, and delete your information can be found in clause 10.1. of this section.
If you are a California resident, your rights to access, edit, and delete can be found in clause 10.2. of this section.
If you are not a resident of the EEA, UK, or California, depending on your location, you may be able to make requests to access, correct, and/or delete certain personal information that you provide to us. For your protection, we may require proof and verification of identity and jurisdiction of residency before we can answer the above requests. If you wish to make such a request, you may contact us at [email protected]. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with some of the features and functionality of the Website. Once we have verified you, we will honor such requests at our discretion and in accordance with applicable law.
If you reside in the European Economic Area (“EEA”) or the UK, applicable privacy laws (in particular EU-GDPR and UK-GDPR respectively) give you certain rights regarding your personal data.
According to both EU-GDPR and UK-GDPR, you have the following options concerning your personal data that was collected:
To exercise any of the rights described above, you can contact us through the Submit Your Privacy Request form. Please bear in mind that we ensure the above-mentioned rights only with respect to the information that we physically access and store.
When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the recipients listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API, or other options.
If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt-out as described below >>
If you are located in the European Union, you may address our representative when you have questions on privacy issues by sending an email to Konrad Gutowski ([email protected]).
If you are located in the UK, you may address our representative in the UK when you have questions on privacy issues by sending an email to Albina Gulevich Apolskaya ([email protected]).
The California Consumer Privacy Act of 2018 (CCPA) provides those who reside in the State of California with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
The CCPA provides consumers (California residents) with the following rights regarding their personal information:
Once we receive and confirm your verifiable consumer request, the data outlined in this section above (Right to Access) will be disclosed to you.
To request access to your personal information or request deletion, please submit a verifiable consumer request to us by either:
Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
Please, include the wording “Consumer rights to maintain confidentiality in the state of California” in the text of your request.
Any request you submit to us is subject to an identification and residency verification process, so when submitting a verifiable request, you should be ready to:
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request, or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third-party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.
We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete it after the purpose is fulfilled.
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.
You may prevent and/or manage the collection and processing of data related to your use of the Website by following the instructions provided below.
Google Analytics. If you want to opt out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics
Bear in mind that if you choose to disable all cookies, this can affect the Website functions, some of the features that make the Website more efficient may not function.
In case we change our Policy, we will post the changes on this page. Please check our Website regularly for any changes.
If you have any questions about this Privacy Policy, please feel free to contact us via the Submit Your Privacy Request form or send your message at [email protected]
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