Privacy Policy
Effective Date: January 29, 2022
Thank you for playing our game!
Please carefully read this privacy policy (“Privacy Policy”) when you use GAMEADVISOR, INC.’s services. This Privacy Policy will come into effect for all existing users on October 1, 2021. Your use of the service from that day will be subject to this Privacy Policy.
The Data Controller under this Privacy Policy is GAMEADVISOR, INC. (“we”, “us”, “our”). and its affiliates.
We are dedicated to protecting users’ privacy rights. This Privacy Policy has been crafted to inform users as to how we collect, store, use, manage, process, transfer, and implement any other possible operation to the personally identifiable information (“Data”) that users provide during the use of our services.
If you do not agree to the processing of your Data in the way that this privacy policy describes, please do not provide your information (when we request) and stop using the Ape Kids Run (“Game”) or any services associated with the Game (“Services”).
We may amend the Privacy Policy from time to time according to the relevant laws, users can find the updated Privacy Policy on the offcial website of Ape Kids Run as well as on the Game application. We will notify users if we make any material changes to the Privacy Policy.
TABLE OF CONTENTS
1. Data and How We Collect them
2. How We Use and Share Data
3. Managing Your Data
4. Your Rights and Options
5. How We Protect Data
6. Children’s Privacy
7. Updates to Our Privacy Policy
8. How to Contact Us
9. How to Contact the Appropriate Authority
1. Data and How we Collect them
We collect or receive Data in three ways:
(1) you directly provide Data to us, such as by creating an account or signing up for email alerts.
(2) we collect Data on an ongoing basis, such as through cookies and related technologies.
(3) we receive Data from third party with your consent, such as social media platforms.
1.1 Data You Provide to Us
You may provide your Data to us when you choose to use our Service. As we change our offerings and features from time to time, the Data we collect from you may vary depending on the services you are using. You do not have to provide certain Data when we ask you for it, but if you decline, you might not to be able to access or enjoy Services or certain services, offering or features.
In general, we collect Data and other information as set forth in the table below for specific purposes:
|
Data |
Use |
Legal Basis |
|
Data of Account |
- To register, update, maintain your accounts; |
- Necessary for our performance of a contract with you. |
|
Region Location |
- To set up your gameplay on a regional server; |
- Necessary for our legitimate interests in providing enhanced game functionality to you if you want it. |
|
Customer Support Data: We use AIHelp customer supporting system to provide the customer service. |
- Help identify and troubleshoot problems with your account or games; |
- Necessary for our performance of a contract with you. |
|
The other data you provide to us |
- When you participate in online discussions or otherwise interact with us; |
- Necessary for our legitimate interests in responding to your interactions with us and ensuring that we deal appropriately with any requests that you have. |
|
Any of the above data (to the extent required and permitted under applicable laws) |
- To represent ourselves in legal proceedings or comply with court orders, litigation procedures and other legal processes. |
- Necessary for a legal obligation. |
1.2 Data We Collect on an Ongoing Basis
We may also collect Data and other information through technologies, from you when you use our Services. We use these Data and information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics and it is necessary for provision of Service. The type of information that we collect includes:
|
Data |
Use |
Legal Basis |
|
Android Device Data: |
- To modify and improve our Game or Service; |
- Necessary for us to provide the Game or Service and to ensure the security. |
|
iOS Device Data: |
- To modify and improve our Game or Service; |
- Necessary for us to provide the Game or Service and to ensure the security. |
|
Advertising ID and Market analytics Data (e.g., Google Advertising ID) |
- To monitor the advertising data and marketing programs; |
Necessary for us to manage advertising and conduct data analytics. |
|
Transaction Records: |
- To process transactions that you make; - To maintain the purchase history; |
- Necessary for our performance of a contract with you. |
|
Data of Use of the Service: |
- To provide Game services； |
- Necessary for us to provide the Game or Service. |
|
Any of the above data (to the extent required and permitted under applicable laws) |
- To represent ourselves in legal proceedings or comply with court orders, litigation procedures and other legal processes. |
- Necessary for a legal obligation. |
1.3 Data Received by Us through Third Party
We may also collect your Data through third parties. Such as:
|
Data |
Use |
Legal Basis |
|
Data you provided to Third Party Services: |
- To enable you to link, connect, or login to your Account with a third-party service; |
Necessary for our legitimate interests in making the Game available through third party services, and enabling the Game to link to third party services to enhance user experience. |
|
AIHelp (Customer supporting service system) |
- Help identify and troubleshoot problems with your account or games; |
Necessary for us to provide the Game or Service. |
|
Bugly-device id-device name-game version-channel-package name-os version-ROM-CPU structure-connection type-website： |
- Provides professional error report and operation stats |
Necessary for improving service quality. |
|
Any of the above data (to the extent required and permitted under applicable laws) |
- To represent ourselves in legal proceedings or comply with court orders, litigation procedures and other legal processes. |
- Necessary for a legal obligation. |
• With regard to clause 1.3 above, please bear in mind that a third party controls your Data and you may vary your authorization and revoke your consent (if applicable) through privacy settings on such third party’s platform. Please ensure that you read the privacy policy of any third-party platform that you access.
2. How We Use and Share Data
2.1 Using Your Data
We collect, use, store, and process your Data based on:
• The principle of lawfulness, fairness and transparency;
• Your consent that we may take from you time to time;
• Specified, explicit and legitimate purposes;
• The extent that is adequate, relevant and limited to what is necessary in relation to the purposes;
• The manner that ensures appropriate security of the personal data;
• Performing the obligations under User Agreement and providing our Services;
• Your and our legitimate interests;
• Other legal reasons including if required under any law or required by governmental and regulatory bodies.
Managing Notifications
• Information on managing notifications from you iOS device is available here: https://support.apple.com/en-hk/HT201925#manage-alerts
• Information on managing notifications from your Android device is available here: https://support.google.com/android/answer/9079661?hl=en.
2.2 Sharing Your Data
We do not share personal data that directly identifies you (such as your name, e-mail) with independent third parties unless:
(i) your prior authorization or consent is obtained;
(ii) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials;
(iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or
(iv) if necessary, to protect the vital interests of us and any of its users (such as to prevent death, bodily harm, or serious damage to property), public security and public interests; or
(v) if we sell part or all of our assets to the third parties, we may share your Data with the buyer. In the event of this circumstance, the buyer will comply with this privacy policy, the related laws and regulations.
We may share anonymous or aggregated data, or other data that does not directly identify you with:
(i) Other players and users. Social features are a core component of our games, other players and users may, for example, see your profile data, in-game activities and read the messages you have posted depending on the setting adopted by you;
(ii) Other companies and public authorities in order to identify and/or prevent fraud and illegal activity, we may exchange data with other companies and public authorities in response to lawful requests;
(iii) Other companies which help us to optimize our games services. We may share in-game click record to other companies to optimize and improve Game experience. Under this circumstance, we will enter into the agreement with such companies and the companies are prohibited from retaining, using, or disclosing your personal data for any purpose other than providing us with their services in support of our game services.
(iv) Advertising Partners, Social Media Platform and third-party payment platforms. The Service includes features from our partners, such as social media interaction tools, in-game advertising and purchasing in-game items. When you use the service, application, other site provided by these partners related to our Game, these partners may access your data and operate under their own privacy policies and their terms of service. We encourage you to check their privacy policies to learn more about their data processing practices and exercise due caution while accessing any third-party website which is beyond our control.
Advertising Partners:
- Alibaba Cloud
- Google Play(https://policies.google.com/privacy)
Social Media Platforms:
- YouTube (http://www.google.com/policies/privacy)
- Facebook(https://www.facebook.com/privacy)
Third-Party Payment Platforms:
- Google Play
- Apple store
We may share your data with our affiliates and companies in the same group of companies as us. This includes our subsidiaries (any organization or brand we own or control); our parent company; and any of its subsidiaries. These companies may use your personal information in the same way as we can under this Privacy Policy.
2.3 Data transfers
Our Service is global by nature and your Data can therefore be transferred to third parties or service providers or business partners located within or outside your jurisdiction. In such cases, we will contractually oblige the receiving parties to ensure that same level of data protection is accorded to your Data that is adhered to by us under applicable law. Further, we contractually ensure that such information is not disclosed, published or transferred further. As different countries may have different Data Protection and Privacy laws, we take steps to ensure adequate safeguards are in place to protect your data. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission or other jurisdictions.
3. Managing Your Data
You may access and update some of your Data through your Account settings. If you have chosen to connect your Account to a third-party application, such as Facebook, you can do so within the Game. You are responsible for keeping your Data accurate and up-to-date.
We securely store your data by using the Storage service provided by Alibaba Cloud (https://alibabacloud.com/help/faq-detail/42425.htm). You can find more information regarding Amazon Web Services’ Security, Identity, & Compliance at https://alibabacloud.com/help/ .
4. Your Rights and Options
You may exercise any of the rights described in this section by using any functionality available while using the Service and/or sending an email to [email protected] and we will respond without delay and in any event within one month of your request. Please note that we may ask you to verify your identity before taking further action on your request.
4.1 Rectification of Inaccurate or Incomplete Data
You have the right to review your Data provided to us, ask us to correct any inaccurate or incomplete personal Data concerning you.
4.2 Data Access
In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that you have provided to us in a structured, commonly used, and machine-readable format, should you have such requirement, please contact us.We may charge a reasonable fee based on administrative costs, or refuse to act on your request, if your request is manifestly unfounded or excessive. We may also refuse to act on a request where it adversely affects the rights and freedoms of others.
4.3 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your Data by us, you can always withdraw your consent at any time by contacting us. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. You may also change certain data preferences at any time, for example you may turn off GPS location sharing in your mobile device settings.
Furthermore, if you have used the service of YouTube API in our Game, you also can revoke our access to your Data via the Google security settings page at https://security.google.com/settings/security/permissions.
Additionally, in some jurisdictions, you have the right to object and/or limit the ways in which we use your Data, in particular where:
(i) you contest the accuracy of your Data;
(ii) the processing is unlawful and you oppose the erasure of your Data;
(iii) we no longer need your Data for the purposes of the processing, but you require the Data for the establishment, exercise or defense of legal claims; or
4.4 Data Retention and Erasure.
We generally retain your Data for as long as is necessary for the performance of our service and to comply with our legal obligations and then it is deleted or erased based on our internal protocols.
If you no longer want us to use your Data to provide our Service to you, you can request that we erase your Data and close your Account. Also if you have not been using our Service for a significant period of time, it will be deemed as you no longer need our Service, then we may erase your Data and close your Account, by a prior notice.
In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:
If you ask us to remove or delete your Data, we may retain your Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain Data or information from that Account to prevent that member from opening a new account in the future.
We may retain and use your personal information or Data to the extent necessary to comply with our legal obligations. For example, we or third parties engaged by us may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others may continue to be publicly visible in the Game, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Data protection and information security is important for us. While providing services to you and other users, we operate and maintain the Services or Game so as to protect Data and our systems from accidental or malicious loss and destruction. Therefore, as part of provision of Service and on account of overall safety of Data of all users, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Retention Schedule
|
TYPE OF DATA |
RETENTION PERIOD |
|
Nickname, gender, profile data |
The duration of player’s use of the Game / [the game Ape Kids Run (the “Game”)] (i.e., until account deletion in accordance with a player’s request) and then deleted within 30 days. |
|
Personal data relating to players collected via the following third parties: - Facebook - Google Play - Game Center |
The duration of player’s use of the Game i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days. Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Player email address |
The duration of player’s use of the Game i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Location and nationality |
The duration of player’s use of the Game (i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Device information: |
The duration of player’s use of the Game (i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Game play statistics (level, heroes, score/s), date and time stamps of actions |
The duration of player’s use of the Game (i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Advertising ID and select device information (Device ID, IP address) |
The duration of player’s use of the Game (i.e. until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Chat communications (text messages between friends) |
Stored for 3 days (up to 10 messages per friend) and then automatically deleted. |
|
Transaction records |
Stored for the lifetime of player’s use of the Game (i.e. until account deletion in accordance with player’s request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations. |
|
Customer support ticket ID & support communications |
Stored for 2 years and then automatically deleted. |
|
Security-Related Information |
The duration of player’s use of the Game i.e., until account deletion in accordance with a player’s request) and then deleted within 30 days. |
|
Survey InformationCountry/area, gender, occupation, education, email address, survey answer |
The duration of player’s use of the Game (i.e., until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
|
Webpage informationBrowser information (browser name, engine type, version), phone brand, OS version |
The duration of player’s use of the Game (i.e., until account deletion in accordance with a player’s request) and then deleted within 30 days.Where a player does not request account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted. |
4.5 Objection to Processing
In some jurisdictions, you may be entitled to object to the processing of your Data where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims, or we are relying upon another legal basis to process your Data.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes in accordance with clause 8.
5. How We Protect Personal Data
5.1 Security Safeguards
We have implemented reasonable security practices and standards and documented information security policies comprising of all relevant security control measures that are commensurate for protection of the information assets (including your data). We shall also comply with audit requirements as may be required under applicable law. The company’s service provider responsible for hosting of Data has implemented ISO/IEC 27001:2013 standards for its management system and we work with our service providers to ensure that adequate security measures are taken to afford protection to your Data.
Security of our users' Data is a priority at us, and we are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your Data against unauthorized access, loss, destruction, or alteration. However, in a digital world, you will appreciate that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. This means we cannot guarantee the security of your Data and do not assume any responsibility for the unauthorized use or access to your Data under our control.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If there is a security breach occurs, we may also post a notice on the Website. We will send an emergency report to authorities in case that the security breach is serious and assist authorities to take steps to prevent further harm.
If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us in accordance with clause 8, and we will take action in relation to your notification without undue delay and in any event within 30 days, and respond to you as soon as possible when we have any update.
Please keep in mind that whenever you voluntarily disclose Data online through certain channels (for example on message boards, through email, or in chat areas), that Data can be collected and used by others. We are not responsible for Data that you share on services/platforms other than the Game or our services. We remind you to use caution before sharing or making such disclosures. Ultimately, you are solely responsible for maintaining the secrecy of your passwords or any account Data. Please be careful and responsible whenever you are online.
5.2Additional Information for India Users
Sensitive Personal Data or Information Rules. The Sensitive Personal Data or Information Rules (SPDI) includes sensitive information pertaining to a natural person like password, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric information, medical records and history etc. However, it does not include information available in the public domain or the information provided under Indian laws.
Age Restrictions. The Indian user under the age of 18 shall not play our Game without the consent of parent or guardian.
6.Children’s Privacy
A “Child” is a person under the age of digital consent (i.e., 13 years old in the United Kingdom and United States and between 13 and 16 years old in the European Union). Please see below for a summary of our practices with respect to the collection of Personal Information from Children and the use and disclosure of such information.
Quick-Chat Mode
If a user of the Game self-identifies or is identified by us as being a Child, their gameplay experience will automatically be set to “Quick-Chat Mode,” unless the parent or legal guardian of the Child permits otherwise. Child users in Quick-Chat Mode (collectively, “Child Users” and each, a “Child User”) are restricted from communicating with or otherwise making their Personal Information publicly available to other users of the Game. Child Users will only be able to use a set of fixed phrases to communicate with other users in Quick-Chat Mode and will not have links to social media in the Game. Each of these features is designed to limit our access and the access of other users of the Game to the Personal Information of Child Users in compliance with the Children’s Online Privacy Protection Act of 1998 and its rules (“COPPA”).
Accounts
Child Users may register an account with us using a registration process similar to the one adults go through; however, in compliance with COPPA, Child Users will first be subject to a parental notice and consent process prior to activation of their account. To initiate the registration and consent process for a Child User, we collect a parent or legal guardian’s email address. We will automatically generate randomized usernames for registered Child Users, unless the parent or legal guardian grants the Child User permission to create a custom username.
Use and disclosure
The Personal Information we collect from or about Child Users is used to give them access to certain features of the Game and communicate with a parent or legal guardian about the Child User’s registration, including for the purpose of verifying their information in connection with the registration. We do not share or otherwise disclose Children’s Personal Information, except (1) as may be necessary to protect the safety of a Child, including by disclosing their Personal Information, where appropriate, to law enforcement agencies or for an investigation related to public safety; (2) to enable us to take precautions against liability; (3) to protect the safety and security of the Game; or (4) where required to do so by law or legal process.
We and the third-party service providers listed below may collect or maintain Child Users’ Personal Information through the Game:
· AppsFlyer
· Bugly
· Getui
Please contact us with questions about our service providers’ privacy policies and our collection and use practices by emailing us at [email protected] with the subject line “Children”.
At any time, a parent or legal guardian may review their Child’s Personal Information maintained by us, require us to correct or delete such Personal Information, request that we delete their Child’s account, and/or refuse to permit us from further collecting or using their Child’s Personal Information by contacting us using the email address provided above. To protect parents and legal guardians’ privacy and security and the privacy and security of Children, we may require a parent or legal guardian to take certain steps or provide additional information, which we will keep strictly confidential, to verify their identity before we provide any information about the Child or make any corrections.
7.Updates to Our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in technology, law, our operations, or any other reason we determine is necessary or appropriate, so please review it frequently. We will indicate on the cover page of this Privacy Policy to indicate the recent most date on which the policy was last updated. Please review this Privacy Policy every time you access or use Service to make sure that you have reviewed the most recent version. We will notify you if there is any substantial change occurs.
8.How to Contact us
If you have any questions about this Privacy Policy or grievances with respect to processing of your information, or you would like to exercise any of your data protection rights, please do not hesitate to reach out to our Grievance Officer. The contact details of the Grievance Officer is set out below:
Contact details/ email: [email protected] .
We will redress the grievances on an expeditious basis within 30 days of receipt of grievance.