PRIVACY POLICY

PRIVACY POLICY

Last Updated: January 29, 2024

This Privacy Policy (ʺPrivacy Policyʺ) explains how Anatogame (ʺweʺ, ʺusʺ or ʺourʺ) handles your personal data when you're using our Game(s). It covers our data protection practices and points out the kinds of information that might be processed while you're using our Game(s).

Please take a moment to carefully review the following Privacy Policy, which explains how we may process your personal data and outlines the rights and choices you have concerning your personal information. By using our Game(s), you acknowledge that you have read, understood, and agree to be bound by these terms.

We collect information that can identify you ("personal information"), either individually or when combined with other data in our possession.

"Personal information" or "personal data" means any kind of info about a person that can identify them, either directly or indirectly, specifically through reference to that data.

In accordance with the EU General Data Protection Policy (EU GDPR) and the UK General Data Protection Regulation (UK GDPR), we act as the data controller unless stated otherwise.

Our Game is intended for individuals who are 18 (eighteen) years of age or older. Therefore, we do not knowingly collect or solicit any personal information from individuals under the age of 18. If you are not of legal age in your jurisdiction, typically between thirteen (13) and seventeen (17) years old, you can only use the Game with appropriate consent and under the supervision of a parent or guardian. Individuals under thirteen (13) should not provide personal information to the Game. If we become aware that we have collected personal information from a child under the age of 18 without obtaining parental consent, we will promptly delete that information. Please contact us if you suspect that we may have collected information from or about a child under eighteen (18) without proper parental consent.

CATEGORIES OF INFORMATION WE PROCESS

Under the conditions described below, we may collect and process information that falls under the following general categories of personal information:

Identifiers (like an online identifier, Internet Protocol address, email address, or other similar identifiers);
Geolocation data (like physical location (approximate) or movements);
Internet or other similar network activity (like information on your interaction with an application or advertisement;
Commercial Information (like products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

TYPES OF THE PROCESSED INFORMATION AND HOW IT IS COLLECTED

Automatically processed information:

With your consent, we employ third-party automated data processing technologies (such as advertising or analytics tools) to analyze specific information sent by your device through our Game(s) (Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools engage in automated processing of your personal data, which may involve profiling (any form of automated processing of personal data used to evaluate certain personal aspects relating to you, particularly to analyze or predict aspects related to your preferences, interests, behavior, location, or movements). Processing information through automatic data processing technologies starts automatically once you allow our Game(s) to track your activity.

In adherence to the IAB Europe Transparency & Consent Framework that we are involved in and its specifications and policies, which help us to stay consistent with data protection laws in the EU and UK, we use Google CMP with the identification number (CMP ID 300) for our Game(s).

You can withdraw your consent at any time - please check the opt-out paragraph below.

Also, we may process some information about your device and your user behavior on the grounds of our legitimate interest. (Generally, such information is 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 use this information to improve our Game(s) and give our users the best experience).

TYPE OF THE INFORMATION	DATA
Device Details. When you use a mobile device to access the Game, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by our partners, service providers, and/or other third parties.	Information about the device itself: type of your mobile device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, battery, and device memory usage. Information about the internet connection: mobile carrier, network provider, network type, Internet Protocol (“IP”) address, timestamp and duration of sessions, speed, browser. Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (eg. “coffee shop”). Other device identifiers: e.g. user identifiers (if they are set up by the Game’s developer).
Information about the Game.	Its name, API key (identifier for the Game), version, and properties of our Game can be reported for automated processing and analysis. Some services also record the list of applications and/or processes that are installed or run on your device.
Cookies and similar technologies	When you use the Game, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information that is downloaded to your device when you access the Game. The text file is then sent back to the server each time you use the Game. This enables us to operate the Game more effectively. For example, we will know how many users access specific areas or features within our Game and which links or ads they clicked on. We use this aggregated information to understand and optimize how our Game is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the Game, which may use cookies or similar technologies.
Log file information.	Log file information is automatically reported each time you request to access the Game. It can also be provided when the Game is installed on your device. When you use our Game, analytics tools automatically record certain log file information, including the time and date when you start and stop using the Game and how you interact with the Game.
Ad-related information.	The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversation” event; what ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the Game); whether you respond to the ad.
In-app events.	When you use our Game, analytics tools automatically record in-app information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, and methods of limiting the processing of user data).

Information automatically provided to advertising or analytics tools is generally beyond our control; consequently, we cannot assume responsibility for processing such information. It's important to note that certain services engage in personal data profiling and may gather information related to your personality and/or your device using technologies that are outside our area of responsibility. We do not oversee or guarantee how third parties process your personal data, which may be collected through their methods (not via our Game). Any requests for information disclosure should be directed to these third parties (see the "HOW WE SHARE YOUR DATA PARAGRAPH").

The billing, processing, and charging for in-app purchases are handled by our e-commerce provider (Google). They are responsible for safeguarding and ensuring the security of your personal information. This information is processed to fulfill the contractual obligations between you and us. Please note that we cannot access or utilize your credit or debit card details.

Information you provide directly:

Contact Information

Information that you voluntarily provide when reaching out to us via email or support form (such as your name, email address, and any additional content provided in the email).

We collect, store, and process this information using a cloud storage provider (Amazon.com, Inc.) to ensure an efficient response to your inquiry, fulfill your requests, deliver the requested services, and send you the communications you specifically request.

PROCESSING PURPOSES

Game Availability. We use information that is processed automatically and information that you provide to us directly to deliver the Game to you;
Game Enhancing, Testing, and Monitoring. We use information that is processed automatically to understand your behavior and trends better, detect potential outages and technical issues, support the existing functions of the Game, and add new features and services to the Game.
Interest-based (behavioral) advertising and other targeted content delivery. We may use information that is processed automatically to provide personalized content and information to you, which can include online ads or other forms of marketing.
Communication purposes. Information that is processed automatically and information that you provide to us directly can be used by us to send you our marketing notifications, receive feedback about the Game experience, notify you about policies and terms, and respond to inquiries or messages you send to us.
Fraud and spam prevention, law enforcement. to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use

If new purposes for processing your personal data emerge, we will inform you as we begin processing information for those additional purposes by incorporating the corresponding changes to this Privacy Policy.

HOW WE SHARE THE DATA

Your data, including information from tools like log files, device identifiers, and location data, may be shared with third-party service providers providing automated data processing technologies for the Game. Additionally, third-party advertising partners collaborate with us to deliver targeted advertisements believed to be of the most interest to you.

We carefully select legal entities capable of ensuring the application of all necessary technical and organizational measures to protect personal data. Nevertheless, we cannot guarantee the security of information transmitted from us to such legal entities. We disclaim responsibility for any accidental loss or unauthorized access to your personal data resulting from the actions of these legal entities. Each legal entity is individually responsible for its privacy policies and practices.

A comprehensive list of legal entities falling under the mentioned category of recipients can be found in Appendix A below, along with links to their respective privacy policies.

Under certain circumstances, we may need to reveal your personal information for legitimate reasons, public interest, or unforeseen situations. This could include compliance with legal obligations, safeguarding our rights, ensuring your safety or the safety of others, investigating fraud, or responding to government requests.

In the event of a merger, acquisition, or the sale of all or part of our assets, we will notify you through a prominent notice within the Game about any change in ownership or the utilization of your personal information.

INTERNATIONAL DATA TRANSFERS

Our operations span the globe, and we extend access to the Game(s) to users worldwide.

Please note that we may transfer information, including personal data, to a country or jurisdiction that may not have the same data protection laws as yours. This means your personal information may be transferred to a third country, a specific territory within that country, or an international organization where data protection and confidentiality regulations may not offer the same level of protection as in your country.

We want to assure you that we make every effort to ensure that any recipient of personal data provides adequate protection for the received information in accordance with applicable data protection laws. Using the Game(s), you consent to transferring your personal data to any third country, specific territory, or international organization. We encrypt your personal data whenever possible before transmitting it to the hosting organizations for storage.

DATA RETENTION (HOW LONG YOUR DATA IS USED)

Typically, we retain your personal information for the duration required to perform the Game's functional service and fulfill our legal obligations. If you prefer us not to use the information we physically access and store, you can request the erasure of your personal information.

Nevertheless, certain data may be retained for a specific period, not exceeding the necessary storage purpose. This retention may occur if the information is essential to comply with legal obligations (such as taxation, accounting, or audit requirements), maintain safety and data backup settings, prevent fraud, or address other malicious acts.

YOUR RIGHTS AND CHOICES

If you are a resident of the European Economic Area, your rights to access, edit, and delete your information can be found in this paragraph below.

If you are a California resident, your rights to access, edit, and delete can be found in this paragraph below.

If you are not a resident of the EEA 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 share certain personal information with us actively, we may not be able to provide you with some of the Game's features and functionality. Once we have verified you, we will honor such requests at our discretion and in accordance with applicable law.

Information for Individuals in the European Economic Area (EEA) and the UK

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:

Data Access and Portability. You can request copies of your personal information.
Change or Correct Data. You have the right to ask us to correct, change, update, or rectify your data.
Data Retention and Deletion. The User data is generally retained for as long as it is needed to provide you with the Game. However, specific retention times can vary based on the context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

You can contact us through the [contact form] to exercise any of the rights described above. Please bear in mind that we ensure the above-mentioned rights only regarding the information we physically access and store.

When your personal information 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 Appendix A 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.

If you are located in the European Union or the UK, you may email our representative when you have questions on privacy issues by emailing: [email protected].

Information for Residents of California: Your California Privacy Rights

The California Consumer Privacy Act of 2018 (CCPA) provides those residing in California with specific rights regarding their personal information. This paragraph 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:

Right to Access. You have the right to request that we disclose, no more than twice in a twelve-month period, any of the following for the period that is twelve months prior to the request date:

The categories of personal information we have collected about you.
The categories of sources for the personal information we have collected about you.
The business or commercial purpose for our collecting or selling your personal information.
The categories of third parties to whom we share your personal information.
The specific pieces of personal information we have collected about you.
Whether we have sold or disclosed your Personal Information for a business purpose, and if so, two separate lists disclosing:

sales, identifying the categories of personal information that we have sold about you in the prior 12 months as well as the categories of third parties to whom we sold that personal information, by category or categories of personal information for each category of third parties to whom your personal information was sold; and
disclosures for a business purpose, identifying the categories of personal information that we have disclosed about you in the prior 12 months as well as the categories of third parties to whom we disclosed your personal information, by category or categories of personal information for each category of third parties to whom your personal information was disclosed.

Once we receive and confirm your verifiable consumer request, the data outlined in this paragraph above (Right to Access) will be disclosed to you.

Deletion rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions outlined in the CCPA. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies.

Right to Opt-Out (“Do Not Sell”). You have the right to tell us not to disclose or transfer your personal information to a third party in exchange for something of value. The CCPA refers to this as your right to say “Do Not Sell” my personal information.

We do not sell personal information, as noted herein. If we decide to sell personal information in the future, we will post an appropriate notice and opt-out method and not sell any personal information previously collected.

However, if you don’t want us to process your personal information, please contact us through the. In most cases, there is no way to maintain the Game’s further operation without functional data; therefore, you will be advised to remove the Game from your device.

If you don’t want us to share device identifiers and geolocation data with third-party service providers, please check your device settings as described here below.

Non-discrimination. You are entitled to exercise the rights described in this paragraph free from discrimination. This means that we will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

Unless permitted by the CCPA, we will not:

deny you goods or services.
charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
provide you with a different level or quality of goods or services.
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Now that you are aware of your California privacy rights, please note the following:

All the categories of personal information that are listed in paragraph ʺCATEGORIES OF INFORMATION WE PROCESSʺ of this Privacy Policy have been collected by us from Users within the last twelve (12) months.
In the preceding twelve (12) months, we have disclosed your personal information included in each of the categories of personal information A, B, C, and D listed in paragraph ʺCATEGORIES OF INFORMATION WE PROCESSʺ for each business purpose described above, depending on your use of the Game described herein.
We are not in the business of selling information about you to anybody, which indicates that no personal information of yours has ever been sold.

How to Exercise Your California Privacy Rights

To request access to your personal information or seek deletion, please submit a verifiable consumer request to us by either contact form or e-mail: [email protected].

Consumers can exercise these rights through an authorized agent who meets the agency requirements of the CCPA. A verifiable consumer request related to your personal information can only be made by you or a person registered with the California Secretary of State, whom you have authorized to act on your behalf. You also have the option to make a verifiable consumer request on behalf of your minor child. Please include the phrase "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:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include name, address, city, state, zip code, and email address. We may use this information to surface a series of security questions for you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney signed by you.
Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly.

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 that relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks 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. We will inform you of the reason and extension period in writing if we require more time. Please note that we are only required to respond to two requests per customer each year.

OPT-OUT

Opt-out of marketing tracking

If you don’t want third-party service providers to use data concerning you to personalize ads on the basis of your interests, you should choose the option “Opt out of Ad Personalization” on your Android device in Settings/ Google/ Ads.

Please mind when you opt-out of certain interest-based advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

If you don’t want third-party service providers to use your precise location data or street-level location information about you, you should turn Location off for the Game via the menu “Settings > Apps > [our Game] > Permissions > Location”. Then, turn off the “Location” button.

You can stop all information collection regarding your Game usage by uninstalling the Game using the standard uninstall process for your device. If you uninstall the Game from your mobile device, some information concerning you may still be stored, as described in the "DATA RETENTION (HOW LONG YOUR DATA IS USED)" paragraph.

MISCELLANEOUS

We may periodically update this Privacy Policy. We will post changes to this Privacy Policy and other relevant locations whenever changes are made. Additional forms of notice regarding modifications or updates may also be provided to you as deemed appropriate under the circumstances.

If you have any questions regarding this Privacy Policy, please don't hesitate to reach out to us through the contact form or by sending your message to [email protected].

APPENDIX A

to the Privacy Policy

The processing of your data may involve the following legal entities (hyperlinks are provided below for more information on how each entity handles your data):

AdColony, Inc. (U.S.A.) - Ad Management Service Provider

Anzu Virtual Reality Ltd. (Israel) - Ad Management Service Provider

AppLovin Corporation (U.S.A.) - Ad Management Service Provider

https://www.applovin.com/privacy/

https://dash.applovin.com/assets/pdf/dpa.pdf

AppsFlyer Inc. (U.S.A.) - Analytics Service Provider