SmartyAds is committed to protecting your privacy. It is our prime responsibility to ensure safety and legitimate use of your personal data. This Privacy Notice describes how and when we may collect, use, secure, and share information collected in connection with our games and mobile applications. This Privacy Notice applies to personal information that we collect through our games, next (“Games“).
If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided in this Privacy Notice.
Definitions
Use of the terms "we" and "us" in this Privacy Notice means SmartyAds and its affiliates, including SmartyAds LLP, SmartyAds Inc. We are a software development company that is focused on providing various services in a digital advertising market, besides, we developed a number of applications to which this Privacy Notice applies.
How to contact us:
SmartyAds INC
Address: 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801
If you have questions, want to find out more about our privacy practices, or if you would like to make a complaint or exercise your rights, please contact our Data Protection Officer by e-mail: dpo@smartyads.com
What personal information do we collect and why?
The personal information that we may collect about you through the Games broadly falls into the following categories:
- Information that we obtain from you
- Within first access of the Game, you will be required to either accept or decline our Terms of Services to begin playing Games.
- Information that we obtain from third party sources
- From time to time, we may receive personal information about you from third party sources (such as third party service providers), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
- In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.
Who does SmartyAds share my personal information with?
We may disclose your personal information to the following categories of recipients:
- to third party services providers and partners who provide data processing services to us (such as PlayFab, Privacy Policy is available at https://playfab.com/privacy-terms/ );
- to marketing and advertising services, who help us to run and maintain advertising activities within Games (such as IronSource, Privacy Policy is available at https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/?_gl=1*1tl2gry*_gcl_au*NzY1NzY2Mjg3LjE3MTg4OTU1Mjk.#step-1)
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- our affiliates, who may act as data controllers processing your personal data, including their names and contact details, can be accessed on our website;
- our subcontractors and team members, such as the support team, or technical team.
- Please be aware that we and the mentioned recipients are located in regions that might not offer the same level of data protection as your home country. We will strive to safeguard your personal data during processing, storage, or transfer.
- Standard Contractual Clauses:
- If we are governed by the General Data Protection Regulation (GDPR) and transfer personal data to a country with different data protection standards than your own, we will implement additional safeguards, such as Standard Contractual Clauses (SCC). These clauses are considered suitable data protection measures under the GDPR and aim to provide a comparable level of data protection by data recipients. This involves, for instance, robust encryption before transmission, stringent encryption key requirements, and encryption of data-at-rest.
- Transfer Impact Assessment:
- Beyond the SCC, we conduct regular assessments of the recipient country’s laws and practices. This ensures that the security measures and protections implemented by that country and the data recipients are verified.
- Security Measures (Technical and Organizational Measures):
- We may use various measures such as data pseudonymization, encryption, anti-virus software, and strict access/transfer controls. This is not an exhaustive list but provides an overview of some of the technical and organizational measures we might employ.
- Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.
We will process your information for the purposes of operating Games and communicating with you as necessary for those purposes and in our legitimate commercial interests, for instance, when responding to your Player Support requests and questions, develop and improve your player experience, provide offers and social features, send you notifications about Game and Service updates, improve our Games, Website and other Services or for the purposes of detecting or preventing illegal activities.
How We Use Information
We may use the information we collect for a number of business and commercial purposes, including to:
- Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support;
- Maintain the safety, security, and integrity of our Games, for example by authenticating players and providing account security and fraud detection;
- Administer contests, surveys, and sweepstakes you enter, notify contest winners, and award prizes;
- Fulfil a purchase or send you order confirmations;
- Facilitate your communication with friends and other players, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or
- Comply with legal requirements and/or investigate or address claims or disputes relating to your use of the Services.
Your data protection rights
At any time, you have the following rights:
| You have the right to: | How? | |
| Access | you have the right to request access to personal data we possess about you, or data we hold that requires updating or correction | you may request a copy of your data via dpo@smartyads.com |
| Be informed | you have the right to be informed of personal data we process and how we process it |
you will be informed through:
or we will answer your questions when you contact us |
| Rectification | you have the right to request correction of inaccurate data or complete information that is incomplete | you may edit your personal data by contacting us at dpo@smartyads.com |
| Erasure |
you have the right to request erasure of certain personal data. For example, we will delete your personal data when:
Please note that sometimes, SmartyAds will be unable to delete your personal data. For example, when:
|
you may delete your data the following ways:
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| Restriction of processing |
you have the right to request us to stop processing your personal data. This right is applicable if:
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we do not need your information for the originally intended purpose you may send request to restrict processing of your data by contacting our DPO at dpo@smartyads.com |
| Object to processing |
you have the right to object to processing of your personal data. The right to object may be exercised in the following situations:
|
you may send your objection request to our DPO at dpo@smartyads.com |
| Data portability |
you have the right to request a copy of your data in electronic format and also the right to transmit your data to a third-party IT environment. You may exercise the right to data portability when certain conditions apply:
|
you may request a copy of your data via dpo@smartyads.com |
| Not to be subject to Automated decision making | you have the right not to be subjected to a decision solely based on automated processing, including profiling, that has legal effects or significantly impacts them in a similar manner. | SmartyAds does not carry out this type of processing |
| Lodge a complaint | you have the right to file a complaint with the data protection authority in the country where you reside, permanently live, work, or where a violation of data protection occurs. | please visit website of the Data Protection Authority in the country where you reside, permanently live, work, or where a violation of data protection occurs |
Age Limit
Our Games are not intended for the use of children (those under the age of 18 or older if the country of your residence determines higher age restrictions). We do not knowingly collect or use personal data from children.
If you become aware that your child has provided us with personal information without your consent, please contact us at dpo@smartyads.com
If we discover that we have gathered the personal information of a child, we will promptly take appropriate measures to remove such personal data.
Updates to this Privacy Notice
We retain the right to periodically revise this Privacy Notice. The most recent version of the Privacy Notice will dictate how your information is handled and will always be accessible on our Privacy Notice page. Please revise this Notice regularly to stay updated.