PRIVACY POLICY – GAMES

1. AN OVERVIEW ON DATA PROTECTION

1.1 General information about this privacy policy

We take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy. Whenever you use our games, various personal data may be collected.

The following information will provide you with an easy to navigate overview of which data we collect how as well as the purposes we use this data for when you play our games.

The term “personal data” comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as your phone ID, cookie identifier or game data).

For detailed information about the subject matter of data protection, please consult our Privacy Policy below. You can access this information at any time at https://jollypunch.com/privacy.

1.2 Data Recording

How do we collect your data?

On the one hand, your data is collected by you communicating it to us. This may be data that you enter in a contact form or if you connect your game to third-party accounts, such as Facebook or Google. Other data is automatically collected when you download and use our games. If advertisements are present in the game, we also collect information about the advertisements served and how often you have viewed them, their location in the game and the identifier of your terminal device. We also collect information about your actions in relation to the advertisements, such as the page views, the time and the duration of the view.

What are the purposes we use your data for?

We use this data to provide our games to you, including for the purposes of optimization, processing support requests, preventing fraud, customizing and/or personalizing your game experience and in-game offers, verifying purchases and provide you with supplementary services. We may also use the data to provide you with advertisements, products, services or personalized content through our services or those of our partners. We may link the data we collect with our partners when you use our services. We may also link this data to demographic, advertising or market research or other analytical surveys.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. Please do not hesitate to contact us at any time under the address disclosed on the imprint of this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.

Moreover, you have the right to demand the restriction of the processing of your personal data.

Details of how to exercise your rights can be found in this Privacy Policy under “Your Rights”.

Analysis tools and tools provided by third parties

If you download and use our games, your usage data may be statistically analyzed.

Such analyses are performed primarily with what we refer to as analysis programs. The analyses of your usage data are usually conducted anonymously; i.e. the patterns cannot be traced back to you.

For detailed information about the tools and about your options to object, please consult our Privacy Policy below.

2. GENERAL INFORMATION

The responsible party (referred to as the “controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).

The controller according to data protection laws is:

Jollypunch Games, Via Venosta 1, Morbegno, 23017 SO, Italy

If you have any questions or suggestions about data protection, you can send us an email to privacy@jollypunch.com

3. COLLECTION AND USE OF YOUR DATA

3.1.         Player ID

When you first play our games, we may automatically create a pseudonymized user ID. We collect this data in order to provide you with access to our games, for example to your saved game and unlocked or purchased content, Article 6(1)(b) GDPR.

3.2.         Third-Party Accounts

In some of our games you may also connect your player to third-party accounts such as your Facebook or Google account in order to participate in multiplayer features. You can cancel the connection with your other third-party accounts at any time by sending a message to privacy@jollypunch.com.

We collect this data to fulfil our contract by providing our app to you and to be able to connect your account if desired. We may also use this information on our legitimate interest to re-identify your player profile, for example when you lose access to your save game.

To the extent that we, as described above, process your data for the purposes of providing the functions of our app (e.g. player ID), we require these information to provide you with our games and their functions. Without this data, we are not able to provide these functions to you.

You are, however, not required to provide data of your third-party accounts and connect our games to them. Without this data, however, we are not able to provide the corresponding functions of our app to you.

3.3.         Support requests

If you send support requests to us by email or via messages within social media platforms, we collect and process the data from your request and data from your account.

We only collect this data in order to appropriately respond to your questions, to provide our app to you and to be able to process your request based on the contract we passed when you accepted the Terms and Conditions.

The data sent by you to us via contact requests remains with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions in particular statutory retention periods remain unaffected.

4. PERMISSIONS

Our app uses the following permissions:

Permission

Purpose

Google Play billing service (Android)

Allows the user to purchase in-game products.

Full access to the network

Necessary for sending data to the Internet.

Mobile data

The player can allow access to mobile data so that it can use all the functions of the game without being connected to Wi-Fi.

Access to local storage

The app characterizes the local storage and accesses it in order to be able to execute the services.

5. STATISTICS AND ANALYTICS

For the needs-oriented design and statistical analysis of usage of our app, we collect pseudonymized data about how our apps are used, and we evaluate this data statistically.

Specifically, we use third-party analytical tools in connection with our own Services. These partners process your data only at and according to our specific instructions and may use cookies and other tracking technologies to collect information about your use of our Apps.

We collect this data on the basis of a legitimate interest in needs-oriented design.

6. DISCLOSURE OF DATA

We may share your data with:

The technical service providers involved in the supply of the services. As subcontractors, these service providers are under the same obligations as Jollypunch Games to comply with applicable personal data protection laws.

Other companies, only in the event of a transfer of Jollypunch Games activities.

Administrative or judicial authorities to verify the proper use of our services or for the purposes of an investigation, in compliance with applicable law. Jollypunch Games always verifies the legitimacy of the request.

In such cases, your data may be transferred to countries located outside of the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of your data is especially ensured by the signature of standard contractual clauses approved by the European Commission.

7. DELETION OF YOUR DATA

Unless the law specifies a different retention period, we will delete or anonymize your personal information as soon as you request us to delete your data or it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs.

If data must be kept for legal reasons, they are blocked. In that case they are no longer available for further use.

8. AGE LIMITS

To use our services you must confirm full legal capacity or, in case of restricted legal capacity, obtain the consent of your legal guardian. We do not knowingly collect or ask for personal information from children. In case you can’t confirm full legal capacity, please do not send us any data about yourself, including name, address or email address. If we learn that we have collected personal data of a child, we will delete these as soon as possible. If you think that we might have data from a child, please contact us at privacy@jollypunch.com.

9. YOUR RIGHTS

In case you have questions about this Privacy Policy or want to exercise your rights as described below, please contact us via email at privacy@jollypunch.com.

9.1   Obtain a copy of your Data – “Right of access and data portability”:

At any time, you can request a copy of your Data. You may also consult the Data, use it yourself or transfer it to another service provider.

9.2   Correct your Data – “Right to rectification”

You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).

9.3   Delete your Account – “Right to erasure (right to be forgotten)”

You can request the closure of your Account and the deletion of the associated Data.

9.4   Limit the use of your Data – “Right to restriction of processing”

You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.

9.5   Give and withdraw your consent – “Right to object and withdraw your consent”:

At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers) by email request to privacy@jollypunch.com.

We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights

If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority.

10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy, if necessary, in compliance with the applicable data protection regulations. This way, we can adapt it to the current legal requirements and take changes in our services into account, e.g. when introducing new services. The most current version always applies to your visit.

The current version of this Privacy Policy is always available at https://www.jollypunch.com/privacy.

Last updated: November 1st, 2021