de_CLAS Softworks Privacy Policy
de_CLAS Softworks develops and publishes game titles for mobile devices (each game title, “Title”). These titles include but are not limited to the following:
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Eat The Spud
We collect information in either of 2 ways:
Directly – from your device through the Titles. For this purpose, we engage with analytics partners that collect the information on our behalf.
Indirectly– through our advertising and analytics partners.
We collect information as described in this privacy policy for de_CLAS Softworks own purposes, as a data controller under data protection law where relevant.
Scope
This privacy policy describes de_CLAS Softworks privacy practices with respect to information it processes in relation to the Titles.
The titles are available to users all around the world. Accordingly, throughout the document, we try to harmonize our approach and the language of the privacy policy as much as possible. However, sometimes we refer to specific laws that require further disclosures.
These disclosures cover laws and regulations applicable to the following regions:
Individuals who we deem to be located in the European Economic Area, the United Kingdom or Switzerland – With respect to the collection and processing of their personal data, as defined by the General Data Protection Regulation (“GDPR”), and the UK Data Protection Act.
Individuals who we deem to be located in California – With respect to the collection and processing of their personal information, as defined by the California Consumer Privacy Act (“CCPA”). For purposes of the CCPA, this Privacy Policy serves as both the Privacy Policy and Notice at Collection of Personal Information.
Information We Collect
Information collected directly from you through our services, and information provided to us by advertising and analytics partners:
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Identifiers associated with your device:
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Advertising ID of the device – Advertising ID refers to Google Advertising ID (“GAID“, on Android devices) or ID For Advertising (“IDFA, on iOS devices). The Advertising ID is a resettable persistent identifier generated by Android or iOS that allows online advertising companies to recognize a device across non-affiliated apps. Additional information about how to limit our use of your Advertising ID can be found under “How to Control Your Information”.
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The IP address of the device.
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Information about the device type and settings known as “User Agent“.
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The ID For Vendors (“IDFV“, on iOS devices), which is a persistent identifier that allows companies to recognize a device across apps of a specific vendor.
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General technical information about your device:
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The device type and language, operating system name and version.
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The device’s time zone.
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The amount of free memory on the device.
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The name and version of the Title.
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The battery status.
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The device’s limit ad tracking status.
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The name of the manufacturer of the device.
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The name of the mobile carrier.
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The device’s internet connection type (e.g., Wi-Fi).
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Your activity in connection with the Title: Transactions and in-app purchases made in the Title, your progress or movement in the Title, and in-game events.
Information received from advertising and analytics partners
– The total amount of revenues received as a result of advertising served to a specific device ID.
How We Use the Information We Collect
We use the information we collect mainly to provide you with the Services you request from us. In addition, we use the information for the following purposes:
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to improve and optimize the Titles and our players’ experiences;
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to communicate with you about the Titles you’re using, including in-game updates, new Titles, and promotional offers that we think might be of interest to you;
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to provide technical support and respond to player inquiries;
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to protect the safety and well-being of our players;
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to protect de_CLAS Softworks rights and property in connection with the Titles;
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to prevent fraud or potentially illegal activities;
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to manage and deliver contextual and behavioral advertising, including for the purpose of generating aggregated reports, and attribution;
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to administer rewards, or other promotional activities or events sponsored or managed by us or our business partners;
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To conduct marketing campaigns across our advertising and marketing partners, including personalized campaigns based on your interactions with the Titles;
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to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties;
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to conduct research.
The GDPR Angle:
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We process personal data for providing you with the Services on the basis of our contract with you.
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We process personal data for the purposes of preventing fraud or potentially illegal activities, protecting our rights and property, serving contextual advertising, conducting non-personalized marketing campaigns, improving and optimizing the Titles and our players’ experiences, communicating with you about the titles you are using, administering rewards and conducting research, based on our legitimate interests.
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We, or our advertising partners, may process your personal data for the purpose of serving you with personalized advertising, or conducting personalized marketing campaigns based on your interactions with our Titles, if we, or our advertising partners, obtained your consent.
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We may also process your personal data for compliance with applicable legal obligations.
The CCPA Angle:
Personal Information We Collect, Disclose for a Business Purpose, and Sell – We collect the categories of personal information about California users identified in the chart below.
Recipients of California Personal Information – Although we do not sell personal information for monetary consideration, we do sell personal information under the definition of “sale” in the CCPA, subject to your choices with respect to “sale” of personal information, to the categories of third parties listed below::
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Advertising/marketing companies;
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Analytics companies; and
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Attribution companies.
How We Share Your Information
We share your information with:
Other advertising and marketing partners – for the purpose of receiving, or delivering, advertising campaigns from such advertising partners.
Our corporate affiliates – from which we receive services, such as IT, security, storage, delivery of advertising campaigns, personalized advertising, and other internal operations.
Advertisers – for the purposes of attribution.
Service providers – We share your information with our service providers for the purpose of receiving services such as fraud detection and prevention, analytics, reporting, and storage.
We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to:
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Comply with any applicable law, regulation, legal process or governmental request.
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Enforce our agreements and policies, including investigations of potential violations thereof.
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Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues.
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Establish or exercise our rights to defend against legal claims.
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Prevent harm to the rights, property or safety of us, our users, yourself or any third party.
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Collaborate with law enforcement agencies or in case we find it necessary to enforce intellectual property or other legal rights.
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When we are undergoing any change in control, including by means of merger, acquisition, or purchase of all or substantially all of our assets.
How to Control Your Information
Personalized Ads
We collect and transfer your information to other entities (including our corporate affiliates and non-affiliates such as advertisers, other ad networks, and third parties acting on behalf of these types of entities) that use the information described in this Privacy Policy for serving you personalized ads (i.e., ads that are based on your interests or profile).
Opt out from personalized ads
You can opt-out of personalized ads inside of the game you are playing, or, if you provide your preferred email inside the ad, you can get a link to order a personal information disclosure report. This means you will receive a report for all the data we collect in games you play that use Unity ads. You will also be able to opt-out of personalized ads for the game you are playing at that time.
Scope of the opt-out
Please note that if you use more than one device, you need to opt-out separately in each device. In addition, if you reset your advertising ID through your device’s platform settings, you should follow the steps above to reset your opt-out choice. Please note that opting out may not stop data from being collected from your device or transferred for other, non-personalized advertising purposes such as optimization, reporting, frequency capping, internal operations, and fraud prevention.
Exercise your rights – To exercise your rights under CCPA/GDPR, you can start by clicking on the privacy icon in the left bottom corner of a Unity ad. The icon looks like this:
Once you click on this icon, you will be guided through a series of steps to achieve the changes or requests you prefer. Other privacy related options are located in the MainMenu of the game under Options -> Privacy Settings.
Children
de_CLAS Softworks does not knowingly collect or maintain personal information collected online from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information without parental consent.
The GDPR Angle:
We do not collect or otherwise process personal data from individuals in the European Economic Area the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to perform the agreement with such individuals, to comply with law or to support our legitimate interests as described above.
Third-Party Services
Our services may link to other websites or mobile apps. Please be advised that we are not responsible for the privacy practices of such other websites or mobile apps as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or mobile apps and we shall not be responsible for any use of such websites and/or mobile apps.
Changes to This Privacy Policy
We may revise this Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. By continuing to access or use an app containing our services after those changes become effective, you agree to be bound by the revised Privacy Policy.