Last Updated: September 30th 2019
TABLE OF CONTENTS
Information We Collect
The information we collect varies depending on which product you use, and how you use them. The controller for personal information collected is:
Concept Softworks, LLC.
6711 N Morning Glory Dr
Tucson, Arizona 85741
United States of America
Information provided by you directly
We collect information you provide us, including:
- Information you provide when seeking help from us, such as your name, email address, and records of the issues you experience;
- Information you provide when completing a customer survey; and
- Information you provide to enter a contest or sweepstakes. If you win, we may need to collect your social security number, postal address and/or national identification for eligibility, prizes delivery and tax purposes.
When you participate in social features through a Social Media Site, the information you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure your privacy settings on the Social Media Sites you use reflect your preferences.
When you participate in online leaderboard components of our products, your in-game profile information, gameplay, and statistics may be visible to all.
Other Information We Collect When You Use Our Products
We collect other information automatically when you use our products, including:
- IP address;
- Mobile and other hardware or device identifiers or the advertising identifier;
- Browser information, including your browser type and the language you prefer;
- Referring and exit pages, including landing pages and pages viewed;
- Platform type;
- Your location, down to the resolution of city;
- Information about your media, device, hardware and software, such as your hardware settings and components;
- Details about what Concept products you use and your use of them; and
- Device event information, including crash reports, request and referral URLs and system activity details (e.g. whether you encountered an error playing our games or lost Internet access).
We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage and application data caches.
To comply with local laws, we may need to collect your IP address to help us determine your country of residence. In that case, your IP address may be sent to a server that we control, for evaluation purposes, but will not be stored or further processed. We also use your device settings to determine the country where you are located as a way to respect privacy laws specific to your location. We do not collect your precise location, at a level more granular than your city, without your explicit consent.
Information Provided to Us by Third Parties
If you play or purchase our games or in-app purchases on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide, through systems such as Google Play Services or Apple Game Center.
We may receive information from third parties, like Facebook or other Social Media Sites, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us. We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.
How we collect information
We collect some information from you when you provide it to us directly, such as via an online form or when you communicate with our customer support team. We and third parties also use certain technologies, described below, to deliver positive customer experiences.
Our products change over time and those changes are reflected in new versions that are available to download from the Apple App Store, Google Play Store, Amazon App Store, and other official stores. Concept recommends that you always use the latest version of our products to guarantee you have the most secure, privacy-oriented, and engaging experience possible.
Older Concept products may not provide all of the privacy protections discussed in this document. Your continued use of them indicates that you understand that your data may be collected by Concept and third party partners and that you consent to that collection.
Concept cannot guarantee the integrity of versions of products that are installed from unofficial channels and does not support provide customer support or provide privacy guarantees for those unofficial versions. If you are using a version of one of our products that was installed from an unofficial channel, we encourage you to remove it from you device as soon as possible and install an officially distributed version.
Information Provided to Us by Third Parties
We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.
For example, Concept may collect and store data from your device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP address and device ID), information about your feature usage, gameplay and usage statistics and system interactions. If you play a game offline, this data will be stored on your device and may be transmitted to Concept when your device connects to the Internet. If you participate in online components of our games, such as leaderboards, Concept may also collect, use, store, transmit, and publicly display statistical data regarding game scores and achievements.
Third party analytics services integrated into our products may combine the information they collect in connection with Concept services with information they have independently collected over time and across different websites and applications. Many of these companies collect and use information under their own privacy policies. A list of the third party analytics companies that operate in our products can be found in the Appendix below.
Ad Serving Technologies
These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to device advertising identifiers, this information includes:
- Advertisements served and the location of the ad;
- Length of time an advertisement was visible;
- Domain type, IP address, size of the advertisement; and
- Advertisement response.
Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different products, websites, and services. Many of these companies collect and use information under their own privacy policies. A list of ad serving companies that operate their own networks in our games as well as how to opt out the extent applicable can be found below.
To learn more about some of these ad networks’ practices, see the Your Choices and Controls section below.
European Economic Area
Prior to being shown ads in Concept products, you will be asked whether you consent to the tracking that enables personalized ads. You have the right to change your consent status at any point in time. If you have questions about how to change your consent status or to inquire regarding your rights to erasure or data portability, please contact our privacy team at email@example.com.
Fraud Prevention Technologies
How we use your information
We use your personal and non-personal information, both individually and in aggregate, in the following ways:
To operate our business and to enhance and personalize your game experience, including to:
- Operate, improve, and develop our games and services;
- Populate online leaderboards and enable online challenges;
- Help you find your friends or tell your friends about a Concept product;
- Facilitate sharing on social networks;
- Serve and measure the effectiveness of advertising;
- Measure the health of our services;
- Provide game experiences customized to your preferences;
- Facilitate your gameplay on multiple devices, when available;
- Identify, fix, and troubleshoot bugs and service errors;
- Provide software updates;
- Save game progress and stats;
- Adhere to your preferences and to deliver dynamic content; and
- Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.
To provide you support, including to:
- Help identify and troubleshoot problems with your account or games;
- To survey your opinions through surveys or questionnaires;
- Communicate with you and respond to your specific requests or questions; and
- Manage and send you confirmations and important information about your products.
To personalize our communications with you, including to:
- Present offers or information relating to games you might like;
- Make recommendations to you; and
- Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
How we process your information
Concept uses analytics services to understand how users engage with our products. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one Concept product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of the Concept products you have installed. The identifier value is provided to Concept through the operating system on your device. In the course of processing your data, we may do any of the following:
- Analyze your behavior in our products over time;
- Analyze your behavior in aggregate;
- Combine your information with the information of other players to create anonymized aggregate reports that allow us to understand large-scale behavior trends;
- Analyze your information to understand how well our products perform on your device or to investigate bugs, crashes, and other technical issues;
- Combine your information with the information of other players to create customer segments based on behavior in our products or location-based behavior;
- Use analysis of your behavior in our products to provide you with customized gameplay experiences;
- Use your device identifier to enroll you in an A/B test. An A/B test is a type of simple behavioral experiment wherein groups of users are provided with slightly different experiences in our products so that we can research and analyze which of the experiences is the most compelling to users of our products; and
- Analyze your behavior in the context of an A/B test.
European Economic Area (EEA) Only:
Per requirements under the EU’s General Data Protection Regulation (GDPR), we log your consent state for compliance purposes. This information is stored on servers hosted in the US and is used solely for GDPR compliance. Your device identifier is stored along with your consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in our consent logging database if you do not consent to personalized advertising.
Please note that your advertising consent status is only respected when you are playing the game from within an EEA member country.
Information we share with third-parties
We do not share personal information that directly identifies you (such as your name, email, or postal address) with independent third parties without your consent, unless it is required by law or we determine that disclosure is critical to protect our rights, property, or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys or analyzing gameplay event data. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.
We do not knowingly disclose personal information about children under 16 years of age to independent third parties even with consent.
However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook “Like” button.
European Economic Area (EEA) Only:
- We use your device settings and SIM card registered country to determine whether we believe you are located in the EEA. That processing is done on your device.
- If your device indicates that you are located in the EEA:
- Concept does not collect gameplay analytics from your device;
- We prompt you for your age to determine whether you are old enough to lawfully consent to tracking of your device identifier and advertising identifier; and
- If you are of legal age to consent in your country of residence, we prompt you for consent to serve personalized advertising.
How we protect your personal information
We have put in place reasonable controls designed to help safeguard the personal information we collect via our products. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an unauthorized way.
Age guidelines and childen privacy
Protecting children’s privacy is extremely important to us. We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times.
Concept products are intended for general audiences and do not knowingly collect any personal information from children under the age of 16. If you are under 16 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access Concept products. If you believe Concept has inadvertently collected such information, please contact us (information below) so we can promptly remove the information.
Concept has a policy of retaining information we collect for no longer than 90 days. During the period when we hold Information, we may transform and aggregate it such that it no longer is personally identifiable. We may retain the de-identified aggregate data products for more than 90 days to support business critical needs.
Uninstalling Concept applications from your devices does not cause the data that we possess to be deleted. It remains subject to the same data retention and expiration policies.
Legal basis for processing (EEA only)
If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Technical and usage information
Concept does not collect in-game technical or usage data or gameplay analytics for players in the European Economic Area. Note that Google Play Services, Apple Game Center, and other platform-level services may collect gameplay analytics if you are located within the EEA. Please see your device-level settings for more information about how to disable those services. Concept considers any data specific to your use of our apps that is collected or processed through Google Play Services or Apple Game Center to be in our legitimate business interests.
Concept works with advertising partners that may collect information from you as part of their process of serving advertisements in our products. This is described above in the section “Ad Serving Technologies.” In accordance with the General Data Protection Regulation (GDPR), Concept’s advertising partners in the European Economic Area all function as independent data controllers. Prior to showing you personalized advertisements, you will be asked whether you consent to sharing your information with the advertising company. If you are a resident of an EEA country and indicate that you are below the age of 16, you will be served non-personalized ads and the advertising companies will not collect personal information from you.
Right to erasure
Under the GDPR you have a right to have Concept and our third party partners erase the personal information we have collected from you without undue delay.
Right to portability
Under the GDPR you have a right to request a copy of the personal data Concept and our third party partners have collected from you.
Right to withdraw consent
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. To change your consent status, please visit the following screen in the product you are playing:
- Super Drop: Options
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org
Right to object
Your choices and controls
We understand your design to have choice and controls over which data you share with us, as such we’ve outlined what data sharing you can control, and how you can control it.
If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative https://www.networkadvertising.org/ and/or the DAA Self-Regulatory Program for Online Behavioral Advertising https://www.aboutads.info/principles. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please download the version of AppChoices for your device here http://youradchoices.com/appchoices or visit these websites:
Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
If you are a California resident, you may request information about our practices related to disclosing your personal information to certain third parties and/or opt-out of our sharing of your personal information with unaffiliated third parties for the third parties’ direct marketing purposes. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email at email@example.com.
For other customer support needs, please contact firstname.lastname@example.org. Please do not include any personal information in your email to customer support.
English version controls
Non-English translations of this Policy may be provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
The following list summarizes our ad serving and analytics providers and where you can go to get more information about their policies and practices and opt out of their networks in many cases.
Concept uses the following providers for serving ads within our software
Concept uses the following providers for analytics within our software