Privacy Policy

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

Your privacy is very important for us, and we will always use your personal information only for the purposes as described in this Privacy Policy.

This Privacy Policy applies to all of our games, applications, websites and related services, collectively referred here as our Service. It covers how we collect, use, disclose, transfer and store information received about users and/or information received about users’ computing device through their use of the Service. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use our Service. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products.

Please read the following to learn more about how we use your personal information. By using our Service, you promise us that:

  • You have read, understand and agree to this Privacy Policy;

  • You are over 16 years of age (or have had your parent or guardian read and agree to this Privacy Policy for you);

  • You are a parent, legal guardian, or an authorized school employee in compliance with applicable laws if you use our services on behalf of a child.

If you do not agree, or are unable to make this promise, you must not use our Service. In such case, if you are using our application you must:

  1. Delete your/your child’s account using the functionality found in “Settings” in the App, or contact us and request deletion of your/your child’s data;

  2. Cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android);

  3. And (c) delete the application from your devices.

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Zebrainy Limited (referred to as “Zebrainy”, “we”, “us”, “company” or “our”) will be the data controller responsible for any personal data we process.

If you have any questions or concerns about Zebrainy Limited’s Privacy Policy, including those related to exercise any of your rights, please contact us through the game’s Help & Support, so we can reply to you more quickly. Or contact us through one of the following ways:

  • For privacy questions and exercising your rights via our privacy email: privacy@zebrainy.com;

  • For general information please feel free to contact us via our customer service by email: support@zebrainy.com.

For information collected under this Privacy Policy, the data controller is Zebrainy Limited, a company registered at 101 Townsquare, Ix-Xatt ta' Qui-si-Sana, Sliema SLM3112, Malta, with business address at Elite Business Centre, Trejqa ta` Box Box, Msida MSD1840, Malta.

ZEBRAINY LIMITED PRIVACY POLICY, v2.0, updated February 2020

2. WHAT PERSONAL DATA WE COLLECT AND WHY

We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.

In each of the sections listed below, we describe how we obtain your personal data and how we handle it.

2.1 APPLICATIONS CUSTOMERS

We collect personal data related to users of our Applications.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

  1. From you directly (through the game, website or online forms); and/or

  2. From third parties, service providers that are assisting us in providing you with an application (for example, Google, Apple, Amplitude, AppsFlyer, Facebook).

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

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 applications 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 and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information).

Technical Information

We collect technical information about your device that is necessary for you to use our applications and additional technical data that enables us to maintain and analyze the functioning of the application and to personalize the content of the application. Such information includes amongst others the type of device(s) you are using to play our applications, persistent identifiers, such as IP address, device identifiers, ad identifiers, unique user ID specific for our applications, and the country or region that you are playing in.

Persistent identifiers (such as Device ID and IP address) are identifiers that do not identify you personally, but may uniquely identify your device. Such online identifiers provided by end user devices, applications, tools and protocols are considered as personal information according to data protection legislation. Please check the rights you have under data protection legislation in the Section “Your Rights”.

We automatically collect certain information about your computing device, including:

  • IP address; Country, city or region;

  • Language; Locale (specific location where a given language is spoken);

  • Time zone, session start/stop time,

  • Network status (WiFi, etc.), browser plug-in types and versions;

  • User agent string (UA), platform, SDK version, timestamp;

  • UDID (Device ID)

  • Technical device information (e.g. device model and name, operating system name and version, CPU information, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, Android ID, Android Serial No);

  • Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications).

In addition, we create a unique user ID for you in order to track your use of our applications.

Service Usage Information

When you use our applications, we collect additional information from you by using persistent identifiers that permit identification of your device. We collect information about how you play our applications. Such information is used for delivering and improving our application, cross-promotion and analytics purposes.

We collect information, including log information, that lets us know:

  1. How you play our applications (”Game progress events” means how often you play the app, for how long you use the app, the events that occur within the app, in-app location, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.);

  2. Whether you use the chat feature (for example, when you send us a message via Help & Support), and if you do, the content of messages sent using our chat system, provided that this is only used for operating the service.

Classical Personal Information

We do not collect classical personal information through our applications (such as you name, address or phone number) and you can use our applications without providing us your classical personal information. We will receive your classical personal information (such as your name, address, email or phone number) only when you contact us directly and will use such information only to respond to your inquiry.

When we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law. If you have passed the age screening and you have given us consent for marketing emails, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products and services. You can decline further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to privacy@zebrainy.com.

We may ask you to submit, and we may process other non-personally identifiable information that may be personal to you such as your child's age category and gender, provided that age category and gender information is collected solely for users who have passed the parental gate in our applications.

For some of our applications we collect information about the nickname you choose for your child's account and your rating of the application (if any). Please do not use your or your child's real name.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

In General

We use the information we collect about you/your device to deliver services and our applications to you and to operate our business. We use it also for improving our services and applications, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience.

Personal Information that we obtain from you directly

We may use your personal data to:

Personal data we may use:

Our lawful basis for doing so is:

Provide you with our products or services (for example, play one of our applications and make online purchases)

Parent account ID, Child ID, Changes applied to Child and Parent account

Contract

We use your information when we are required to do so by law, for example we use your country or region for tax reporting purposes.

Country and Region

Legal Obligation

We may use your personal data to:

Personal data we may use:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Establish and manage our relationship (this covers making your experience with us personalized, dealing with complaints or maintaining your account with us)

Game progress events,

Parent Account's Information (amount of child accounts; created, last seen and first seen dates),

Child Account's Information (nickname, age category; gender category; created, last seen and first seen dates)

Legitimate Interest

Account Management,

Efficiently fulfil our contractual and legal obligations

Security (ensuring confidentiality of personal information or preventing unauthorized access and modifications to our systems)

Application version and Build ID,

Device ID (UDID),

Information about applied promo codes,

Transaction receipt and IDs

Managing security, risk and fraud prevention

We use information about your currency preferences and convert it to the universal value

Currency

Understand the market in which we operate

We use information for developing, delivering and improving our applications and other services. We're tailoring our products and services, providing application updates, technical trouble shooting, understanding and analyzing trends in connection with usage of the services and administering them

OS Type and Version, Application version,

Device Information (such as brand, platform, graphics system, carrier, device family, manufacturer, model, type, timezone information)

Delivering and improving our services

We use your IP address to determine your location and to apply the correct language preferences for your account

IP Address

Account Management

We use your information for providing customer support to you and to respond to your inquiries.

User IDs and Parent E-mail,

Child's account age category,

Device Information (Language, Platform, ID and Type),

OS Type and Version, Application version

Consent

Customer Support

Personal Information that we obtain from Third Parties and our Service Providers

Data Processor

We may use your personal data to:

Personal data we may use:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Amplitude, Inc.;

Unity Technologies

Security (ensuring confidentiality of personal information or preventing unauthorized access and modifications to our systems)

Product ID and Game access status,

Subscription Information (ID, Status, Currency, Period),

Order ID, Transaction IDs, Tariff plan IDs list,

Legitimate Interest

Managing security, risk and fraud prevention

Amplitude, Inc.

We use information for developing, delivering and improving our applications and other services. We're tailoring our products and services, providing application updates, technical trouble shooting, understanding and analyzing trends in connection with usage of the services and administering them

OS Type and Version,

Error messages (description, code, trace),

Application Version, SDK library version,

Device Information (such as platform and device family)

Delivering and improving our services

Amplitude, Inc.;

AppsFlyer, Inc.;

Facebook, Inc.

We use your information for understanding and analyzing trends in connection with the usage of our services, gathering demographic information about our user base, data about where applications were downloaded from. We may also create reports and analyses for the purposes of research or business intelligence, for example to track potential problems or trends with our applications and services, or to test our new game features and content.

Game access status,

Subscription Information (ID, Order ID, Renewal Status, Start and Till dates, Price, Status, Currency and Cancellation reason)

Cancellation reason

Marketing campaign type, Application media source

Product ID and Language

Understand the market in which we operate

Amplitude, Inc.

We use your information to learn about how our products and services are or may be used. We may also create reports and analyses for the purposes of research or business intelligence, for example to track potential problems or trends with our applications and services, or to test our new game features and content.

Game progress events,

Game access status,

Parent Account's Information (created, last seen and first seen dates)

Child Account's Information (created, last seen and first seen dates),

Platform

Efficiently fulfil our contractual and legal obligations

To help us provide you the best service, we work with third party analytics providers. Their respective Privacy Policies can be found at:

These companies help us to understand your use of the applications. In association with them, we may collect some Personal Information mentioned above. This information is for internal operations only and cannot be shared.

Push Notifications

We use push notifications to remind you about your activities within the applications. You will receive push notifications only if you have subscribed to push notifications in the application. You can always unsubscribe from push notifications. Please use the instructions provided below.

  • For iOS: You will be asked to accept or refuse push notifications after an application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON.

  • For Android: After an application is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.

When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

For the restriction on the usage of information please see the ‘Children's Privacy’ Section of this Privacy Policy.

Survey

We are conducting surveys in order to improve our services and you may freely decide whether you would like to help us or not. We will always ask for your consent before conducting a survey.

From time to time we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, whether children under the age of 13 use the app on their own or with an adult, the gender of users playing the game, different ways of using the app, an assessment of the features of an application, the time period of using the application, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.

We may use third party providers for the in-app surveys and they may place their tags within an application to collect non-personally identifiable data from the device (”Tag Data”) solely for the purposes of conducting the survey, such as to the collection of cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated bases together with the data from other partners (”Unified Data”) to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or decline to answer the survey questions.

In-App Purchases

Our applications 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. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store. Please review privacy policy and terms of service of your app store. For more information on in-app purchases in our applications please see Terms of Use available at https://zebrainy.com/terms-of-service/

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

Some personal information that we collect is stored on your device (such as: Temporary age category hash; Temporary interest types hash; Temporary gender category hash; Audio setting for Parent account; Debug mask status). We do not process or have access to it, and it's stored until you delete our application or service from the device.

2.2 REPRESENTATIVES OF OUR EXISTING OR PROSPECTIVE CORPORATE CUSTOMERS, BUSINESS PARTNERS AND VENDORS

We may collect personal data related to employees, directors, authorized signatories, or other individuals associated with Zebrainy Limited’s existing or prospective corporate customers, business partners, and vendors.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

  • From you directly,

  • From a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor,

  • During networking events that we have either hosted, sponsored, or attended; and/or

  • From publicly available sources (for example, your company website or social media sites, such as LinkedIn or Facebook ID).

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our existing or prospective customers’, business partners’, and vendors’ employees, officers, authorized signatories, and other associated individuals:

  1. Name;

  2. Business address;

  3. Business email address;

  4. Business telephone number; and/or

  5. Job title.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Provide you with our products or services or receive products or services from you

Legitimate Interest

Efficiently fulfill our contractual and legal obligations

Establish and manage our relationship

Efficiently fulfill our contractual and legal obligations

Account Management

Understand the market in which we operate

Exercise or defend legal claims

Learn about how our products and services are or may be used

Understand the market in which we operate

Security

Managing security, risk and fraud prevention

Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Promote our goods and services

If you object to us using your personal data for these purposes, including direct marketing, please let us know using еру game’s Help & Support tool or via the email provided in section 1 above.

Wheт we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

2.3 WEBSITE VISITORS

This Privacy Policy governs your use of https://zebrainy.com/, https://skazbuka.com/, and any other websites and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By using the Websites, you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Services. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services and content.

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

When you visit our Websites, we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimizing the Websites, in connection with promoting our apps and services, and for research or analysis.

Technical Information

We collect the data necessary for you to use the Websites, for us to maintain and analyze the functioning of the Websites and to personalize the content of our products.We automatically obtain certain information about your computing device, including:

  • IP address; Country code;

  • Language; Locale (specific location where a given language is spoken);

  • Time zone;

  • Network status (WiFi, etc.), browser plug-in types and versions;

  • Technical device information (e.g. device model and name, operating system name and version, screen size, mobile phone carrier, Internet service provider);

  • Information we collect via cookies (which are small text files placed on your device). Cookies allow us to collect data, such as your device's model, operating system and screen size and other information about how you use our Services. For more information please see our Cookie Notice: https://zebrainy.com/cookies

  • Information we collect via the use of pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emails. –

  • Information we collect via the use of tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates to be able to evaluate how many users have downloaded the app.

Although some of this information (such as IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US and EU) may treat information that uniquely identifies your device as personal information.

Website Usage Information

When you use the Websites, we collect additional information from you by using persistent identifiers that permit identification of your device. The information we collect includes:

  • Website usage, including log information, that lets us know how you use the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);

  • Characteristics obtained by your use, such as data about pages of our Websites that were viewed during your visit, any actions or movements within the Websites and movements to/from the website from/to another website, date and time, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

Classical Personal Information

When you request information using the Websites or contact us directly, we may collect personally identifiable information about you that you provide us such as your name and surname, email address and demographic information such as your year of birth. When you voluntarily submit your ideas, cooperate in our contests and/or surveys or otherwise register with Zebrainy Limited, we may collect additional personally identifiable information about you that you voluntarily submit, such as your telephone number, address, resume, job position, etc.

When you pre-register for any new games and sign-up for marketing emails, we will collect your information that you submit in the pre-registration or sign-up forms, such as your name, your date of birth, your email address and your marketing preferences. We will use your contact information and other personal information only for the purpose for which you provided it to us. We will not share this data with third parties other than those detailed in this privacy policy.

If you wish to delete your personal information that we received from you, please send an e-mail to privacy@zebrainy.com and your personal information will be deleted from our database.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Provide our website services to you

Legitimate Interest

Website Management

Promote our goods and services

Account Management

Establish and manage our relationship

Understand the market in which we operate

Account Management

Learn about our website(s) users’ browsing patterns and the performance of our website(s

Website Management

Security

Managing security, risk and crime prevention

Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication

Promote our goods and services

Learn about how our products or services may be used

Understand the market in which we operate

If you object to us using your personal data for the above purposes, including direct marketing, please contact us using the email address in section 1.

When we use cookies or similar technologies we will seek your prior consent where required to do so by law.

When we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.

2.4 JOB APPLICANTS

We may collect personal data related to job applicants for positions advertised on our website.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

  • From you directly;

  • From a third party, for example, individual referrals or a recruitment agency;

  • Via hard copy and web-based application forms;

  • During networking events that we have either hosted, or sponsored, or attended; and/or

  • From publicly available sources (for example, professional networks, such as LinkedIn).

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data, which may differ, depending on the content of your CV or baseline documents you submit to us:

  1. Name;

  2. Residence address;

  3. Personal email address;

  4. Telephone number;

  5. Date of Birth;

  6. Career and education history;

  7. Skills, experience, and qualifications;

  8. Personal interests, languages spoken, questionnaire results;

  9. Gender;

  10. Names and contact details for references. Please note that it is your responsibility to obtain consent from your references prior to providing us personal information about them;

  11. Current and historic salary details together with salary expectations;

  12. Details of your current benefit entitlements;

  13. Information about your entitlement to work; and/or

  14. Other information you choose to give us.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to:

Our lawful basis for doing so is:

Check your eligibility to work in the country in which ф Zebrainy Limited affiliate is located. When you provide us with information regarding your disability, we will process it as part of our legal obligation to make reasonable adjustments for recruitment process

Legal obligation

We may use your personal data to:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Facilitate the selection process

Assess and confirm your suitability for employment

Communicate with you

Legitimate interests

Talent Management (including at an intra-group level)

Execute business process and internal management

Management Reporting (including at an intra-group level)

Safeguard the security of our infrastructure, premises, assets and office equipment, including prevention of criminal activity, defending legal claims

Managing security, risk and crime prevention,

Exercise or defend legal claims

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will keep and process your Personal Data only for as long as is necessary for the purposes for which it was collected. If you are successful, and we hire you, we will keep your CV as part of your employee record for the duration of your employment with us. We will keep CVs and documents submitted by unsuccessful candidates for no longer than twelve months, unless we obtained their consent to keep it for longer.

2.5 VISITORS TO OUR PREMISES

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from you directly and from our systems’ records.

B - PERSONAL DATA THAT WE COLLECT AND PROCESS

  1. Name;

  2. Business contact details;

  3. Organization;

  4. Role;

  5. Time and date of your visit.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to:

Our lawful basis for doing so is:

Our legitimate interests in doing so are:

Security

Legitimate Interest

Managing security, risk and crime prevention

Maintain records of visitors to our premises

Legitimate Interest

Management Reporting

If you object to us using your personal data for the above purposes, please let us know using the email address provided in section 1.

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your personal data for as long as necessary to ensure security of visitors to our premises and as soon as it is no longer necessary, usually after 90 days, we delete it.

3. WHO WE SHARE YOUR PERSONAL DATA WITH

We do not sell your personal data to Third Parties, оur Partner Organizations or Service Providers.

We cannot provide all services necessary for the successful operation of our Services by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking and fraud prevention providers and other third party service providers that develop and support our Services.

We do not share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address). We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

  1. Technical support providers who assist with our website and IT infrastructure,

  2. Third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;

  3. Professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;

  4. Providers that help us generate and collate reviews in relation to our goods and services;

  5. Our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or

  6. Service providers that assist us in providing our services.

  7. Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms of Use or other agreements, or as required by law.

For any additional questions about third party information collection please refer to privacy@zebrainy.com;

4. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA

We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third-party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

When we share your personal data with our affiliates in the EU and outside the EU. International transfers with Zebrainy Limited affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.

We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.

We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.

We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by the Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via privacy@zebrainy.com).

When we transfer your personal information to our Partner outside EEA, we ensure that our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation. For instance, to our partner that is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at www.privacyshield.gov).

You may request a copy of these agreements by contacting us using the email address in section 1.

5. CHILDREN’S PRIVACY

Zebrainy Limited adheres to the strict information collection, use and disclosure requirements. Zebrainy has established COPPA compliant privacy practices. If you have questions or concerns about our privacy practices, please contact us at privacy@zebrainy.com.

We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed toward, and we do not knowingly collect, maintain, or use personal information from children under the age of digital consent according to EEA data protection legislation without their parent’s/legal guardian’s permission, with the exception of persistent identifiers and age category as described below. If we learn that we have collected personal information other than persistent identifier or age category of a child under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@zebrainy.com.

The only personal information we collect from users who have identified themselves as below the age of digital consent according to EEA data protection legislation for the purposes of offering our services are persistent identifiers (such as User UDs, Device ID or IP address) and Child’s age category.

We do not share such persistent identifiers with third parties. They are used only to authenticate users of applications, to maintain or analyze the functioning of the application, to personalize the content of the application (or send push notifications), to perform network communications to protect the security or integrity of the user or the application, or to ensure legal or regulatory compliance. Child’s age category used to build a correct education plan (as we are required to do so by Contractual Necessity), its processed as a pseudonymized information (for example, ‘category A’ or ‘B’), so the date of birth could not be identified from it.

When using the persistent identifiers we will not contact users under the age of digital consent according to EEA data protection legislation, nor do any user tracking or profiling. For the detailed information about disclosure to third parties please see section 3 of this Privacy Policy. For any additional questions about third party information disclosure please contact us at privacy@zebrainy.com.

6. YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it, i.e. you have the right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to privacy@zebrainy.com.

Your rights include:

  • Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by uninstalling all the Services from each of your computing devices.

  • Right of access. You have the right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for the right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.

  • Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via privacy@zebrainy.com and we will correct it as soon as we can.

  • Data deletion. You have the right to request deletion of the personal information that we hold about you. Should you wish to do so, please contact us via privacy@zebrainy.com. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.

  • Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do so, please contact us via privacy@zebrainy.com.

  • Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.

  • Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.

You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in sections ‘Why do we collect your personal data and what are our lawful bases for it?’ above.

If you would like to exercise any of your above rights, contact us using the contact details in section 1 above.

B – LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA 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 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 Apps (such as in-app chat feature, multi-player 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 Apps 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 legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.

  • 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 you consent before sharing any information with our advertising partners for the purposes of interest-based advertising and before conducting any surveys.

  • Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.

C – 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.

D – CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, we will provide California customers certain information upon request (“Right to access”) or permit California customers to opt out of, this type of sharing (“Right to opt-out of the sale of your personal information”).

If you are a California resident and wish to obtain information about our compliance with this law, please contact us via privacy@zebrainy.com. We may request information from you to verify your identity. Please note that Zebrainy Limited is not required to respond to requests made by means other than through the provided email address or mail address.

E – 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 https://zebrainy.com/privacy-policy/.

For previous versions of this Privacy Policy please contact us via privacy@zebrainy.com