HUMMINGBIRD GAMES PRIVACY POLICY

Last Updated: September 12, 2024

This Privacy Policy explains how HUMMINGBIRD GAMES PTE.LTD. (referred to as "we" or "us" here) collects, stores, uses, or otherwise handles your personal information when you use our Services (referred to as "you"). It also details your rights regarding our processing of your personal data.

In this document, "Services" includes our Games, Websites, and any related services or properties we control. "Games" refers to our various gaming apps and products. "Websites" relates to the web pages and online platforms we oversee. When we refer to "your data," we mean personal information that identifies or can identify you.

This Privacy Policy applies to all our Services unless a specific Game or Service has its own distinct Privacy Policy, which will then take precedence. Additionally, our Services may link to or provide access to third-party properties. This Privacy Policy does not cover these third-party sites, and their operators may collect and use your data according to their own policies.

We encourage you to read this Privacy Policy thoroughly before using or accessing our Services to understand how and why we handle your data. While some sections offer brief summaries for convenience, a full read of the Privacy Policy will provide a more complete understanding. We also suggest reviewing our Terms of Service, which govern your use of our Services.

I Data controller

The term "data controller" refers to an entity that decides how and why personal data is processed. In relation to the activities described in this Privacy Policy, HUMMINGBIRD GAMES PTE.LTD., located at 3 TEMASEK AVENUE, #27-02, CENTENNIAL TOWER, SINGAPORE 039190, acts as the data controller.

While operating our Services, we may work with partners to whom we may share your data. Some of these partners function as separate data controllers, determining their own purposes and methods for processing your data. For more information about these partners and their data handling practices, please refer to section VII of this Privacy Policy.

II Contact information

For any questions about this Privacy Policy, please contact us by email.

We have designated a Data Protection Officer (DPO) to oversee data protection matters. If you have any concerns or inquiries regarding the management of your data, you can reach out to our DPO via email.

III Permission

To ensure our Games and Services operate smoothly, we may request the following permissions:

(1) Location access

(2) Internet access

(3) Read and write to external storage

(4) Vibration control

(5) Access to Google Play Services

(6) Wi-Fi status access

(7) Network status access

(8) Bluetooth status access

(9) Reading system logs

(10) Push notifications

You can understand the reasons for these permissions and how we use them by thoroughly reviewing this Privacy Policy.

Please note that some of these permissions are not essential for the core functionality of our Games or Services. You have the option to deny certain permissions by adjusting your phone's settings:

(1) Vibration control

(2) Bluetooth status access

(3) Push notifications

IV Data Process

We use your data for various purposes in connection with our Services. Here's a brief overview:

(1)Service Functionality: We process your data to deliver and enhance our Services, such as saving your progress in our Games.

(2)Support and Maintenance: Your data helps us manage accounts, provide support, and improve our Services by addressing issues or moderating our Games.

(3)Advertising: We may display advertisements within our Games or promote our Services on third-party platforms, using your data to tailor these ads to your interests.

(4)Compliance and Security: As allowed by law, we might use your data for fraud prevention, auditing, or other compliance-related activities.

In more detail, we may process your data for the following specific purposes:

(1)Account Management: Creating and managing your account in our Games or Services.

(2)Gameplay and Service Use: Enabling your participation in our Games or Services.

(3)Service Customization: Providing the right version of our Games or Services, such as language settings.

(4)User Interaction: Facilitating communication with other users, including managing chat, communities, or forums.

(5)Service Communication: Sending you updates about our Services, including technical notices and security alerts.

(6)Transaction Processing: Handling and completing your purchases or other transactions within our Services.

For the purpose of enhancing our Services, we may also process your data to:

(1)Service Operation: Maintain and ensure the security and proper functioning of our Services.

(2)Issue Resolution: Troubleshoot and fix bugs or errors, and analyze usage patterns to gain insights.

(3)Data Aggregation: Create and use non-identifiable aggregate data.

(4)Research and Improvement: Conduct surveys or research to improve our Services or develop new ones.

To improve your experience with our Games, we may process your data for:

(1)Personalization: Tailoring your gameplay experience and offering rewards based on your activity.

(2)Multi-Device Support: Enabling gameplay across different devices where applicable.

(3)Social Features: Providing features such as competitions or events and managing support requests.

(4)Service Communication: Sending relevant service-related communications.

To ensure a safe and fair environment, or as required by law, we may process your data to:

(1)Age-Appropriate Content: Ensure that content and features are suitable for your age.

(2)Monitoring and Enforcement: Moderate use of our Games, including message monitoring, and enforce our Terms of Service and Code of Conduct.

For promotional and advertising purposes, we (and our partners) may use your data to:

(1)Track Ad Performance: Monitor installations and effectiveness of our ads.

(2)Optimize Advertising: Analyze and improve ad relevance and adjust ad display frequency based on your activity.

(3)Promotional Communication: Send information about offers, events, or other news related to our Services.

In some Games, to provide relevant ads and support our Services, we may:

(1)Display Ads: Show ads from us or our partners.

(2)Ad Relevance: Track and personalize ads based on your activity.

For operational security, we may process your data to:

(1)Fraud Prevention: Detect and prevent fraudulent or unauthorized activities.

(2)Compliance Audits: Ensure our operations adhere to regulations.

(3)Legal Protection: Protect our legal rights within the bounds of the law.

With your consent, we may process your data for:

(1)Partner Sharing: Sharing with advertising partners as per their privacy policies.

(2)Communications: Sending newsletters or similar updates if you have subscribed.

(3)Additional Consent-Based Purposes: Other purposes specified when we seek your consent.

We may also process your data as necessary to:

(1)Meet Legal Obligations: Comply with legal requirements.

(2)Protect Interests: Safeguard vital interests or those of others.

(3)Compatible Purposes: For other purposes that are compatible with those outlined above.

We do not use your data for automated decisions that have a significant impact on you, such as decisions made solely by an automated system without human intervention.

1 Advertising

Advertising is crucial for funding our Services and allowing us to offer our Games for free. Within some of our Games, you may encounter both our ads and those from third parties. Additionally, we may promote our Games on external platforms such as websites or apps. In these cases, we and our advertising partners generally use pseudonymous identifiers linked to your device to deliver relevant ads, assess ad performance, and for related activities. By using our Services, you agree to share your data with our advertising partners for targeted advertising and similar purposes, as allowed by applicable laws. You can manage your advertising preferences by contacting our DPO via email.

Mobile advertising utilizes various online identifiers, primarily Advertising IDs, along with IP addresses and other unique markers. An "Advertising ID" is a unique alphanumeric code typically assigned by a device or its operating system. This ID remains consistent across different applications on the same device, irrespective of the app publisher. On iOS devices, it is known as the Identifier for Advertisers (IDFA), while on Android devices, it is called the Google Advertising Identifier (GAID). Other operating systems and devices may have similar identifiers.

Advertising IDs are used for interest-based advertising and related purposes, helping to maintain a pseudonymous identity across various apps and platforms. You have control over your Advertising ID through your device's privacy settings, where you can often reset or limit its use. For instance, on iOS, you can choose to "not allow apps to request tracking," and on Android, you can "opt out of interest-based ads." These settings are device-specific and need to be adjusted individually. Additionally, some of our games may offer options within their settings to manage ad-related data usage.

It's important to understand that resetting or limiting your Advertising ID will not stop you from seeing ads but may result in less personalized advertising.

If you view ads in our Games, we may share your Advertising ID and IP address, along with game and device information, with our advertising partners. These partners might also gather data directly from our games using technologies like software development kits (SDKs). This data can be used to manage ad frequency, tailor ads to your interests, and other related purposes based on your previous activity linked to your Advertising ID.

When our ads appear outside our Services (such as on third-party sites or apps), the ad network might use your past activity associated with your Advertising ID to gauge your potential interest in our offerings. They may leverage your data to regulate ad frequency, notify previous users about new content or updates, or avoid showing ads to current players of the advertised game.

Additionally, ad networks might employ Advertising IDs or similar identifiers to target users who are likely interested in our services based on similarities with existing users.

Advertising IDs or other identifiers are also used for measuring ad performance, which involves tracking metrics like ad views, clicks, or installs. This measurement data is often collected by various parties involved in ad delivery (including us and our advertising partners) through technologies such as conversion pixels embedded in ads. This data helps in measuring ad effectiveness, detecting fraud, and managing financial transactions related to ad delivery.

2 Cookies

Like many other websites, our Websites may use cookies or similar technologies such as local shared objects or web beacons.

A "cookie" is a small data file placed on your device by your browser at the request of a website. Cookies can be from the site you are visiting ("first-party cookies") or from third parties who provide content, functionality, or services for that site, such as analytics or advertising ("third-party cookies"). Generally, cookies are used to recognize or "remember" your device, enabling website functionality, performance improvements, audience measurement, and preference storage.

When you visit our Websites, you might be presented with options regarding cookies. Some cookies are necessary for the essential operation of the Websites and will be used and stored on your device regardless of your choices about other cookies. You can control cookie usage through your browser or device settings, including disabling some or all cookies or setting up alerts when cookies are being placed. However, disabling cookies might affect your ability to fully use the Services.

V Types of Data Collected

When you interact with our Services, we may gather information you provide directly or through your use of our Services. This includes information submitted when setting up an account, sending messages within our Games, or reaching out for support. We also collect data automatically about your usage and the device you use, including identifiers like an Advertising ID. Additionally, if you encounter our ads outside of our Services, we may gather data on your interactions with those ads. We may use this data to deduce further insights, such as your content preferences.

Here is a summary of the types of data we may collect and process:

(1)Personal Information: Includes details like your name, email address, and contact information that you provide when creating an account or subscribing to our communications.

(2)Age or Date of Birth: Information related to your age or birthdate.

(3)Online Identifiers: Includes identifiers such as your in-game username, IP address, account-specific identifiers we assign, and device-related identifiers like your Advertising ID.

(4)Device Information: Technical details about the device used to access our Games or Services, including its type, model, manufacturer, operating system, language, display specifications, processor, and memory.

(5)General Location: Inferred from your IP address, such as your country, state, or city.

(6)Usage Data: Information about how you use our Services, including game progress, purchases, website visits, and interactions with ads.

(7)Ad Interactions: Data about your interactions with our ads outside of our Services, including any referrals to our Games or Services on external platforms.

(8)Reports: Information from crash logs or bug reports encountered while using our Services.

(9)Activity Insights: Insights based on your activity within our Services, such as content preferences.

(10)Communications: Messages or interactions sent through our Services or related communities on third-party platforms.

(11)Third-Party Data: Information from third-party accounts linked to our Services, such as social media accounts for cross-device gameplay or social features.

(12)Transaction Data: Details from purchases made within our Games or Services, processed through third-party payment providers (we do not receive credit card or payment method details).

(13)Content Preferences: Preferences or subscription-related details if you have opted to receive communications from us.

(14)Feedback: Information provided through surveys or research activities, including your background or gaming experience.

(15)Data Preferences: Your preferences regarding data collection, including any consents granted or withdrawn.

(16)Additional Information: With your consent, additional information as specified at the time of consent, such as GPS location for location-based features.

We do not seek to collect or process sensitive data such as genetic, biometric, or health information, racial or ethnic origin, sexual orientation, political views, religious beliefs, or criminal history. Please avoid providing such sensitive information through our Services.

VI Data Source

We primarily gather information directly from you or your device while you use our Services. Additionally, we may obtain data from other sources, such as third-party login services you use, companies processing transactions in our Games, or advertising partners who help deliver and measure ads outside of our Services.

Here's how we collect data about you from various sources:

(1)Direct Input: Data you provide to us directly, such as when registering an account, subscribing to communications, requesting support, or participating in surveys.

(2)Automatic Collection: Data collected automatically from you and/or your device during the use of our Services or interaction with our ads, including those on third-party sites, using cookies, similar technologies, or SDKs.

(3)Distribution and Publishing Partners: Information from companies involved in distributing or publishing our Games, which may include HUMMINGBIRD GAMES PTE.LTD. and other third parties like platform operators.

(4)Advertising Partners: Data from partners involved in delivering and measuring ads, if you interact with ads either within our Games or on external platforms.

(5)Third-Party Account Providers: Information from third-party accounts if you choose to link these accounts with our Services.

(6)Community Groups: Data from official community groups related to our Games on third-party platforms or from the platform providers themselves.

(7)Payment Service Providers: Data from payment processors when you make purchases within our Games or Services.

(8)Additional Sources: With your consent, data from other sources as specified when we request your consent.

Providing your data is not mandatory, but not doing so may limit our ability to deliver certain Services or features. As you use our Services, we collect data according to the purposes described in this policy, based on the Services you access and your preferences. You have control over how much data we process. For example, you can choose not to link third-party accounts with our Games, adjust privacy settings in those services, manage advertising preferences in our Games, reset or manage your Advertising ID via device settings, or change browser settings to block cookies. However, please be aware that our Websites may not respond to "Do Not Track" requests in HTTP headers.

VII Share Data

We do not directly transfer your data from your device. However, since our Services integrate third-party SDKs, your data may be transferred to or processed in countries other than your own when you use our Services. Below are the details regarding this:

Facebook SDK

We use the Facebook SDK to facilitate login procedures in our Games. When you log in with Facebook, the following information may be shared with Facebook:

(1)Activities or content you post from our Games

(2)Your interactions within our Games

(3)Information about your device

Language settings in our GamesYou can manage your information through Facebook's settings: https://www.facebook.com/help/1727608884153160/app-visibility-and-privacy.

Bugly SDK

We use Bugly SDK to enhance the user experience in our Games. The SDK may collect the following data to troubleshoot and improve app stability:

(1)Cell phone model

(2)Phone brand

(3)Android version and API level

(4)Vendor system version

(5)CPU architecture

(6)Root status

(7)Disk, SD card, and memory space usage

(8)Network type

(9)Process name and PID

Data is transmitted securely via encryption. For more details or to manage this information, contact our DPO or Bugly SDK's developer.

Google Pay

PrivacyNotice:https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en

We have integrated Google Pay for in-game purchases. Google may collect transaction details including date, amount, merchant information, and payment method details. Manage your information via: https://payments.google.com/s/?page%253DprivacySettings%2523privacySettings.

AppsFlyer

We use AppsFlyer for statistical analysis, which may involve collecting and anonymizing your Advertising ID. You can request data deletion by contacting our DPO or directly through AppsFlyer.

AMP

Privacy Policy: https://images.prismic.io/openjsf/ba00b254-685f-4e54-b1ca-17984b0f3e55_OpenJS-Foundation-Privacy-Policy-2019-11-15.pdf

We use AMP to enhance our website performance. Data collected is stored for up to one year. You may request data deletion by contacting our DPO or directly through AMP.

Adjust

Adjust is used to optimize advertising campaigns, with data collected and stored for up to two years. To request data deletion, contact our DPO or Adjust directly.

Firebase

We use Firebase to address app development challenges and improve user experience. Data is retained for 2 to 14 months depending on the type. Data deletion requests can be made through our DPO or Firebase.

In addition to these third-party integrations, we may share your data with various entities, including:

(1)Affiliated Entities: Other parts of HUMMINGBIRD GAMES PTE.LTD., which help us in developing and operating our Games and Services.

(2)Service Providers: External companies that provide services to us, such as hosting, analytics, or functionality enhancement, who process data on our behalf.

(3)Payment Processors: Companies handling transactions within our Games or Services, who may process your payment information independently.

(4)Business Partners: Collaborators involved in delivering and promoting our Services, including advertising partners.

(5)Business Transfers: Potential buyers or their representatives in the event of mergers, acquisitions, or restructuring.

(6)Legal Compliance: Courts or authorities if required by law or regulation.

(7)Legal Protection: To assert, establish, or defend legal rights or to protect the vital interests of you or others.

(8)With Your Consent: Any other individual or entity as permitted by your consent.

Be aware that some information you provide or make visible through our Services, such as your in-game alias or chat messages, may be accessible to other users.

VIII Data Retention

We will retain your data only as long as necessary to fulfill the purposes for which it was collected, including providing our Services and meeting any legal, accounting, or reporting obligations. Inactive accounts and data in our Games or Services may be periodically deleted or anonymized.

Once the retention period has elapsed, we will either delete or anonymize your data. If deletion or anonymization is not feasible (such as when data is stored on backup servers), we will isolate your data from further processing until such actions can be performed. We may continue to use data that cannot be traced back to you, such as aggregated data. We will not attempt to re-identify individuals when using such anonymized data.

IX Data Protection

We have implemented security measures designed to protect your data according to the risk level associated with the processing activities described in this Privacy Policy. These measures aim to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to your data. The specific security practices we use can vary, but generally include encryption during transmission, pseudonymization of personal data when possible, access controls to restrict entry to systems containing personal data, and protocols for addressing suspected security incidents. Please be aware that while we strive to safeguard your data, the nature of the internet means we cannot guarantee complete security.

X Your rights

You have specific rights concerning your data in accordance with applicable laws and regulations. If we handle your data, you can exercise these rights. For example, you can request to access your data, ask for it to be deleted, or withdraw consent where applicable. To manage these rights, please use the options available in the settings of our Games or contact our Data Protection Officer (DPO). Your rights include:

(1)Accessing, correcting, or requesting the deletion of your data.

(2)Requesting restrictions on how we process your data.

(3)Objecting to our data processing based on legitimate interests.

(4)Requesting a machine-readable copy of the personal data you've provided to us, where feasible.

If our data processing is based on your consent, you can withdraw it at any time. To manage your advertising preferences, please contact our DPO. However, we may continue to process your data if we have legal reasons to do so, even if you withdraw your consent. For data access or deletion within our Games, use the provided options in the game settings or contact our DPO. If you have an account across our Games, you can also contact our DPO to request modifications or deletion of your account data. To exercise your rights, reach out to our DPO. We may need to verify your identity, which could involve requesting additional information. For inquiries related to payment methods or transactions, please contact the payment service provider directly.

XI Minor

Our Services are designed for a broad audience, including various age groups. While most of our offerings are suitable for all ages, some Games are intended for adults. If you choose to use these Games, you may be asked to confirm your age, or we may otherwise learn your age. If we determine that you are a minor or do not meet the age requirements, we may take necessary actions, such as restricting, suspending, or terminating your access to our Services. These measures are taken to comply with regulatory or platform requirements and to ensure a suitable user experience. If your access is not restricted or terminated, we will only use your personal data as needed for the operation of our Services and in compliance with relevant laws, regulations, and platform policies. This may involve limiting access to certain features or areas of the Services.

XII Updates

We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations. Any updates will be posted here, and we may also notify you through appropriate channels depending on the nature of the changes. Continued use of our Services will be considered as your acceptance of these changes.