PRIVACY POLICY

This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We Sapniverse LLC, a company under laws of United States , with registered address at : 447 Broadway, 2nd Floor Suite #2206, New York, New York 10013, United States (“Sapniverse LLC” or “we”) , a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

1. INFORMATION WE COLLECT FROM YOU

Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publishers' Games. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games, and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners an...

The information that we may collect about you through the Services broadly falls into the following categories:

(a) Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit inquiries to us, such as:

• Your name, email address, or other details necessary to process your inquiries;
• Any information you submit to our support team via email.

We will try to explain to you at the point we ask you to provide your personal information why we are asking for it and how it will be used.

(b) Information that we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or your device, which may be considered personal information under applicable data protection laws, such as:

• Data and analytics about your use of our Services (e.g., in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, the means by which you were referred to our Services);
• Your IP address and device identifiers such as your Advertising ID, Device ID numbers;
• Your device type and the operating system that you use;
• Your Service communications (e.g., in-game emotion signals which you exchange with other players);
• Broad geographic location (e.g., country or city-level location) based on your IP address.

(c) Information we obtain from third-party sources

• Third-party service providers: We may receive personal information about you from third-party sources, such as when you installed our Game and prior to installing, you clicked an advertisement for the same Game.
• Advertising partners: From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of one of our Games in another publisher’s game), we will be provided with information about which ad network and advertising campaign the install originated from.

(d) No special categories of information

We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

2. HOW WE USE YOUR INFORMATION

2.1. In General

We use the information we collect about you/your device to deliver services and our Games to you and to operate our business. We use it also for improving our services and Games, for enhancing security, and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Games in our Games and also in other publishers' apps and to display third-party advertisements to you. We use your information also for tracking a...

We use your information for the following purposes:

• Delivering and improving our services: Developing, delivering, and improving our Games and other products, services, and content, tailoring our products and services, providing Game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Games, and administering the Games.
• Displaying advertisements: Showing advertisements for our Games in other publishers' apps and displaying third-party advertisements in our Games.
• Cross-promotion: Promoting one of our Games while you are playing a different Game of ours.
• Tracking and fraud prevention for advertising purposes: Tracking how our advertising campaigns perform and identifying and preventing fraud for our advertising campaigns.
• Analytics and research: Understanding and analyzing trends in connection with the usage of the Games, gathering demographic information about our user base, and data about where the Game was downloaded from. Creating reports and analysis for research or business intelligence, tracking potential problems or trends with our Games and services, or testing our new game features and content.
• Security: Enhancing the safety and security of our Games, products, and services.
• Customer Support: Providing customer support to you and responding to your inquiries.
• Our legal obligations: Using your information when we are required to do so by law.

2.2. In-App Purchases

Our Games enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are completed through the app store via your App Store account or Google Play account. Any post-purchase processes are controlled by Apple or Google stores and are subject to their specific terms. Please review the privacy policy and terms of service of your Apple or Google stores.

• iOS: Apple Support
• Google Play: Google Play Support

To cancel your subscription, please visit the applicable link below and follow the instructions:

• iOS: Apple Subscription Support
• Google Play: Google Play Subscription Support

3. HOW WE SHARE YOUR INFORMATION

We cannot provide all the services necessary for the successful operation of the Games by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research, and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to d...

We may share such information with:

• Our analytics providers: We use third-party analytics such as Unity, Firebase, Tenjin, Gameanalytics for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to you.
• Our cloud service providers: We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform.
• Our tracking and fraud prevention providers: For some of our Games, we use tracking and fraud prevention providers, such as Tenjin for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services, and for fraud prevention purposes.
• Third-party advertising partners: We have contracted with certain third-party advertising networks that assist us in delivering advertising to you, allowing us to continue offering the Games for free or at a low cost.
• Advertising partner’s third-party tracking provider: We allow our advertising partners to track impressions, clicks, installs, or other advertising campaign performance indicators through their tracking providers for measuring their advertising campaign performance.
• Other third-party service providers: For our Games, we use Unity Software to develop such Games. For the data processing by Unity please see Unity’s privacy policy available at Unity Privacy Policy.

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Games. These changes shall be updated promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to the law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. Additionally, in the event of a reorganization, merger, or sale,...

4. ADVERTISING

4.1. In General

We use advertising to fund our Services and to make our games available for free. We offer our Games for free and in order to do that, we need to share the information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base.

If you are a European Economic Area (EEA) – based user be aware that:

• When you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR. In addition, data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR.We also ensure that our external service providers are committed to a high level of data prote...
• Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at the relevant button at the loading of the Game. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in the relevant pop-up window and consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for t...

4.2. In-game advertising (i.e. when you view ads in Our Games)

To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads.

Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

• Limit the number of times you see the same ad;
• Ensure they are dealing with humans with real devices and not ‘automated’ bots;
• Serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as an intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and pot...
• Keep track of what games you have used to market you similar kinds of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at the city level).

4.3. View of Our ads on third-party services

We also advertise Games in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs).

The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

• Measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ games);
• Informing players, that have not been playing for a while, about new content in the Game. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content;
• Not showing ads on a game that a player is already playing. We can send a list of active players in the form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad;
• Marketing games to a group of potential players.

4.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?

Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.

4.5. HOW CAN YOU TURN OFF PERSONALIZED ADS?

Besides specific instruments available to EEA-based users via the Game you can use your device settings.

iOS

Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu, you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.

Android

Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be c...

• Contractual Necessity: This covers information that is processed by us in order to provide you with the service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Games (such as in-app chat feature, multiplayer feature, leaderboards, and other third-party social network features), to deliver content of the in-app purchase you make.
• Legitimate Interests: This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Games free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our l...
• Consent: Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
• Legal Obligation: This covers information that is processed by us to comply with a legal obligation, for instance, to maintain records for tax purposes.

11. SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

12. INTERNATIONAL TRANSFER

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third-party service providers and partners, which require us to protect personal information they process from the EEA in accor...

13. RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than two (2) years after your interaction with all of our Games has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in the “Your Rights” section.

14. CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at Sapniverse Privacy Policy

15. CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us via our privacy email: games.privacy@sapniverse.com

9. GENERAL

Your information privacy and security are important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners (see the List of ...

10. LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with the legal bases set out under Laws of the United States data protection law.

The legal bases that we rely upon are the following:

• Contractual Necessity: This covers information that is processed by us in order to provide you with the service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Games (such as in-app chat feature, multiplayer feature, leaderboards, and other third-party social network features), to deliver content of the in-app purchase you make.
• Legitimate Interests: This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Games free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our...
• Consent: Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
• Legal Obligation: This covers information that is processed by us to comply with a legal obligation, for instance, to maintain records for tax purposes.

11. SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

12. INTERNATIONAL TRANSFER

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third-party service providers and partners, which require us to protect personal information they process from the EEA in acco...

13. RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than two (2) years after your interaction with all of our Games has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in the “Your Rights” section.

14. CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at Sapniverse Privacy Policy

15. CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us via our privacy email: games.privacy@sapniverse.com