Privacy Notice

SDCode develops and publishes social games for mobile devices. This Privacy Notice describes the ways SDCode collects, stores, uses, discloses, or otherwise processes the personal information of our users in connection with their use of our products or services, including our product offerings. Additionally, this Notice describes the rights and choices concerning your information that may apply to you.  

This Privacy Notice covers the following topics:

• Personal information we collect and how we collect it
• How we use your information
• Sharing of your information
• Online advertising 
• Security of your information
• Children’s Privacy
• Third-party websites and services
• Transfer of personal information outside your country 
• Specific provisions for EEA, UK
• Contact information

If you have questions regarding this Notice or our collection and use of personal information, please contact us as described in the Section “Contact Us”. 

1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile).  At times, we may collect personal information about you from other sources and third parties, including other players. 

1. Information We Collect Automatically or From You Directly

Technical and Usage Information

When you access our Services, we may use cookies and other similar technologies to collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile device ID (IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services, including the links, objects, products and benefits you view, click or otherwise interact with (also known as “Clickstream Data”). Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. In connection with your use of certain Services, we will create and assign to your device an identifier that is similar to an account number. In addition, in certain circumstances, we may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or e-mail address. We may also infer your approximate geographic location based on your IP address. 

Payment Information

When you order any good or service through the Services, including any virtual currency or virtual good, we collect certain non-financial transaction information related to these purchases, including what you purchased, the price, and the date.  Your in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices). The third-party payment processors will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information to enable them to process your payment.  The third-party payment processors may also retain this information to enable you to purchase additional items through our Services without having to re-enter your payment information each time. Please note third-party payment processors do not share your financial information, like credit card numbers, with us. In addition, please note that the third-party payment processors’ processing of transactions and collection and use of your personal information is governed by their terms of service and privacy policy, and purchases through these third parties may also be subject to additional policies.  We encourage you to review the terms of service and privacy policies of those third parties to learn more about how they handle your personal information.

1. Information We Collect From Other Sources

We may collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers, such as digital advertising companies; and (iii) social networking sites. We may combine this information with the information we collect from an individual directly.

1. Sensitive or Special Categories of Information

We typically do not request or seek to elicit sensitive or special categories of information, but you may choose to provide this information to us in connection with certain of the interactions described above, including when you ask for assistance from our Customer Support team. The meaning of sensitive or special categories of information varies by jurisdiction and it could include, for example, health, genetic or biometric data, or precise location information.

2. HOW WE USE YOUR INFORMATION 

We use information collected through our Service for purposes described in this Notice or disclosed to you in connection with our Service. For example, we may use your information for: 

Service Delivery

• Create your Service accounts and allow access to our Services;
• Operate our Services;
• Improve our Services;
• Understand you and your preferences to enhance your experience and enjoyment using our Services;
• Respond to your comments and questions and provide customer service;
• Provide and deliver products and services you request;
• Prevent fraud or potentially illegal activities, and enforce our Terms of Use;

Marketing and Advertising 

• Deliver and target advertising and marketing and promotional information to you; and
• Communicate with you (including via email and push notifications) about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners.

Push Notifications

We may occasionally send you push notifications through our Service to send you game updates, high scores and other service-related notifications that may be of importance to you.  You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

3. SHARING OF YOUR INFORMATION 

We may share information we collect for the following purposes:

• Service Providers.  With service providers that perform services on our behalf or enhance our Services, including hosting services, customer service, analytics services and to assist us in our marketing efforts; 
• Payment Processors. With third-party payment processors that process payments you make;
• Advertising Partners. Advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts, including as described in the Online Advertising section below;
• Professional Advisors. With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;
• Authorities and others. With law enforcement and public authorities, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above;
• Your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

4. ONLINE ADVERTISING 

Interest-Based Advertising

To the extent we display advertising in our Services, with your consent as may be required by applicable law, we may share or we may allow online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time to enable them to play or display ads on our Services, on other devices you may use, and on other websites, apps, or services.  Typically, though not always, the information we share is provided through cookies, software integrations, or similar tracking technologies, which recognize the device you are using.  We and our third-party partners use this information to try to make the advertisements you see online more relevant and tailored to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.   Such information includes the following:

• Device make, model and operating system;
• Device properties related to screen size & orientation, audio volume and battery;
• Carrier;
• Operating system;
• Name and properties of mobile application through which the user interacts with the Services;
• Country, time zone and locale settings (country and preferred language);
• Network connection type and speed;
• IP Address;
• Gender;
• Keywords;
• City- and/or country-level geolocation data;
• Internet browser user-agent used to access the Services; and

Google Analytics and Advertising

We utilize certain forms of display advertising and other advanced features through Google Analytics, including, but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager Integration, Google Ads, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.  To learn how you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. 

Opting-Out of Interest-Based Advertising

You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.  If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice.  AppChoices is available at the links below:

• DAA AppChoices Android

You may also limit data collection by third parties by visiting your mobile device settings and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”) or by exercising other privacy options in your device’s settings.  

Please note that electing to opt-out will not stop advertising from appearing in your browser or applications or reduce the number of ads that you receive.  You will still receive ads, but those ads may be less relevant to your interests.  In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to apply your opt-out choices to that particular browser or device. 

Please note that the opt-out tools described in this section are provided by third parties, not by us.  We do not control and are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

5. SECURITY OF YOUR INFORMATION 

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage. 

However, no security system is impenetrable, and we cannot guarantee the security of your personal information.  Any transmission is at your own risk.

6. CHILDREN’S PRIVACY 

The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services.   If we learn that we have unintentionally collected personal information from a child, we will delete that information.  If you believe that we might have collected personal information from or about a child, please contact us at sdcode.inc@gmail.com.

7. THIRD-PARTY WEBSITES AND SERVICES 

The Services may contain integrations or links to third-party websites or services, including those of our business partners.  By interacting with these third parties, you are providing information directly to the third party.  Please note that the Studio is not responsible for the privacy practices of these third parties or any entity that it does not own or control.  We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

8. TRANSFER OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY 

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Economic Area, United Kingdom or Switzerland, your personal information may be processed outside of those regions, including in the United States. 

9. SPECIFIC PROVISIONS FOR EEA, UK 

These additional provisions apply to individuals who are located in European Economic Area (“EEA”), United Kingdom (“UK”) and Switzerland. 

Your Rights With Respect to Your Personal Information 

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

• Accessing and Correcting Your Personal Information.  At any time, you may request to access the personal data that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide us with the necessary information to correct it. 
• Erasing or Restricting Access to Your Information.  You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why. 
• Transferring Your Personal Data (Otherwise Known as Your Right to Data Portability).  You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others. 
• Right to Object to Processing.  You have the right to object to our processing of your personal data, under certain conditions. 
• Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data based on that consent. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal. 

If you wish to exercise any of your rights detailed above, please contact us at sdcode.inc@gmail.com or write to us at the address set forth in the “Contact Us” section. If you make a request, we will typically look to respond within one month, although a longer period may be permitted.  

For questions about the lawful basis we rely on for data processing, please contact us at sdcode.inc@gmail.com.  Visit the “Contact Us” section below for contact information.

10. CHANGES TO THIS NOTICE

We may update this Notice to reflect changes to our data and information privacy practices. If we make any material changes, we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Notice for the latest information on our privacy practices. Please note that if we need to adapt the Notice to legal requirements, the new privacy Notice will become effective immediately or as required.

11. CONTACT US

Our Data Protection Officer

You may contact us at sdcode.inc@gmail.com