PRIVACY POLICY

Effective Date: February 1, 2019

INTRODUCTION

Hello! Welcome to the Thinkplay Privacy Policy. This policy describes how Thinkplay and its third party marketing and advertising partners collect, use, process and share information about you.

This Privacy Policy applies to Thinkplay’s games, websites, marketing and related services, which we here collectively call the “Services”. This Privacy Policy applies to information that you provide to us (or permit third party sites to provide us) or that we collect through the Services. By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to Thinkplay’s and our advertising partners’ use of your data for targeted advertising purposes. If you have any concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services. You are advised to consult this policy regularly for any changes.

THE DATA WE COLLECT

Data you provide us

Contact information (such as name and email address)
Player name and password
Profile information (such as profile photo)
Your messages to the Service (such as chat logs and player support tickets)
Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.

Data about your account and game progress
Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
Data about your device, such as device name and operating system, browser type and language
Data we collect with cookies and similar technologies (see more below)
General location data
Precise geo-location data (GPS, with your consent)
Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

In most cases, we also create a Thinkplay-specific ID for you when you use the Services.

Data we collect from our partners.

Data we receive if you link a third party tool with the Service (such as Facebook, WeChat or Google)
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Data from platforms that the games run on (such as to verify payment)
Data for advertising and analytics purposes, so we can provide you a better Service.

WHY DO WE COLLECT YOUR DATA

To make the Service work

To perform the contract, we process data necessary to

Create accounts and allow you to play our games and use our Service
Operate the Service
Verify and confirm payments
Provide and deliver products and services you request
Send you Service-related communications

To make the Services more suitable for our players

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

Update and develop player profiles
Develop and improve the Services and player experience
Manage our relationship with you
Provide social features as part of the Services
Customize your Services experience
Respond to your comments and questions and provide player support
Provide you Thinkplay offers in the Services as well as in other websites and services, and by email
Send you related information, such as updates, security alerts, and support messages
Enable you to communicate with other players

To show personalized advertisements

To show you personalized advertisements in the Services as well as in other websites and services (including email) we have a legitimate interest to process necessary data to

Track the content you access in connection with the Service and your online behavior
Deliver, target and improve our advertising and the Service For information on how to opt-out from personalized advertisements, see section ‘Your Rights’ below.

To keep the Services safe and fair

Ensuring a level playing field in the Services is a top priority for us. For more information on our acceptable use policy, see the Thinkplay Terms of Use.

In order to keep the Services and their social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Services and their social features
Moderate chats either automatically or manually
Take action against fraudulent or misbehaving players

To analyze, profile, and segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may then not function properly.

ADVERTISING

Our games may include advertising for third party(such as Facebook, Admob, Vungle, Unity etc.) products and services. By accepting this Privacy Policy and downloading or continuing to play our games or use our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.

When you play our games or use our Services, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’) and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.

Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.

You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies.

SECURITY

We have taken appropriate steps and followed industry standards to secure all personal data stored by our systems. All transactions are processed in keeping with the highest security level protocols, ensuring that no one can access or use personal information in an unauthorized manner.

However, while we take responsible measures to protect your Personal Information, the internet is not a 100% secure environment. We cannot guarantee the absolute security of all information transmitted or electronically stored. We disclaim any liability for any unauthorized access to, disclosure or damage to, theft of, or loss of any Personal Information. By using our website and/or our software, you acknowledge that you understand and agree to assume these risks.

Please note that you can terminate your account at any time and request that we completely delete all of your data we have stored. Just contact us at: support@thinkplay.co.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

Those rights include:

Right of access. You have a 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 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 endeavour to tell you why. We will try to respond to any request for a 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 realise that any of the information that we hold about you is incorrect, please let us know at support@thinkplay.co and we will correct it as soon as we can.
Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. 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.
Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as Gold Bars or Boosters will be lost and we may not be able to restore them in the future.
Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests.
Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.

CONTACT US

If you have any questions or concerns about any of the matters in relation to this privacy policy, including to exercise any of your rights, then please contact our customer services by email to support@thinkplay.co.