Spiral Interactive Ltd. and its subsidiary (referred to herein collectively as, “Spiral Interactive”, “we”, “us”, “our”) develop and operate Social Games for mobile devices and websites (Each an “App”, and collectively the “Apps”).
We encourage you to read the Policy in full. However, we understand that it may be sometimes difficult to find the time to fully review everything online immediately, and therefore present you with a brief summary of key points of the Policy. These key points are brought only for your convenience and do not substitute the full Policy.
Information we collect.
We collect information about your use of our Apps. If you contact us for questions or complaints, we will collect the information related to your inquiry. We will collect additional information we may receive from third-party applications if you chose to access any of our Apps on connected third-party applications or connect our Apps to any third-party applications.
Basis for processing your information.
Processing your information is necessary for the performance of the Terms and the provision of the Apps’ service to you. Processing for the purposes of developing and enhancing new games and our products and services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
Using the information we collect.
We use the information we collect mainly to administer and provide the Apps, contact you with administrative information, improve the Apps, and to tailor the game experience and our app’s offers to you
Sharing the information we collect.
We will share the information we collect with our subsidiary and our trusted vendors who assist us in the internal operation of the Apps and process the information on our behalf and under our instructions.
Under certain circumstances you have rights under data protection laws, such as the General Data Protection Regulation (“GDPR”), in relation to your personal data, such as the right to access, rectify, restrict, erase or transfer your personal data and obtain a copy of it. For additional information regarding rights which may apply to you under the GDPR please review our GDPR Awareness Center.
We retain information for as long as necessary for the purposes set forth in this Policy.
We implement customary measures to reduce the risks of damage and unauthorized access or use of information.
Changes to the Policy.
We may update or change this Policy from time to time, by notifying you of such changes.
Personal Data Processed
In order to make our Apps as customized as possible to your needs and interests, we will gather certain information from you, such as:
device identifier (such as IDFA and/or Advertiser ID and/or IMEI and/or ASHWID and/or Device UniqueId and/or Android ID);
based on your consent. your personal data we gather can also originate from third-parties, If you play or access any of our Apps on connected third-party applications or connect our Apps to any third-party applications, including social networks such as Facebook, we may receive certain information about you from such third parties. The information collected by us depends on the third-party application, your privacy settings within the third-party application and your game settings. Information we will collect and store from third-party applications, may include the following (depending on your personal settings):
How Your Personal Data Is Used
We use the information that we gather about you for the following purposes:
In order for us to provide you with the best experience and services, we use the data we collect for the following purposes:
Customer Support Correspondence
Correspondences with our support team will be collected and stored, including your contact details and the information provided by you during the various correspondences, in order to provide support, improve our services and for our exercise or defense of potential legal claims (only for the appropriate period under applicable law).
Who Will Process Your Data
Your personal data will be processed by us and/or our trusted service providers, only where we have a lawful basis to do so.
In respect of your personal data, the lawful basis for processing may include:
where we are required to do so in accordance with legal or regulatory obligations – If we are required to disclose your information by a judicial, governmental or regulatory authority we will do so under the legal basis of complying with mandatory legal requirements imposed on us.
where it is in our legitimate interests to process your personal data – in case of a serious abuse of rights of our Apps or violation of any applicable law, we will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation under the legal basis of defending and enforcing against violation and breaches that are harmful to our business.
Consent – If you have provided your consent to process your data, you can withdraw it at any time by contacting our support team here.
Contract performance – where it is necessary for us to process your data in order to establish, operate and manage your account in our Apps.
Legitimate interests – to improve our service and make your experience as enjoyable as possible by conducting technical diagnostics, research analyses and obtaining feedback from time to time, in order to personalize and modify our Apps and services.
We will share your personal data with our trusted vendors, such as Google and Apple, who assist us with marketing optimization, analyzing data, payment processing and analysis of our services.
We also use third-party advertisers, these companies will be authorized to use your personal data only as necessary to provide these services to us and not for their own promotional purposes.
If you do not want to receive tailored 3rd party in-app advertisements, please contact us here. Please note that you will still receive advertisements from third parties within our app even if you opt out of tailored advertising but they will not be based on your activity
International Data Transfers
We transfer your personal data from within the European Union to locations outside the European Union. In such cases, and in order for us to keep your information as safe as possible, we will take appropriate steps such as via data processing agreements and standard contractual clauses to ensure an adequate level of protection to your personal data. For additional information please review our GDPR Awareness Center.
We retain the collected information for the minimum appropriate amount of time, as may be necessary in order to provide you with access to and use of the App(s) and Services, comply with our legal obligations, resolve disputes, and enforce our agreements. We may delete information from our systems, without notification, once we deem it is no longer necessary to continue retaining it.
If you are an EU individual, you may request from us a copy of your personal data that we store, or to update, correct, restrict, erase or transfer your personal data, provided however, that we may retain a copy of certain information for audit and record-keeping purposes and protection of our legal rights, where permissible by law. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further information about you, you should delete our Apps from your devices. For additional information please review our GDPR Awareness Center.
You are also entitled to obtain your information in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller.
If you wish to exercise these rights, please contact our support here and let us know that you wish to exercise your right of access and specify which information you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Where we are not able to provide you with information that you have asked for, we will endeavor to explain the reasoning for this.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.
We do not knowingly collect personally-identifiable information from or market our Apps to children under the age of thirteen (13). In the event that you become aware that an individual under the age of thirteen has enrolled without parental permission, please advise us immediately.
How to Access and Limit Our Use of Certain Information
Users of our App(s) are given the opportunity to “opt out” of having their personal data used for purposes not directly related to downloading and accessing our Apps and purchasing Virtual goods and/or Virtual Money. You may “opt out” at any time, even if you have previously elected to receive direct/personalized marketing communications or advertising. If you prefer to do so and do not want us to use your information except in relation to offering the Apps, you may notify us by emailing our support here
If we update or change this Policy, we will make efforts to proactively notify you of such changes.
Comments and Questions
Last updated on May 25, 2018