Effective Date: Dec 1, 2021
2. The Data We Collect About You
We collect several different types of personal information from you depending on how you interact with our Services. Personal information means any information about an individual from which that person can be identified. It does not include information where the identity has been removed or is not able to be associated with an individual.
Most of the information we collect is given to us by you through filling out forms, registering for an account, or otherwise providing information when asked. Occasionally, we collect information from your device which helps us better provide our services to you. Because we may change our website and the services we offer from time to time, the means and methods to provide us with personal information may also change. Depending on how you interact with us and use our services, the personal information we collect may vary. We may process the following types of personal data about you, which we have grouped together as follows:
2.1 Identifiers：This may include your name (first and last), a username (or similar identifier), data of birth, gender, and profile photo if you upload it.
2.2 Contact Information：This may include your email address, mailing address, telephone number.
2.3 Virtual Gifts Transaction Information：This may include information you provide for the purposes of sending virtual gifts to you, such as the email address associated with your account. It also includes the records, amounts and other information associated with virtual gifts transactions.
2.4 Technical Information：This may include your IP address (which may identify your general geographic location), device identifier data, the type of device you use, your operating system and version, the URL’s of our web pages that you visit, the URL’s of referring and exiting pages, the pages you view, the time spent on a page, the number of clicks made, the platform type, and generalized, non-specific location data.
2.5 Usage Information：This may include information about the game features you use, your game preferences, the types of games you play, how long you use our Services, and how you use our Services.
2.6 Account Information：This may include your username and password, your preferences, feedback and survey responses.
Marketing and Communications Information：This may include your communications preferences in receiving marketing from us and/or third parties.
2.7 Account Information：This may include your username and password, your preferences, feedback and survey responses.
2.8 Marketing and Communications Information：This may include your communications preferences in receiving marketing from us and/or third parties.
2.9 Geolocation Data：We collect your geolocation data whenever you choose to access the rewards or wallet features and play our games. We use this data to determine our legal obligations in that jurisdiction.
3. How We Collect Your Personal Information
We collect information about you in many different ways. Most of the time we collect through your direct interactions with our Services, but we may also automatically collect personal information from your devices, and occasionally from third parties or publicly available sources.
We collect information about you in the following ways:
Direct Interactions. When you interact with our Services, you may provide us your personal information by filling in forms, communicating with us by email, telephone, text/SMS, post, or otherwise. This may include personal information you provide when you:
3.1 Subscribe for our Services/Register for an Account;
3.2 Request that the App be texted to you;
3.3 Request marketing be sent to you;
3.4 Enter a game, competition, promotion, or survey,
3.5 Provide us feedback, requests support, or otherwise communicate with Us.
3.1.1 Automated Collection. As you interact with our Services, we may automatically collect Technical Information and Usage Information. We collect these categories of Personal Information by using cookies, SDK’s, web beacons, and other similar technologies.
Third Parties or Public Sources. We may share and receive personal information about you from various third parties as follows:
3.1.2Technical Information and Usage Information from the following parties:Advertising Networks
3.1.3 Contact Information, Transaction Information, and Technical Information from providers of technical, communications, and service providers;
3.1.4 Social Networking Posting Tools and Share features. When you visit a page that includes one of these sharing tools, the third-party company that operates the tool may be collecting information about your browser, device, and other online activity through its own technology not controlled by us. Please read their privacy policies.
3.1.5 Identifiers and Technical Information from Social Networks when you grant us permission to access data on one or more of those services.
3.1.6 Publicly visible data, such as your social media and other information submitted to social media or other publicly available media.
4. How We Use Your Personal information
We will only use your personal information when allowed by law. Generally, we will use your personal information: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and (c) where we need to comply with a legal or regulatory obligation.
We will use the information we collect about you in the following ways:
4.1 to administer our platform (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to solicit your feedback;
4.2 to allow you to participate in interactive features of our apps, when you choose to do so;
4.3 to personalise the content you receive and provide you with tailored content that will be of interest to you;
4.4 to improve and develop our service and conduct product development;
4.5 to provide you with services based on the country settings you have chosen, such as the content that is related to the country settings;
4.6 to allow other users to identify you via the "Add Friends" function as a user of the Service, to allow you to find other users and to connect with them on our apps, and to support the socializing function of the Services;
4.7 to provide you with your profile information to send to anyone you choose and to enable you to participate on our apps and interact with other users;
4.8 to help us detect abuse, fraud, and illegal activity within any of our apps;
4.9 to notify you about changes to our Services;
4.10 to communicate with you.
4.11 to provide you with user support;
4.12 to enforce our terms, conditions and policies.
5. Marketing and Advertising Practices
We may reach out to you in different ways, for example, to tell you about new features, games, or sweepstakes on the App we think you’d be interested in, or to show you how to use a particular feature we think you may enjoy. However, you can also let us know that you’d rather not hear from us with this type of communication.
Promotional Offers From Phoengod. We may use any of the categories of personal information we collect to make decisions about what we think you may desire or need as our consumer. We will only make these marketing decisions if you agree to receive email marketing from us. In all cases, we allow you to opt-out of receiving marketing communications from us.
Interest Based Advertising. Phoengod uses advertising to help fund our services and we utilize numerous advertising technology platforms to help deliver relevant advertising to you. Phoengod and the technology service provider may collect, receive, or use your personal data in connection with our use of the platform in order to provide interest-based advertising to you. In such cases the advertiser is acting as a controller of the data for its own purposes.
Most of the third-party advertising and data companies we work with, including subscribe to the DAA Principles and/or are members of the Network Advertising Initiative (“NAI”). To learn more about the information collection practices of NAI members and your related opt-out choices, please visit the NAI’s website here. For more on EU online choices, please visit the EU online choices website here. You can opt out of interest-based advertising from Google by visiting the About Google Ads page or opt out of the DoubleClick cookie by installing the DoubleClick opt out extension. For information about how Google uses data from DoubleClick for Publishers, click here.
Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertisers include the following:
5.1 MoPub: https://www.mopub.com/legal/privacy/
5.2 AppLovin: https://www.applovin.com/privacy/
5.3 Facebook: https://www.facebook.com/about/basics/advertising
5.4 Unity: https://unity3d.com/legal/cookie-policy#cookies
5.5 Vungle: http://vungle.com/privacy
5.6 Fyber: https://www.fyber.com/privacy-policy/
5.7 IronSource: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Mobile App Advertising and Tracking. Phoengod, our authorized service providers and/or other third-party partners (listed above) involved in the delivery of advertising you receive through our App may collect information about your mobile device, including your mobile device’s advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. We and our partners use this information to enable interest-based advertising you receive through our Services and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device’s advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions. Visit the privacy settings for your mobile device for more information.
In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.
6. Disclosures Of Your Personal information
From time to time, we may need to share your personal information with others, including in the following circumstances.
Disclosures to the Public. Some of your personal information will be shared with the general public, including your first name and last name initial, city, state, and country. When information is made publicly available it may be accessed by anyone with access to the platform to which the information is posted. It may also be indexed by third-party search engines, and be imported, exported, distributed, aggregated, and redistributed by others without our knowledge.
Third Party Service Providers. We may share your personal information with third party service providers who perform various functions to enable us to provide our services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the personal information we provide to them, only act on our behalf and under our instructions, and not use personal information for purposes other than the product or service they’re providing to us or on our behalf.
With our Affiliates and Partners. When participating in events or activities that we offer along with our partners and/or affiliates, you may be asked to share personal information with those affiliates and/or partners. For example, a game, contest, competition, contest, sweepstake or other offering may be co-sponsored by another company or companies. In such a situation, the information we obtain from you in connection with such a contest, sweepstake or offering may be shared with our co-sponsor, unless you instruct us not to (which may result in you not being able to participate). In some of those cases, we may act as co-controllers of your personal information, depending on the circumstances.
With Unaffiliated Controllers. In some cases we may transfer personal information to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your personal information to third-party data controllers for the following purposes: 1) to provide you with third-party offers; 2) to provide us information about the quality of our services offerings. We will only provide your personal information to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive personal information, where you have opted-in if the disclosure requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for your personal information that is required of us. We also limit their use of your personal information so that it is consistent with any consent you have provided and with the notices you have received.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your personal information may be shared with other third parties.
7. Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. International Data Transfers
10. EU Data Subjects Privacy Rights
EU data subjects have certain rights with respect to your personal information that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
10.1 Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal information. You can often go directly into the Service under Account Settings to take these actions. Please note that even if you request for your personal information to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in Section 9 “Data Retention”, above.
10.2 Objection. You may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
10.3 Restriction. You have the right to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10.4 Portability. You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
10.5 Withdraw Consent. If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
10.6 File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information.
To file a request or take action on one of your rights, please contact us at the contact details provided. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We comply with the Children’s Online Privacy Protection Act (COPPA) and the General Data Protection Regulation (GDPR). We do not intend to collect any personal identification information of children under the age of thirteen (13), but there may be errors during the process of collection of data. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we would take action to ensure that such information is deleted from our server.
12. How to Contact Us
We will generally notify all users of any material changes to this policy, through a notice within our apps. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.