Privacy

Effective Date: March 23, 2022

Version: 1.1.0

 

 

Jump to Children’s Privacy

 


Your privacy – it’s a big deal to us. Of course, we know, nobody loves reading long privacy policies though – even us! But, please know this policy is detailed and here simply because we care and put privacy first in our service. We refuse to compromise here. We value your rights and want you to be have full transparency and be aware of how we use data, protect your privacy, etc. Users’ privacy, safety, and security in our service are our top priorities – of course with fun too :). So please take a few moments to review here, and as always let us know if you ever have questions or concerns!


 

Widgetbaby.com (“Website”) and its related WidgetBaby! Application (“App”), services, and products specific to WidgetBaby (collectively “WidgetBaby” or the “Service”) are owned and operated by H’Appile Interactive, LLC (“H’Appile Interactive”,”our”, “us”, “we”).

 

This policy (“Privacy Policy”) informs you of the data and Information, including Personal Information, we may collect when you use the Service and explains in detail how this information is used. H’Appile Interactive complies with all applicable laws, policies, and regulations related to the collection, usage, and sharing of all information. Please contact us directly with any questions or concerns after reviewing this policy. This is a living document and we’re always striving to keep this policy as clear and simple as possible, so please understand you may see updates from time to time.

 

H’APPILE INTERACTIVE MAY CHANGE, MODIFY, AMEND, SUSPEND, TERMINATE, OR REPLACE THIS PRIVACY POLICY FROM TIME TO TIME AND WITHIN ITS SOLE AND ABSOLUTE DISCRETION. IN THE EVENT H’APPILE INTERACTIVE CHANGES, MODIFIES, AMENDS, OR REPLACES THIS PRIVACY POLICY, THE EFFECTIVE DATE AND VERSION, LOCATED ABOVE, WILL CHANGE. YOUR CONTINUED USE OF THE SERVICE AFTER A CHANGE IN THE EFFECTIVE DATE OR VERSION OF THIS PRIVACY POLICY CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE CHANGE, MODIFICATION, AMENDMENT, OR REPLACEMENT CONTAINED WITHIN. THIS PRIVACY POLICY SHALL SUPERSEDE ANY PRIOR, AND APPLIES TO ALL VERSIONS OF THE SERVICE, INCLUDING FUTURE.

Contents:

1 Definitions.

Children’s Privacy

Common Questions/FAQs

2 Information we may Collect.

2.1 Personal Information

2.1.1 Children’s Personal Information

2.2 Consent/Compliance Information

2.3 Contextual/Device Data

2.3.1 About Coarse Geo-Location

2.4 Crash Data/Logs

2.5 App Data/Service Usage Data

2.6 User Generated Content

2.7 Ad/UA Performance Data

2.8 Customer Communications/Feedback.

3 About Tracking Technologies.

3.1 Cookies

3.2 Interest Based Ads & Advertising Identifier (“IDFA”)

3.3 Identifier for Vendor (“IDFV”)

4 When we Collect or Receive Information.

5 How and Why we Use Information (Lawful Bases).

6 When and Why we Share Information (Lawful Bases).

7 Who we Share Information With, Third Parties.

7.1 Analytics/Marketing

7.2 Advertising

7.3 Database

7.4 Payments

7.5 Authentication

7.6 Customer Service/Communication

7.7 Compliance Management/Consent

8 Data Aggregation and Service Statistics.

9 Information Transfer and Storage.

10 Information Security.

11 Payments.

12 Your Choices.

13 EU Users’ Rights under the GDPR.

14 Brazil Users’ Rights under the LGPD.

15 California Users’ Rights under the CCPA.

16 Our Policy on DNT Signals under the CalOPPA.

17 Purchase or sale of the App and/or Other Assets.

18 How to stop us from collecting your Personal Information.

19 How to request a copy of your Personal Information.

20 How to request we delete your Personal Information.

21 Your Representations, Right to Update.

22 Children & Child Online Privacy Protection (e.g. COPPA, GDPR-K).

22.1 Parents’ Rights & Choices

23 Contact and Notices.

23.1 Representation for Data Subjects in the EU and the UK

24 Third Party Data Processor Contacts.

1 Definitions.  [contents]

   (a) “Children’s Online Privacy Protection Act” (“COPPA”) means the United States law for online protection of Children’s privacy.

 

   (b) “California Consumer Privacy Act” (“CCPA”) means the California statute intended to enhance privacy rights and consumer protection for residents of California, United States.

 

   (c) “General Data Protection Regulation” (“GDPR”) means the European Union (“EU”) law on data protection and privacy applicable to individuals within the EU.

 

   (d) “Lei Geral de Proteção de Dado”(“LGPD”) means Brazil’s law on data protection and privacy applicable to individuals within Brazil.

 

   (e) “Information” includes the literal definition of “information” and means any data, content, parameters, identifiers, etc.

 

   (f) “Personal Information” or “Personal Data” is a subset of Information, and means any Information “relating” to an identified or “identifiable natural person”. An identifiable natural person is one who can be reasonably identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, behavioral, or social identity of that natural person. Data that relates to a person would be data that has the ability to impact the person or be used to learn and make decisions specifically about them or targeted to them.

 

   (g) “Persistent Identifier” also referred to as “device identifiers” are anonymous numeric or alpha-numeric character sequences that uniquely identify a specific device. Alone, and with limited usage, these identifiers can’t be reasonably linked back to a specific individual. In some cases, however, you may see in this policy we regard these as “Personal Information”. This is because in unique circumstances or over time, these identifiers can become personally identifiable and traceable back to you. Examples may be in cases where they’re used to track behavior across third parties services, depending on how they may be shared/stored, and if they’re used to build behavioral profiles for targeted advertising. (e.g. Consider an IP Address that identifies a computer (or a group of) on the internet. Alone, this doesn’t identify who that computer belongs to or is used by, etc. unless possibly combined with additional records from say an Internet Service Provider(i.e. “ISP”) that may link that identifier to some individual.)

 

   (h) “Internet Protocol Address (“IP Address)” is a Persistent Identifier that identifies your device(s) or computer(s) on the internet.

 

   (i) “Identifier for Advertiser (IDFA)” also referred to as “advertising identifier” or “advertising device identifier” is a Persistent Identifier, and may be used for the purposes or tracking and attributing users’ behaviors across their device and third parties to learn their preferences and interests so ads may be better targeted for them.

 

   (j) “Identifier for Vendor (IDFV)” also referred to as “vendor device identifier” is a Persistent Identifier that identifies one or more installed application(s) by the same vendor on a given device, and can be used to understand first party analytics and contextual use of an application by that device.

 

   (k) “Targeted Advertising” is advertising selected or curated based on known Information for the User and/or device, in an effort to be most relevant and appropriate for them. Targeted advertising has two forms, “Personalized” and “Contextual”.

 

   (l) “Personalized Advertising” for the purposes of this policy and when referenced within the App, if authorized/allowed, means with respect to use of the IDFA to track and behaviorally target interest based ads for you in the Service. This may use a profile of data that details your interests and actions from use across your device and third party apps/services.

 

   (m) “Contextual Advertising” for the purposes of this policy may also be called “Contextualized Advertising”, “Contextually Based Advertising”,”ads served contextually” etc. Contextual Advertising refers to advertising that doesn’t track user behavior or interests across third party apps (i.e. doesn’t use the IDFA). This advertising is limited to only using first party data obtained in the context of and/or from your use of the Service or those by H’Appile Interactive on your device.

 

   (n) “Private Database” means a database that is only accessible by You and/or Your device, or any of those devices which share the same credentials (i.e. Apple ID) as You. (e.g. iCloud)

 

   (o) “Public Database” means a database that is accessible at various levels to the general Service’s user base. Public Databases we maintain are zoned and secured using security rules to limit access based on need, function, and appropriate user privilege or relationship. Such databases may be hosted on our own servers and/or via a cloud provider such as Firebase.

 

   (p) “Shared Database” means a database that may be available to a subset of the public (i.e. shared among friends or family, etc) and which you choose to share or control what records/data from your Private Database may be shared into such “Shared Database”.

 

   (q) “User(s)” means individuals that download and/or use the Service.

 

   (r) “You / Your / You’re” means Users and/or those reviewing this policy.

 

   (s) “Data Subject” or “subject” when referred to in such context herein means a living individual whose Personal Data is being collected, processed, stored, or shared.

 

   (t) “Data Controller” means the natural or legal person, or entity, who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are the Data Controller of your Personal Data.

 

   (u) “Data Processor” (or Service Provider) means any natural or legal person, or entity, who processes the data on behalf of the Data Controller. We may process and/or use the services of various Service Providers in order to process your data more effectively. For the purpose of this Privacy Policy, we are also a Data Processor of your Personal Data along with various third party partners detailed in this policy.

 

   (v) “Internal Operations” is in reference to “Support for the internal operations of the Web site or online service” as mentioned in COPPA 16 C.F.R. § 312.2 Definitions. Also described more here in section J5.

 

   (w) “Age Gate” is a screen presented during first launch after install or initial onboarding that asks for users’ Age so we can configure and “gate” features of the Service appropriately for a mixed user audience.

 

   (x) “Children/Child” for the purpose of this policy refers to individuals who are under the age of ability to consent to Personal Data processing in their jurisdiction (e.g. < 13 in the USA, Brazil; < 16 in California; < 16 in parts of the EEA, etc). Please refer to your state’s or jurisdiction’s specific privacy/data protection laws to learn more. Generally, we will always regard all users < 13 years of age to fall into this category. Age used for determination of Child/Children users in the Service is based upon Age Gate entry.

 



Children’s Privacy:

 

At H’Appile Interactive, we make apps that are for all audiences. Our Service is designed for a broad general audience of users. While we do not primarily direct the App or Website towards Children, we are committed to protecting all users’ privacy. Therefore, we’ve implemented the following features 1-6 specifically to protect any Children Users, in addition to the rest of our general privacy policy that follows in this document.

 

1)   An “Age Gate” upon launch.

 

For users deemed as Children based on the user specified Age Gate (1) input:

 

2)   We do not request, collect, or share personally identifiable “Advertising Device Persistent Identifiers” (e.g. the IDFA).

3)   We never provide Personalized Advertising to Children, and all interest based advertising, surveys, and re-marketing ads are disabled.

4)   We only display advertisements from Google Admob, which we provide flags to indicating that users are Children and to filter ads to a “G-Rated” audience.

5)   We place extra parental/guardian gate(s) throughout the app to help prevent inadvertent purchases by accidental clicks from a user.

6)   We may restrict or limit certain features of the Service, content sharing, etc. where applicable and to best protect privacy and safety.

 

While we’ve worked hard and carefully to design the above measures, we still always encourage parents and guardians to discuss safe internet and mobile device use with Child users and to monitor their Children’s safe mobile application use. We ask you to always facilitate any communications with us they need for support, feedback, etc. related to the Service to comply with our communication processes and this policy.

 

2.1.1 Children’s Personal Information.
22 COPPA Compliance and Parents’ Rights.




Common Privacy Questions, FAQs:

 

   Q. Do you “track” my precise location?

   A. No. We only use a “coarse” location (i.e. like your country or city) to help configure the Service appropriately, for our internal analytics, etc. Often this is just inferred from your IP address. We have no idea where you are at the actual street level, your address, etc. Your precise whereabouts is your private information and we don’t collect such or monitor. Learn more.

 

   Q. Do you “sell” my data?

   A. No, never in the sense of a literal sale. Only when you have opted in, may we share some Personal Data (e.g. an Advertising Identifier) for helping our advertisers serve Personalized Advertising based on your interests. This can help show ads that you might be interested in which help support and monetize the Service. This is always optional though and you can configure this off or choose not to opt in so you only receive general and/or contextualized ads. This is never provided or enabled for Children users. Learn more.

 

   Q. My Child wants to play WidgetBaby?

   A. We place a special emphasis on our commitment to Children’s Privacy and care about parents’ rights. We take special measures to protect Children users appropriately. You can learn more in the above block “Children’s Privacy” on how we specifically protect and configure the Service for known Children users. Learn more.


2 Information we may Collect.  [contents]

2.1 Personal Information  [contents]

When you use the Service and/or contact us, we may collect Personal Information. This information may include:

 

   Persistent Identifier(s):

   Cookies on our Website (see section 3.1 for more).

   Device Identifier for Advertiser (IDFA) if authorized and allowed for the Service on your device (see section 3.2 for more).

   Device Identifier for Vendor (IDFV) from the App installation on your device (see section 3.3 for more).

   Internet Protocol Address (“IP Address”).

 

Please note based on your privacy choices, data sharing settings, Children users, etc. these may not always be linked or traceable back to your identity. For limitations on how we use these and protect your privacy, please see section 3 regarding Tracking Technologies.

 

   Email Address, Name:

   Through customer service or support requests initiated by you we may receive your email address and/or your name during these communications. Important: These are not used or asked for in the App or Website itself. We only include them here for completeness in the case of customer service requests or you contacting us via email.

 

   Surveys or Interest Based Responses:

   May be prompted in select cases by advertisements or third party offers in the Service. These are always completely voluntary and optional and governed by the respective third party’s privacy policy (see section 7.2). Not present for Children users.

2.1.1 Children’s Personal Information  [contents]

Collection is limited to Persistent Identifiers – The Service is intentionally designed such that if we collect a Persistent Identifier of a known Child user, it’s never used to communicate with (unless under one-time contact exception per COPPA 16 C.F.R. § 312.5(c)(3)), behaviorally track across third party services, or provide any Personalized Advertising. For Child users all Persistent Identifiers are limited in use and scope to solely Internal Operations (COPPA 16 C.F.R. § 312.5(c)(7)).

2.2 Consent/Compliance Information  [contents]

   Age:

   To protect Children’s Privacy rights and determine how to serve users appropriately.

 

   Country/State of Location and/or Residence, either as determined by your entry or from IP Address:

   To configure the App properly for your privacy protections and regional specific compliances.

 

   Data Sharing Preferences/Consent Acknowledgements:

   To save your settings and preferences.

   To maintain compliance with logs/traceability of consent captures.

2.3 Contextual/Device Data  [contents]

When you access the Service, we may also collect certain information automatically about the “context” of, or device of, your use, including, but not limited to, the type of device you use, network carrier, do not disturb or silenced mode, airplane mode, bluetooth connection state, network signal strength, battery state of charge, keyboard language settings, UI mode (e.g. light/dark theme, etc), device orientation, the local timezone of your use, anonymous identifiers (e.g. IDFV), anonymized IP Address (e.g. last octet masked), disk space, the coarse city/regional geolocation of your use (i.e. not at street level, see 2.3.1), your device’s operating system version, the currently installed app version, the type of Internet browser you use, the timestamp/date of your use, and other diagnostic data. This information helps us understand the “context” of, and track analytics from, use of the Service so we can serve you best.

2.3.1 About Coarse Geo-Location  [contents]

We never track users at the street level nor does our Service provide any ability to do so. We only infer a coarse or “regional” (i.e. country, state, city level) location based on IP Address or user selection. This is used for compliance purposes, privacy consent management, analytics, etc. as outlined and detailed by this policy.

2.4 Crash Data/Logs  [contents]

To improve and diagnose crashes of the Service, we may also collect crash logs and information when/if the Service experiences a crash during your use. This information may include contextual data as defined in 2.2 and additional information including operating system state (e.g. memory use, CPU use, etc), device state (e.g. orientation, etc.) and specific “traces” or logs of activity (e.g. actions within the app such as screen transitions/sequences, taps, etc.) leading up to and at the time of crash.

2.5 App Data/Service Usage Data  [contents]

We may collect software level App Data or parameters such as unique identifiers, session or authentication tokens, settings, flags, etc. that are created based on your selection, use, or are auto generated in your App. These may be used to provide or secure connection of the App with our, or third-party, servers and/or to maintain and configure the App for you.

 

We may also collect Service Usage data from your use. We may collect/track things such as the frequency of your use (e.g. session/launch instance dates and/or time stamps), the count or frequency of specific feature(s) use and/or action(s) you take or have taken within the Service, such as page visits, screen views, screen gestures or inputs, software and/or algorithm states, variables, metrics, run-time actions, database and cloud store usages etc. We may use these stats to learn about how the Service is used and to improve the Service through analytics, insights, etc.

2.6 User Generated Content  [contents]

We may collect user generated content from your use. This may include content such as avatar or character details (e.g. their name, gender, customizations), game play stats, etc.

2.7 Ad/UA Performance Data  [contents]

We may collect advertising and user acquisition(UA) metrics through the duration of a session and use, including click through rates on advertising impressions, completion percentages on video based ads, impression volumes, domains of previously shown ads, install stats/attributions, media sources (e.g. Facebook, Google, etc) and/or campaign identifiers retained from the link the app was installed or opened from, etc. This Ad/UA Performance Data is not linked to your personal identify and cannot be used to behaviorally track you across third party apps or websites, unless you’ve granted permission for App Tracking Transparency and sharing of your device’s IDFA. Your privacy here is very important to us, and you’re always in control of this IDFA setting as detailed in section 3.2.

2.8 Customer Communications/Feedback  [contents]

We may collect feedback or communications during the course of receiving messages from Users for support, troubleshooting, reviews, comments, etc. This may include simple text and/or device screenshots of App related, satisfaction ratings or opinions, etc.

3 About Tracking Technologies.  [contents]

3.1 Cookies  [contents]

Cookies are small pieces of data that are stored by your browser when a website is visited to track and store information associated with your activity to help improve your browsing experience, capture analytics, perform authentication, store cache records, etc.

 

Since the App primarily exists on a native iOS, iPadOS, watchOS, or MacOS application, we don’t directly use cookies in the App. However, some of our adjacent platforms, such as the Website, links found within the App that direct to the Website, and any other subdomains or websites associated with the Service may use Cookies, web beacons, pixels, and other similar technologies from third-party service providers.

 

You have a variety of tools available to control the data collected by Cookies, web beacons, pixels, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use Cookies and to withdraw your consent by clearing or blocking Cookies. You can also stop H’Appile Interactive from placing Cookies (other than those required for the Website and/or App to function) on your device by referencing the instructions below.

 

The table below sets out how we may use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

 

Type of Cookie

Description

Managing Settings

Required/Essential Cookies (Strictly Necessary)

Required/Essential – or strictly necessary – cookies enable you to navigate the Website and are required to provide its features, maintain compliance, respect your privacy choices, secure the service, etc.

 

These may include cookies by:


Webtoffee and CookieYes, our cookies consent and compliance management partners

 

consentmanager AB, as our advertising choices IAB TCF framework partner learn more here for providing maximum ad network configurability and privacy choices, and following best practices for privacy regulations and compliance (i.e. like in the EEA under GDPR, etc)

 

WordPress/Jetpack by Automattic, for the operation, navigation, and support of our website

 

Intercom, for the facilitation of messaging with us when you contact us via the website’s Intercom plugin

 

Because required cookies are essential to operate the Website there is no option to opt out of these cookies.

Analytics/Performance Cookies (Non-Strictly Necessary)

This information is used by us to help us improve our Website and App by analyzing its use, performance stats, etc.

 

We may use Google Analytics to help us analyze how our Website and App is used, including the number of visitors, where the website visitors have come from, and the pages they visit. This information is used by us to improve our Website and App.

 

To learn more about safeguarding your data for websites using Google Analytics, visit here. To opt of our data collection by Google Analytics, you can download and install a Google Analytics opt-out browser add-on here.

 

To learn more about how Google Analytics may use cookies on the Website and/or App visit here.

 

See browser based cookies configuration note below.

Functionality Cookies (Non-Strictly Necessary)

Functionality cookies may allow us to remember your custom choices or settings for better functionality and optimization of appearances when you return to the site, etc, but are not required for the website’s features to operate.

See browser based cookies configuration note below.

Advertising Cookies (Non-Strictly Necessary)

The Website does not use or show any advertisements and therefore provides no Personalized Advertising and uses no Advertising Cookies.

Not used or present on Website.


 

Browser based configuration: You can also adjust your individual browser settings relating to cookies by visiting these pages:

 

· Google Chrome

· Internet Explorer

· Microsoft Edge

· Mozilla Firefox

· Safari (Desktop)

· Safari (Mobile)

· Android Browser

 

For other browsers not listed, please consult the documentation that your browser manufacturer provides.

3.2 Interest Based Ads & Advertising Identifier (“IDFA”)  [contents]

The Advertising Identifier (“IDFA”) on your device can be used to track your ad clicks and behavioral actions across your device’s use (e.g. third party app usage, etc). This can help us understand and track your interests and preferences. If your device settings allow and you’ve provided opt-in permission, the IDFA may be shared with third-party advertisers to track and target Personalized Advertisements. You understand and consent that if you allow this tracking/targeting, this may also use automated decision making and algorithms to serve you behaviorally targeted ads. You can restrict this IDFA access, as detailed below, by either (1) choosing not to opt-in to ATT, or (2) if already opted into ATT for the App, then modifying in your device privacy settings:

 

(1) For enhanced privacy control, Apple’s App Tracking Transparency (ATT) framework provides explicit means for choosing to opt-in to sharing your device’s IDFA at the app level. If your device settings allow, you may be asked during the use of the App if you’d like to opt-in to “Allow Tracking” so we can personalize advertising for you using the IDFA described here. You can also learn more here https://developer.apple.com/app-store/user-privacy-and-data-use/. If you choose to opt-in, this can help our advertisers provide more meaningful and Personalized Ads during your use.

 

(2) If you’ve already opted into ATT for the App, you can always view your current tracking permission setting and change this preference to control sharing of your IDFA within the “Settings>Privacy>Tracking” on your device.

 

Note you can also find additional instructions for limiting Advertising here https://support.apple.com/en-us/HT205223.

 

Note, disabling or preventing sharing of the IDFA on your device by not opting in for ATT are not means to stop all advertising in the Service. Our right to advertise in the Service is described in the End User License Agreement. Therefore, we may always still show general and/or Contextualized Advertising as these are in our legitimate interest and necessary to support use of the Service.

3.3 Identifier for Vendor (“IDFV”)  [contents]

This identifier is specific to and only identifies the apps by us (i.e. the “Vendor”) that are specifically installed on your device. Fundamentally it can only track your activity within our services and apps. The IDFV only becomes considered “Personally Identifiable” when linked with other information that may reveal identity of the User (e.g. linked with the IDFA or through a user’s behavioral profile of actions/tracking across other third party apps and services not operated by H’Appile Interactive).

 

In cases of “Limited Ad Tracking”(LAT), Children users, or not opting-in to “App Tracking Transparency”(ATT) (see section 3.2 on IDFA for more details), we always respect privacy rights and our data processors limit the use of and data linked to the IDFV for the sole purpose of our Internal Operations (COPPA 16 C.F.R. § 312.5(c)(7)). In these cases, the IDFV functions just as an identifier to identify one or more of our installed apps on a specific device. The identifier can be reset by simply uninstalling all apps by us from your device. You can also learn more here https://developer.apple.com/app-store/user-privacy-and-data-use/.

4 When is Information Collected.  [contents]

H’Appile Interactive may collect Information from you through various channels, including, but not limited to, through your voluntary submission of information to H’Appile Interactive, through requests initiated by you through the Service, through the collection and analysis of information concerning your computer and browsing activities, automatically through the use of the Service, through the use of cookies, web beacons, pixel tags, analytics services detailed in section 7.1, and through other sources permitted by law. The following table describes when the collection of various data and information happens in the Service:

 

Data or Information

When Collected

IP Address

Automatically in the App at startup and/or during onboarding process.

IDFA

Automatically in the App (ONLY if your consent has been provided, not applicable to Child users, see section 3.2)

Cookies

Automatically on the Website (if required or consent is provided, see section 3.1)

IDFV, Contextual/Device Data, Crash Data/Logs, App Data/Service Usage Data, Ad/UA Performance Data

Automatically in the App and Website where applicable

Consent & Compliance Parameters

Automatically and/or through your input in the App

Customer Communication/Feedback, Email Address, Name

You providing when communicating with us for support, feedback, reviews, etc.

User Generated Content

From your inputs and/or actions of using the Service, creation of content or feature use within, associated game play and interactions, etc.

Surveys or Interest Based Responses

If presented by a third party advertisement or offer (not applicable to Child users) and your choosing to participate in.


5 How and Why we Use Information (Lawful Bases).  [contents]

The lawful bases for us processing your Information for the uses described below will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest of providing the Service and not overridden by yours.

 

By using the Website and/or the App, you authorize and acknowledge the following uses of your Information:

 

Processing Purpose/Use

Information

Lawful Basis

Advertising, Marketing:

 

Customize and/or personalize selection and display of third-party advertisements within the Website and/or App;

 

Combine your information with other information from other third party services for Personalized Advertising and Targeted Ad serving;

 

Combine your information with other information from the App or other H’Appile Interactive applications on your device for Contextual Advertising and Targeted Ad serving;

 

Advertise products and services of H’Appile Interactive;

1.    IDFA,

2.    IDFV,

3.    Contextual/Device Data,

4.    App Data/Service Usage Data,

5.    Ad/UA Performance Data,

6.    Consent & Compliance Parameters,

7.    Survey & Interest Based Responses

1) Your Consent – via opting-in to App Tracking Transparency (ATT)

 

1-5) Legitimate Interest of Advertising or Promoting the Service; consent to EULA/Terms and Privacy Policy

 

6) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection

 

7) Legitimate Interest of advertising by showing a third party offer or advertisement containing; consent to EULA/Terms and Privacy Policy; your optional choice to participate in any (not applicable to Child users)

Customer Service, Support:

 

Contact and communicate with you in response to a communication initiated by you to us;

 

Provide you with technical service and support, including updates;

 

Provide you with information concerning H’Appile Interactive’s benefits or services;

 

Understand your needs and requests;

 

To understand the authenticity, validity, or more details on the nature or source of communications and their details;

1.    Cookies (strictly-necessary)

2.    Email Address, Name

3.    Contextual/Device Data,

4.    App Data/Service Usage Data,

5.    Crash Data/Logs

6.    Consent & Compliance Parameters

7.    Customer Communications/Feedback

1-7) Our Legitimate Interest of supporting our Users and Customer Service

 

2-7) Consent via EULA/Terms; your choosing to provide in the course of Customer Service or contacting us.

 

6) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection

Analytics:

 

Aggregate/Collect certain information that does not include your Personal Information and disclose and/or reduce it for our analysis, analytics, modeling, demographic profiling and/or Targeted Advertising;

 

Provide statistical information, and include your use in the same, where applicable;

 

Plan promotions or other offers;

 

Measure service usage;

 

Develop new features;

 

Optimize the Service;

1.    IDFV,

2.    Contextual/Device Data,

3.    App Data/Service Usage Data,

4.    Ad/UA Performance Data

5.    Cookies (non-necessary)

1-5) Our Legitimate Interest of monitoring and understanding our Service; consent to EULA/Terms and Privacy Policy

 

5) You’ve opted in to/provided consent for such on our website(s) via the cookie banner.

Reliability, Technical Debugging:

 

Improve algorithms and fix bugs or problems;

 

Monitor service reliability;

1.    IDFV,

2.    Contextual/Device Data,

3.    Crash Data/Logs,

4.    App Data/Service Usage Data

1-4) Our Legitimate Interest of Service reliability/performance; consent to EULA/Terms and Privacy Policy

Provide and Sustain Service:

 

Enable your use of the Website and/or App and its associated services or features;

 

To secure the Service and protect its integrity;

 

Customize and/or tailor the Website and/or App and your user experience;

 

Facilitate your use of the Website and/or App and upgrades/replacements to the Website and/or App.

 

Store, archive, retrieve, attribute, and make copies of your user generated content or app related data/information;

 

Transmit and process your information and actions within the Website and/or App;

 

Understand your needs and requests;

1.    IP Address,

2.    IDFV,

3.    Consent & Compliance Parameters,

4.    Contextual/Device Data,

5.    App Data/Service Usage Data,

6.    User Generated Content,

7.    Cookies (strictly-necessary)

2,4-6) Legitimate Interest/necessity in order to enable and provide the App/Service and its desired feature set for you; consent to EULA/Terms and Privacy Policy,

 

7) Legitimate Interest/necessity in order to enable and provide the Website or its service for you; consent to EULA/Terms and Privacy Policy,

 

1,3) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection

 


6 When and Why We Share Information (Lawful Bases).  [contents]

Your Information may be shared with third parties in the following cases:

 

Sharing Purpose/Use

Information

Lawful Basis

Customer Service, Supporting:

 

Where sharing or disclosure of your Information is necessary and/or in the legitimate interest of supporting you through customer service communications and responses/feedback;

 

Where H’Appile Interactive has obtained your request to share and appropriate consent;

 

When we seek to understand the authenticity, validity, or more details on the nature or source of communications and their details;

1.    Cookies (strictly-necessary),

2.    Customer Communications/Feedback

3.    Email Address, Name

1-3) Legitimate Interest of providing and facilitating Customer Service

Advertising, Marketing:

 

Third party advertising personalization and tailoring ads to you

 

Where sharing or disclosure of Information is related to an advertising or social media campaign and/or for attribution of app install or purchase related to such;

1.    IDFA,

2.    IDFV,

3.    Ad/UA Performance Data,

4.    Contextual/Device Data,

5.    App Data/Service Usage Data,

6.    Consent & Compliance Parameters,

7.    Survey & Interest Based Responses

1) Your Consent – via opting-in to App Tracking Transparency (ATT)

 

2-5) Legitimate Interest of Advertising; consent to EULA/Terms and Privacy Policy,

 

6) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection

 

7) Legitimate Interest of advertising by showing a third party offer or advertisement containing; consent to EULA/Terms and Privacy Policy; your optional choice to participate in any (not applicable to Child users)

Legal or Compliance Requirements:

 

Where sharing or disclosure of Information is necessary to respond to requests by government authorities;

 

Where Information is demanded by a court order or subpoena;

 

Where sharing or disclosure of Information is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of H’Appile Interactive;

 

Where sharing or disclosure of Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty;

 

Where H’Appile Interactive is otherwise legally obligated to share Information;

1.    IP Address,

2.    IDFA,

3.    IDFV,

4.    Cookies (All),

5.    Email Address, Name,

6.    Consent & Compliance Parameters,

7.    Customer Communications/Feedback,

8.    Contextual/Device Data,

9.    Crash Data/Logs,

10.    App Data/Service Usage Data,

11.    User Generated Content,

12.    Ad/UA Performance Data

13.    Survey & Interest Based Responses

1-13) To Comply with Legal Request/Req’mt; consent to EULA/Terms and Privacy Policy.

Analytics:

 

Understand and reduce statistical information, and include your use in the same, where applicable;

 

Measure, aggregate, and monitor service usage;

1.    IDFV,

2.    Cookies (non-necessary),

3.    Customer Communications/Feedback,

4.    Contextual/Device Data,

5.    Crash Data/Logs,

6.    App Data/Service Usage Data,

7.    Ad/UA Performance Data

1,3-7) Legitimate Interest of monitoring and understanding how our Service is used; consent to EULA/Terms and Privacy Policy.

 

2) You’ve opted in to/provided consent for such on our website(s) via the cookie banner.

Provide and Sustain Service:

 

Where sharing or disclosure of Information is necessary or in our legitimate interest to provide you with the Website and/or the App (We may share your information with trusted third-parties who assist us in operating the Website and/or the App, providing the associated services, and conducting our business);

 

To secure the Service and protect its integrity;

 

Monitor service Reliability and troubleshoot crash logs effectively;

1.    IP Address,

2.    IDFV,

3.    Cookies (strictly-necessary),

4.    Consent & Compliance Parameters,

5.    Contextual/Device Data,

6.    Crash Data/Logs,

7.    App Data/Service Usage Data,

8.    User Generated Content,

9.    Ad/UA Performance Data

1-2,4-9) Legitimate Interest of providing Users our App/Service and its features; consent to EULA/Terms and Privacy Policy

 

1,3) Legitimate Interest/necessity in order to enable and provide the Website or its service for you; consent to EULA/Terms and Privacy Policy,

 

1,4) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection

Business Sale or Transfer:

 

Where the Service or H’Appile Interactive has been purchased by a third party;

1.    IP Address,

2.    IDFA,

3.    IDFV,

4.    Cookies (All),

5.    Email Address, Name,

6.    Consent & Compliance Parameters,

7.    Customer Communications/Feedback,

8.    Contextual/Device Data,

9.    Crash Data/Logs,

10.    App Data/Service Usage Data,

11.    User Generated Content,

12.    Ad/UA Performance Data

2) Your Consent – via opting-in to App Tracking Transparency (ATT)

 

1-12) Legitimate Interest or contractual fulfillment of transfer of Business/Sale,

 

1-12) Legitimate Interest of continuity of preserving Service for existing Users; consent to the EULA/this Privacy Policy.

 

1,6) Your Privacy Protection, COPPA/GDPR/CCPA/LGPD, etc. legal compliances/protection


7 Who we Share Information With, Third Parties.  [contents]

We may use third-party service providers to store/or and process your Information.

 

Disclaimer: No Liability Third-Party Services and Third-Party Links.

All third-party service providers have their own independent privacy policies governing the use of your Information and we encourage you to read those privacy policies carefully. You understand that even if H’Appile Interactive deletes your Information that it may still be available in a third-party service provider’s database. H’Appile Interactive only integrates and uses reputable third party services that we feel align with our privacy standards. We take due diligence before onboarding and using any new partners. You understand however, that H’Appile Interactive ultimately cannot assume and has no responsibility or liability for the Information collection, use, or storage activities of the third-party services providers used by H’Appile Interactive to provide you with the services associated with the Service. Third party service providers operate independently and are not owned or directly under our control.

 

H’Appile Interactive may outsource or subcontract some of our technical support, tracking and reporting functions, database management functions, and other services to third parties. We may share information from or about you with them so that they can perform their services as long as they comply our Privacy Policy and local or regional requirements such as the GDPR, CCPA, LGPD, etc. You understand and agree that H’Appile Interactive will not be held responsible for any third-party communications sent by entities that H’Appile Interactive does not own or control. You are encouraged to review any third-party privacy policies before utilizing any such third-party service.

 

H’Appile Interactive may include or offer third-party products or services on the Website and/or App and provide third-party links to the same via advertisements provided by third parties. These third-party websites have separate and independent privacy policies. H’Appile Interactive has no responsibility or liability for the content and activities of such third parties or their websites. We encourage you to read carefully the privacy policies of all such third-party websites. We seek to protect the integrity of the Website and/or App and therefore always welcome any feedback about any such third-party websites, content, or ads.

7.1 Analytics/Marketing:  [contents]

We may market the app and perform User Acquisition efforts to grow the Service and/or use Analytics in the Service. To facilitate these efforts on our behalf, we may use industry leading third party data partners including:

 

•    Apple (privacy policy here);

•    Google (privacy policy here);

•    Facebook (privacy policy here);

•    TikTok (privacy policy here);

•    JetFuel (privacy policy here);

•    AppLovin (privacy policy here);

•    AppsFlyer (privacy policy here);

 

Apple. The App is available on the Apple App Store. Apple may collect and/or we may share one or more of the following: IDFV, Contextual/Device Data, Service Usage Data, and Crash Logs with Apple for analytics purposes and/or product trend/sales reporting in our legitimate interests of providing and maintaining the Service effectively.

 

Google is a measurement and analysis partner we use in the Service to improve and understand the Service in various ways through different metrics and parameters. Various Google services may include Google Firebase, Google Analytics, Google Ads, Google Admob, etc. Through these services, Google may collect and/or we or AppsFlyer may share with Google one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data, and Crash Logs with Google for such purposes. Google uses the data collected to track and monitor the use of our Service to provide us with analytics monitoring, diagnostics, consent requirements, to measure and attribute installs related to our user acquisition/marketing efforts, and other insights in our legitimate interests of maintaining and improving the Service. Note that Google may also use the collected data to contextualize the ads served by its own advertising network within our service and/or attribute installs. You may opt-out of certain measurement parameters through your device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en.

 

Facebook is a social media platform we may partner with for advertising and have integrated with the Service. Facebook may collect analytics and marketing optimization metrics from the use of the Service. Facebook may collect and/or we or AppsFlyer may share with Facebook one or more of the following: IDFA (if authorized/available), IDFV, Contextual Device Data, App Data/Service Usage Data, Ad/UA Performance Data, with Facebook. This data is used to help attribute installations from our advertising campaigns, appropriately target audiences for our marketing using contextualized parameters, and collect analytics from the service in our legitimate interests of growing, improving, sustaining the Service.

 

TikTok is a social media and content sharing platform we may run ads on to promote the Service. When You install or use the Service from an ad shown on TikTok, TikTok may collect and/or we or AppsFlyer may share with TikTok one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data. This data is used to help attribute installations from our advertising campaigns and appropriately target audiences for our marketing efforts.

 

JetFuel is a social media advertising via influencer platform we may run ads on or contract social media influencers to promote the Service. When You install or use the Service from an ad or post shown by JetFuel or an associated influencer, JetFuel may collect and/or we or AppsFlyer may share with JetFuel one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data. This data is used to help attribute installations from our advertising campaigns and appropriately target audiences for our marketing efforts.

 

AppLovin is a mobile marketing platform. We use AppLovin as an advertising mediation and user acquisition platform partner to help grow and sustain the Service in our legitimate interest. AppLovin may collect and/or we or AppsFlyer may share with AppLovin one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, App Data/Service Usage Data, Ad/UA Performance Data, and Crash Data/Logs with AppLovin. This data is used in our legitimate interests of growing, improving, and sustaining the Service by providing insights and learning to us on the use and marketing/monetization performance of the Service.

 

AppsFlyer is a mobile marketing analytics and install/session attribution tracking platform. We use AppsFlyer to measure the performance/effectiveness of our advertising and user acquisition campaigns and to monitor/analyze our App’s audience, reach, user retention, and growth. AppsFlyer may collect and/or we may share with AppsFlyer one or more of the following: IDFA (if authorized/available), IDFV, Contextual/Device Data, Ad/UA Performance Data, and App Data/Service Usage Data with AppsFlyer. This data is used in our legitimate interests of growing, improving, and sustaining the Service in evaluating our user acquisition, analytics, and marketing efforts.

7.2 Advertising:  [contents]

We may show advertisements on the Service to help support and maintain the Service and keep it available for free. We partner with industry leading third-party advertising services and companies, which may include the following:

 

•   AdMob by Google Inc. – (Privacy Policy here);

•   Vungle – (Privacy Policy here);

•   AppLovin – (Privacy Policy here);

•   InMobi – (Privacy Policy here);

•   Fyber – (Privacy Policy here);

•   Unity – (Privacy Policy here);

•   Smaato – (Privacy Policy here);

•   Facebook – (Privacy Policy here);

•   AdColony – (Privacy Policy here);

•   Mintegral – (Privacy Policy here);

 

You can also find additional contact details for the above data processors in section 24.

 

These advertising third party providers may have access to process your data as defined here for the legitimate interest of advertising in order to protect your privacy rights, serve you best, and to contextualize and personalize (if allowed) ads for you. Examples of User data that may be processed include the following:

 

   Consent & Compliance Parameters (i.e. aforementioned in section 2.2)

   Contextual/Device Data parameters (i.e. aforementioned in section 2.3)

   Ad/UA Performance Data parameters (i.e. aforementioned in section 2.7)

   Survey or Interest Based Responses (i.e. aforementioned in section 2.1)

   Service Usage Data (i.e. aforementioned in section 2.5), if available for a specific network’s integration (e.g. Google Analytics in the case of Google AdMob, etc.)

   The ID for Vendor (IDFV) for the App instance on your device (i.e. aforementioned in section 3.3)

   The Advertising Identifier (IDFA) of your device (if tracking is allowed for the App as discussed in 3.2)

7.3 Database:  [contents]

Firebase by Google Inc. – We may use third-party service provider Firebase to store and maintain content and data for our Service, including IDFV, User Generated Content, App Data/Service Usage Data, Contextual/Device Data, and Consent & Compliance Parameters. The Firebase database is a secured Public Database hosted by Google that we own and control.

 

We encourage you to review the Firebase privacy and security standards https://firebase.google.com/support/privacy.

 

iCloud by Apple Inc. – We may use the Apple iCloud to store and maintain content and data for our Service, including User Generated Content, and App Data/Service Usage Data. This data may be stored associated with your Apple ID in a Private Database which is owned by you and linked with your Apple ID credentials. Under certain situations you may have the ability and choice to share data or records from your Private Database with other friends, family, etc in a Shared Database. When you engage in live or linked play with others, etc, we may also sync data to a secured Public Database in the iCloud, maintained by us, in order to enable and facilitate such shared game play interactions with others, etc.

 

Keychain by Apple Inc. – We may use the Keychain secure storage on your device to store and protect sensitive game data such as in-app purchases and in-app currency balances, etc. also possibly including User Generated Content, App Data/Service Usage Data, and Consent & Compliance Parameters. If your device is configured to allow, Keychain data may be sync’d across your devices and linked to your iCloud account with your Apple ID.

 

We encourage you to review all the Apple privacy and security standards https://www.apple.com/legal/privacy/en-ww/.

7.4 Payments:  [contents]

Apple In-App Payments/Purchases – We work with Apple as a payment processor for in-app purchases. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.

7.5 Authentication:  [contents]

We may utilize third party services including Apple, Facebook, Google to allow users to create profiles and save, manage user profiles and accounts. Use of these login services is completely optional and voluntary. We do not own or manage any OAuth protocol or encryption used in these services, and have no access to your password. We cannot be responsible for 3rd party loss of and/or invalidation/corruption of your login/credentials.

 

If account based authentication is offered, you may delete your profile and associated authentication credentials anytime you choose while logged in within the settings menu of the application.

 

In cases where the Service doesn’t use account based authentication, we may simply use anonymous authentication methods to still allow secure access to backend databases and services, and in order to limit access to only those from validly authenticated App instances.

7.6 Customer Service, Communication, Website:  [contents]

We may use third party services to host our Website, provide information on our Service, manage customer service and support Users, verify the authenticity and validity of communications or their details, etc. These services may include:

 

Intercom is a customer communications platform we use to support users and may receive feedback from you on via integrated into our website. Intercom may collect/use an anonymous Persistent Identifier cookie to enable us to communicate with you via your request. This may allow our responses to you to show up in a conversation feed you have initiated with us on our website. Most importantly, we cannot contact you directly with this outside the context of our website, as this identifier is anonymous to any real identity. We actually prefer and will usually suggest you communicate with us via this tool as it enables us to communicate with you efficiently, anonymously, and in our opinion is more elegant and robust for privacy than standalone email. In the course of such, intercom may also collect/process any Customer Communications/Feedback shared with us through such channels, Contextual/Device Data, and Service Usage on our Website. You can find Intercom’s privacy policy here https://www.intercom.com/legal/privacy.

 

WordPress by Automattic is a website creation and management platform. We rely on WordPress as our domain name server(DNS) provider, for website creation, hosting, etc. WordPress may have access to strictly-necessary Cookies for the facilitation of operating our Website and/or enabling your use of such and its feature set. You can find WordPress’s privacy policy here https://wordpress.org/about/privacy/ and https://automattic.com/privacy/.

 

Google though their Gmail product is an email provider and service that we receive email on. We may also use Google search services to validate or substantiate the authenticity and nature of certain communications, their details or sources, etc. in our legitimate business interest to provide context for our communications with you. If you communicate to us via email, Google may have access to and we may share your email address and your name (if associated with your email or provided) for such purposes. You can find Google’s privacy policy here https://policies.google.com/privacy?hl=en.

 

Mailgun by Pathwire is a mail forwarding and smtp routing service we use to manage our email address accounts. Mailgun may have access to your email address and your name (if associated with your email or provided), solely for the purposes for facilitating your communication to us, if you initiate communications with us via email. You can find Mailgun’s privacy policy here https://www.mailgun.com/privacy-policy/.

7.7 Compliance Management/Consent:  [contents]

We may use third party services to aid in management of consent and compliance. These services may includes:

 

IPData in the App in order to process your IP Address to infer your regional location of use (e.g. Country, State) and comply with local regulatory requirements (e.g. Privacy protection laws like the GDPR in the EEA, LGPD in Brazil, etc), and/or use limitations, etc. We may share with IPData your IP Address to facilitate this processing. You can find IPData’s privacy policy here https://ipdata.co/privacy-policy.html.

 

Cookies Consent Plugin by WebToffee on our website(s) which enables us to communicate to you that Cookies may be present on such sites, their purposes/categories, the ability to configure opt-in and opt-out preferences accordingly. WebToffee may process/access “strictly-necessary” cookies and your IP Address to manage consent and opt-in/out preferences for Cookies on our site. You can find WebToffee’s privacy policy here https://www.webtoffee.com/privacy-policy/.

 

ConsentManager AB in the app which allows us to provide choices and opt-in/out granularity for users advertising network preferences. This enables us to follow best practices in the evolving mobile advertising space and respect your privacy choices with industry leading technology and consent frameworks. To enable this, we may share with and ConsentManager AB may use and collect your IP Address and Contextual/Device Data so they may communicate your preferences to the appropriate advertisers and networks to respect your privacy choices.https://www.consentmanager.net/datenschutz/.

 

Cookies Consent Management by CookieYes on our website(s) which enables us to communicate to you that Cookies may be present on such sites and their purposes/categories, and the ability to configure opt-in and opt-out preferences accordingly. CookieYes may process/access “strictly-necessary” cookies and your IP Address to manage consent and opt-in/out preferences for Cookies on our site. You can find CookieYes’s privacy policy here https://www.cookieyes.com/privacy-policy/.

8 Data Aggregation and Service Statistics.  [contents]

Information or data points/statistics obtained from your use of the Service, along with that of other users, may be combined and processed into aggregated Service metrics. These metrics are always stripped of any personal identifiers, anonymized, and never include any Personal Information. Examples of such may include, but are not limited to, derived statistics such as organic vs. inorganic install breakdowns, most successful ad campaigns or product placements in the app, revenue channel splits, retention cohorts, DAU counts, country-wide/large geo regional breakdown of such metrics, etc. These “big picture” or “aggregated” statistics may be shared and used in any way we deem fit for the Service or in our interest.

9 Information Transfer and Storage.  [contents]

Through your use of the Service, you consent to the processing and storage of your Information and Personal Data. You understand that your Information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction. If you are located outside the United States and choose to provide Information to us, please note that we may transfer your Information to the United States and process it here, and that we may store portions of your Information in the United States.

 

We will retain your Personal Data for only as long as is necessary for the purposes set out in this Privacy Policy, to provide you the Service, and/or to the extent necessary to comply with our legal obligations or liability (e.g. if we are required to retain your data to comply with applicable laws, maintain consent logs), resolve disputes, and enforce our legal agreements and policies. If you would like to request specific Personal Data deleted or removed, please contact us via details provided in Section 20. Note, even if H’Appile Interactive deletes your Information from our servers, it may still be available in a third-party service provider’s database. You should consult with those third-parties in the event you would like Information deleted therefrom.

 

By design, we limit the non-necessary linking of personal and non-Personal Data sets on our servers or in any Public Databases maintained by us. We do this intentionally because it helps keep your privacy robust, introduces anonymity, and is best practice. You understand and agree therefore that non-Personal and/or anonymized Information not linked to your identity may be stored indefinitely.

 

Note: Any data the service generates or stores on your device locally and/or in a Private Database (e.g. your iCloud) is always under your own control through your device’s settings and/or AppleID/iCloud account management.

10 Information Security.  [contents]

We use standard technology to store and help prevent against the unauthorized disclosure of your Information. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is 100% completely safe. Accordingly, you provide all such information at your own risk.

 

For personal and/or sensitive data transmission to/from the app and our servers or any third party apis, we use commercial and industry wide standard encryption protocols such as https calls (i.e. http using SSL or TLS) to protect your data. Further, we always design database schema and security rules with careful privacy considerations. We employ security rules on our Firebase database to maximize data privacy and security. Administrative access to any database or Service/User level data is strictly limited, and password protected with multiple layers of authentication (e.g. 2FA). Additionally, we may take added steps for data structures that are proprietary, personal, or sensitive in nature for when stored at rest, e.g. applying standard encryption algorithms, storing in the iOS Keychain, etc. in efforts to maintain and protect the App’s data integrity, user settings, and intellectual property.

 

In the unforeseen event of breach or database integrity being compromised, and we become aware of such that Information is at risk or has been exposed, we will take appropriate steps to notify all impacted Users.

11 Payments.  [contents]

We may provide paid products and/or services via the Website and App. We may use third-party payment processors for payment processing in the Service.

 

We will never store or collect your payment information directly. We will also never contact you regarding such details or ask for them. If you have provided this to our third-party payment processors outside of the Service, then this information is stored directly by our third-party payment processors whose use of your Information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

12 Your Choices.  [contents]

You have choices about how we may use data you share and/or what information you choose to share. You can find data sharing settings in the app at anytime under the “foot print” logo page at the bottom via the “data sharing” button. You can also disable, opt-in, or opt-out accordingly to certain tracking technologies specifically as described earlier in section 3 of this policy.

13 EU Users’ Rights Under the GDPR.  [contents]

The GDPR provides Users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Website and/or the App. Accordingly, H’Appile Interactive recognizes and will comply with the GDPR and those rights, except as limited by applicable law. The rights under the GDPR include but may not be limited to:

 

Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint.

 

Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.

 

Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfillment of your request may prevent you from using our services and may result in closing your account.

 

Right to Restriction of Processing or consequences of: This includes the right to request restriction of how and why your Personal Data is used or processed by us. Along with what impacts such request may have on features or functionality of said service(s).

 

Right to Data Portability: This includes the right to receive your Personal Data in a structured, readable format and the right to have your Personal Data transferred.

 

Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.

 

Right to not be Subject to Automated Decision-Making: This includes the right to not be subject, without your consent and notification, to a decision based solely on automated processing of your Personal Data, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.

 

To exercise any of these rights under the GDPR or request more information, you may submit a request to our Data Protection Officer(DPO) or EU/UK based Privacy Representative (Prighter) per details in section 23.

14 Brazil Users’ Rights Under the LGPD.  [contents]

The LGPD provides Users located in Brazil and under its protection certain rights with respect to their Personal Data collected by us on the Website and/or the App. Accordingly, H’Appile Interactive recognizes and will comply with the LGPD and those rights, except as limited by applicable law. The rights under the LGPD include but may not be limited to:

 

Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint.

 

Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.

 

Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfillment of your request may prevent you from using our services and may result in closing your account.

 

Right to Restriction of Processing or consequences of: This includes the right to request restriction of how and why your Personal Data is used or processed by us. Along with what impacts such request may have on features or functionality of said service(s).

 

Right to Data Portability: This includes the right to receive your Personal Data in a structured, readable format and the right to have your Personal Data transferred.

 

Right to Opt-out/Revoke Consent, Limited Preconditions: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific, historical research, statistical purposes, or beyond what is strictly necessary for the Service. Additionally, we will not pre-condition your use if you choose to limit or opt-out of Data Sharing as applicable in the “Data Sharing” settings page of the game and/or during onboarding.

 

To exercise any of these rights under the LGPD or request more information, you may submit a request to our Data Protection Officer(DPO) per details in section 23.

15 California Users’ Rights under the CCPA.  [contents]

Under the CCPA, California Users have, but may not be limited to, the following rights:

 

Right to Know About Personal Information Collected, Disclosed, or Sold: You have the right to request that H’Appile Interactive disclose what Personal Information of yours it has collected, used, disclosed, and sold over the past 12 months.

 

Right to Have Personal Information Deleted: You have the right to request that H’Appile Interactive delete any of your Personal Information that we collected from you.

 

Right to Opt-Out of the Sale of Personal Information: In the literal sense of a “sale”, we will never actually directly sell any of your Personal Information. However, as we do use advertising in our service, we may share your Personal Information to better serve these ads and personalize them for you (if authorized/allowed as discussed previously in section 3.2). Under some definitions this could be interpreted as a “sale” since we use these ads to help monetize and support the Service. You have the right to opt out of us disclosing and/or selling any of your Personal Information. You can opt-out via a button at the bottom of the “foot print” settings page in the App labeled “Do Not Sell My Personal Information”. If you choose to opt out, we will also limit Personalized Advertising and sharing of your device’s IDFA to protect your privacy.

 

Right to Non-Discrimination: H’Appile Interactive shall not discriminate against California Users for exercising their rights under the CCPA.

 

To exercise your rights under the CCPA, you may submit a request to H’Appile Interactive by contacting H’Appile Interactive at privacy@happileinteractive.com.

 

Under California’s “Shine the Light Law”, California residents have the right to receive information that identifies any third-party companies or individuals that H’Appile Interactive has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting H’Appile Interactive at privacy@happileinteractive.com and at the address below in section 23.

16 Our Policy on DNT Signals under the California Protection Act (CalOPPA).  [contents]

We do not support Do Not Track (“DNT”) signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

17 Purchase or sale of the App and/or Other Assets.  [contents]

H’Appile Interactive may purchase other businesses or sell components of its business, including, but not limited to, the Website and/or App. In the event H’Appile Interactive purchases another business or sells any component of its business, your Information will continue to be used consistent with the terms of this Privacy Policy, unless you are otherwise notified by us or a new Data Controller.

18 How to stop us from collecting your Personal Information.  [contents]

You can stop us from collecting Personal Information in the App by one or more of the following:

 

(1) Configuring your device settings to not allow App Tracking and/or the use of the IDFA in the App (section 3.2 of the policy).

(2) If you are a California Resident, by requesting “Do Not Sell My Personal Information” by tapping on the button described in section 15 and following any instructions therefrom.

(3) Stopping use of the Service and removing the App from your Device(s).

 

and/or on our Website by:

 

(1) Turning off and clearing non-necessary cookies in your browser settings (section 3.1 of this policy).

 

For more details or help on any of the above, please contact us.

19 How to request a copy of your Personal Information.  [contents]

You can request a summary and copy of your Personal Information from us as follow:

 

(1) In the app from your widget baby’s home page tap on the “foot print” logo in the upper right corner.

(2) At the bottom of the page tap on “my_device_identifiers“, then scroll to the bottom of the popup, and please take a screenshot of this popup which contains the identifier(s) we need to process your request.

(3) Please attach this screenshot, and any prior email address(es) you’ve used to correspond to us in an email to privacy@happileinteractive.com with the subject “DSDR Copy – WidgetBaby”. Note: Please be sure to send the email from where you’d like us to send the response or indicate otherwise in your request.

(4) We will reply back within 15-30 days (or otherwise as required by law) with a human readable copy of all your Personal Data on file in our systems and servers for the identifier(s) or email you provided.

(5) For our third party partners, please refer to their privacy policies (section 7 of this Policy) to request similar and understand their processes for obtaining a copy of Personal Information.

20 How to request we delete your Personal Information.  [contents]

Note, requesting we delete your Personal Information may impact functionality of the Service and cause loss of data previously associated with your use. All requests are performed on a single basis and do not automatically recur.

 

You can request we delete your Personal Information from our servers as follows:

 

(1) In the app from your widget baby’s home page tap on the “foot print” logo in the upper right corner.

(2) At the bottom of the page tap on “my_device_identifiers“, then scroll to the bottom of the popup, and please take a screenshot of this popup which contains the identifier(s) we need to process your request.

(3) Please attach this screenshot, and any prior email address(es) you’ve used to correspond with us or in the Service in an email to privacy@happileinteractive.com with the subject “DSDR Delete – WidgetBaby”.

(4) We will reply asking for confirmation that you’d like all Personal Data deleted. Please reply “Yes – I agree” or “Cancel”. If we do not receive a timely response, please note we may still proceed with your request based on an obligation to respect your prior communication in step 3 above.

(5) If you don’t want any further Personal Information collected after this request, please stop use and remove the App from your device. Note any continued use of the Service may result in additional data collection.

(6) We will remove all your Personal data related to the supplied information (3) from our servers within 15-30 days (or otherwise as required by law) and we will send you a confirmation that we have done so. We will also make request(s) to all third party partners that they do the same for the information you supply to us in (3).

(7) For our third party partners, you may also refer to their privacy policies specifically (section 7 of this Policy) for a full understanding of their data retention practices.

21 Your Representations, Right to Update.  [contents]

Among other factors, we may rely upon information you provide to configure and make the Service available for you. When using the Website and/or App, you are obligated to inform H’Appile Interactive of any material changes to your Consent and Compliance Parameters (as detailed in section 2.2). You understand this is necessary for use of the Service and may be actively relied upon under this policy and/or our End User License Agreement/Terms of Service for you. For instance, the items such as your age and state/country of residence may be necessary and being relied upon to protect your privacy rights and configure or update the App properly for you. Unless otherwise updated from you in writing to us, or until we learn/gain knowledge otherwise of, we will reserve the right to rely on any previously provided or obtained information and your representations as true and accurate.

 

If you need to make a request to correct or update any information you’ve provided previously, please find instructions here.

22 Children & Child Online Privacy Protection (e.g. COPPA, GDPR-K).  [contents]

The Website and App are intended for a general audience, and are not primarily directed to Children. However, H’Appile Interactive also recognizes that in some cases the App may attract a mixed audience of users and age demographics. We therefore take additional steps to determine ages of users (via age gate) and configure the Service appropriately to protect Children’s privacy when we gain knowledge of a Child user (via age gate). For clarity and emphasis, these steps are detailed at the beginning of this document in the outlined block titled “Children’s Privacy”. Note for protection we do not allow the age gate to be bypassed and a user cannot go back and change their age once entered (the only exception to this is via the completion of parental consent form and signature in the procedure outlined in section 21 for exercising a right of updating/correcting information).

 

H’Appile Interactive does not knowingly or intentionally collect Personal Information from children under the age of 13 (or the legal age of able to consent to Personal Data processing in their jurisdiction if greater, e.g. 16 in parts of the EEA), unless one or more of the following is met:

 

1.  The subject falls under COPPA and Personal Information is limited to the use of a Persistent Identifier for purposes of supporting “Internal Operations” as limited to and defined here in section J5, and/or

2.  Guardian or parental consent has been given.

2.  The Subject falls under GDPR, LGPD, or similar and the collection/processing falls under the basis of Legitimate Interest.

 

If we ever gain knowledge Personal Information has been collected somehow otherwise or inadvertently from a Child, we will promptly remove all information immediately.

 

For any direct communications with us (i.e. support, feedback, etc.) we ask parents to please help with and facilitate. However, if we ever gain knowledge any communication is specifically from a Child we always promptly delete the communication and all associated contents after one-time contact with accordance to COPPA 16 C.F.R. § 312.5(c)(3).

22.1 Parents’ Rights & Choices.  [contents]

As always, if you are a parent or guardian and you are concerned that your child has inappropriately provided us Personal Information, please contact us so we may remove it and address any concerns.

 

For any Personal Information we do collect, we always want parents to have choices and control over how information is shared or used. We provide data sharing settings that may be adjusted in the app under the settings “foot print” page at any time. You may also request we stop collection of, provide access to, correct, and/or delete data as described in sections 18-21.

23 Contact and Notices.  [contents]

All questions and concerns regarding this Privacy Policy may be submitted to H’Appile Interactive at:

 

Data Protection Officer

H’Appile Interactive, LLC

2711 Legion Rd

PO Box 8184

Erie,  PA  16506

privacy@happileinteractive.com

23.1 Representation for Data Subjects in the EU and the UK  [contents]

We value your privacy and your rights as a Data Subject and have therefore appointed Prighter as our privacy representative and your point of contact.

 

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your Data Subject rights, please visit https://prighter.com/q/14912091663

 

Kriegerstraße 44

30161 Hannover

Germany

 

UK Office 20 Mortlake Mortlake High Street

London, SW14 8JN

UNITED KINGDOM

24 Third Party Data Processor Contacts.  [contents]

Google

1600 Amphitheatre Parkway

Mountain View, CA 94043

https://support.google.com/policies/contact/general_privacy_form

 

Apple

One Apple Park Way

Cupertino, CA 95014

https://www.apple.com/privacy/contact/

 

AppLovin

1100 Page Mill Road

Palo Alto, CA 94304

info@applovin.com

 

Vungle

1255 Battery Street Suite 500

San Francisco, CA 94111

https://vungle.com/contact-us/

 

InMobi

Suite 420, 475 Brannan Street

San Francisco, CA 94107

https://www.inmobi.com/company/contact/

 

Fyber

90 New Montgomery Street, Suite 500

San Francisco, CA 94105

https://www.fyber.com/about-us/

 

Unity

240 Page St

San Francisco, CA 94102

https://unity.com/help

 

Smaato

240 Stockton St, 9th Floor

San Francisco, CA 94108

https://www.smaato.com/contact/

 

AdColony

41 Madison Ave 30th Floor

New York, NY 10010

https://www.adcolony.com/consumer-privacy/

 

Facebook

1 Hacker Way

Menlo Park, CA

https://www.facebook.com/help/

 

TikTok

5800 Bristol Parkway, Suite 100

Culver City, CA 90230

https://www.tiktok.com/legal/report/privacy

 

JetFuel

690 Pennsylvania Ave, Unit 115

San Francisco, CA 94017

dataprotection@reallabs.io

 

Mintegral

44 Montgomery Street,

San Francisco,

CA, USA 94104

https://www.mintegral.com/en/privacy/

 

AppsFlyer

100 1st Street, 25th floor

San Francisco, California 94105

https://www.appsflyer.com/contact/

 

WordPress, Jetpack

by Automattic Inc.

60 29th Street #343

San Francisco, CA 94110

https://wordpress.com/help/contact

 

Intercom

55 2nd Street, 4th Fl

San Francisco, CA 94105

https://www.intercom.com/legal/privacy

 

CookieYes

CookieYes Limited

3 Warren Yard Warren Park

Wolverton Mill, Milton Keynes, MK12 5NW

United Kingdom

https://www.cookieyes.com/privacy-policy/

 

WebToffee

Mozilor Limited

10 Paxton Crescent

Shenley Lodge, Milton Keynes, MK5 7PY

United Kingdom

https://www.webtoffee.com/privacy-policy/

 

consentmanager AB

Håltegelvägen 1b

72348 Västerås

Sweden

https://www.consentmanager.net/contact/

 

IPData LLC

2035 Sunset Lake Road Suite B-2

Newark, Delaware

support@ipdata.co

 

Mailgun

San Antonio, TX 78205

112 E Pecan St #1135

https://www.mailgun.com/contact/support