1Game Mobile Apps - Privacy Policy

Last Revised: October 22, 2017

1Game, its subsidiaries and its affiliates («Company», «we» or «1Game») respect the privacy of the users (including children) of their mobile applications («User» or «you») and are committed to protect the Users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our Apps (defined below).

IMPORTANT - 1Game operates mobile apps which are oriented for children under the age of thirteen (13) (collectively, “Kids Apps”).

1. Your consent (important, please read carefully!)

BY INSTALLING THE APPS ON YOUR MOBILE DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APPS, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION. PLEASE NOTE: IF YOU OR, AS APPLICABLE, YOUR LEGAL GUARDIAN, DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MUST NOT INSTALL, ACCESS AND/OR USE THE APPS AND YOU ARE REQUESTED TO PROMPTLY ERASE ALL 1GAME APPS FROM YOUR MOBILE DEVICE.

If you are under the age of eighteen (18) you represent that your legal guardian has reviewed and agreed to this Privacy Policy.

Kids Privacy Policy

This Kids Privacy Policy is designated to provide you, the legal guardian of a child under the age of 13 years old, with guidance regarding our privacy policies and principles with respect to collecting, using and disclosing personal information regarding children under the age of thirteen (13) («Kids») that are using our Kids Apps.

We do not knowingly collect any personal information from Kids other than as expressly specified in Sections 3.2 and 3.3 below.
We hereby prohibit any User under the age of 13 from actively and directly providing us with any personal information other than as specified in Section 3.3 below. If you are a legal guardian of a child under the age of 13 and you believe that your child has provided us with any personal information, please contact us at 1game.mob.apps@gmail.com and we will delete such information from our servers.

1Game may collect and maintain the information described in Section 3, directly or through certain products or services, solely for the purpose of supporting 1Game’s internal operations as permitted under applicable laws and rules (as described in greater detail below).

1Game’s third party providers of certain products or services operating on our behalf, such as advertising networks, analytics services etc. («Third Parties») may passively collect and maintain information about Users. Such Third Parties are carefully selected by 1Game to preserve compliance with applicable privacy laws, and we confirm that they are compliant with the US Children’s Online Privacy Protection Act of 1998 and the rules promulgated by the Federal Trade Commission (FTC) under that Act, including but not limited to the Children’s Online Privacy Protection Rule 16 C.F.R. Part 312) («COPPA») in performance of their services for 1Game. Any question about Third Parties' privacy practices and policies should be directed to our Privacy Policy Administrator by e-mail to: 1game.mob.apps@gmail.com. We will forward your inquiry to the applicable Third Party and make an effort to provide you with such Third Party’s response within a reasonable timeframe.

2. Offline Use

1Game allows an offline use (without Internet connection and without GPS enablement) of some features of its Kids Apps. Offline use of Kids Apps will preclude the collection by 1Game and/or Third Parties of any information pertaining to you, as the legal guardian of a Kid, and/or your use (including, as applicable, information pertaining to your Kid and his/her use) of the Kids Apps.

3. Online Use

There are three types of data and information which may be collected from Users of our Kids Apps:

1. 3.1 Non-personal Information: 1Game and its Third Parties may passively collect non-identifiable and anonymous information as detailed below («Kids Non-personal Information»). To put it simply, with respect to such Kids Non-personal Information, 1Game and the Third Parties are not aware of the identity of the User from whom Kids Non-personal Information has been collected. Kids Non-personal Information collected by either 1Game or Third Parties may include technical information such as: type of operating system (e.g. Android, iOS, etc.), type of browser (e.g. Explorer, Firefox, Chrome, Safari, etc.), screen resolution (e.g. 800×600, 1024×768, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ad units, sites or applications, and campaigns a User came from), language (e.g. English), device type (e.g. Galaxy, HTC, iPhone, etc.), data regarding User behavior within our Kids Apps (e.g. advertisements impressions, User’s response to advertisements (including advertisements viewed or clicked), User’s in-app purchases, User’s gameplay (e.g. level reached, frequency and time spent in the Kids App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, tools and in-app functionalities used, screens accessed, User retention, performance errors and problems, Kids Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific advertisement and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), other 1Game Apps installed, User age-related information (meaning whether a User passes an age-gate, if included to prevent access to certain features to Users who do not pass the age-gate to protect Kids privacy), randomly generated User ID which may not be matched back to the User, and geo-location - only at a country level. It is hereby clarified that no street name or city/town name is collected.

2. 3.2 Kids’ Persistent Device Identifier and No Other Kids personal identifiable information:
1Game and Third Parties may also passively collect a persistent device identifier from Kids, such as IP address unique device identifier, advertising identifier (when available on a device) etc. («Kids’ Persistent Device Identifier»). 1Game does not collect and does not permit Third Parties to collect from Kids any information that may personally identify an individual (e.g.name, address, e-mail) (other than the Kids’ Persistent Device Identifier which is collected for the limited purpose of supporting the internal operations of the Kids Apps) and any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that 1Game may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies.

1Game does not link any additional personally identifiable information to the Kids’ Persistent Device Identifier, even from other services.

3. 3.3 Information gathered through the Kids Apps «Ask a Question» or «Support» type of a feature:
If a Kid e-mails a question to 1Game, using the «Ask a Question» or «Support» type of a feature which may be available within the Kids Apps, 1Game may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at 1Game’s discretion, not responding) to such question, 1Game will delete the Kid’s e-mail address.

Purpose of the collection: The information abovementioned is collected and processed solely for the purpose of supporting 1Game’s internal operations. This means the following:

I. providing and improving Kids Apps as well as ensuring proper functioning of the Apps and services;

II. maintaining or analyzing the functioning of the Kids Apps and services;

III. authenticating Users (e.g. verifying the User's identity when interacts with advertisements or acquires in-app purchases);

IV. personalizing content and enhancing User experience;

V. performing network communications;

VI. protecting the security or integrity of Users, Kids Apps and services;

VII. serving contextual advertisements;

VIII. capping the frequency of advertising;

IX. ensuring legal or regulatory compliance;

X. fulfilling a User’s request under Section 3.3.

The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.

How the Information about our Users of Kids Apps is being collected? The abovementioned Kids Non-personal Information and Kids’ Persistent Device Identifier are collected either by 1Game or by Third Parties through the Users’ use of the Kids Apps, including, without limitation, through Third Parties’ SDK embedded in our Kids Apps. In addition, Kids Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Kids Apps, such as «cookies-like technology» and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).

If Third Parties whose SDK is installed in the Kids Apps collect Kids Non-personal Information, Kids’ Persistent Device Identifier and/or any other information directly from Kids, such collection and processing is governed by such Third Parties’ privacy policies and not by this Privacy Policy. However, all Third Parties are carefully selected to preserve compliance with applicable privacy laws, and we confirm that they are compliant with COPPA in performance of their services for 1Game.

1Game does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Kids.

4. Sharing Kids information with third parties

We may share the Kids’ Persistent Device Identifier only in limited cases, including the following:

a. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

b. to enforce this Kids Privacy Policy or the Terms of Use, including investigation of potential violations thereof;

c. to detect, prevent, or otherwise address fraud, security or technical issues;

d. to protect the rights, property, or personal safety of 1Game, its Users, suppliers, licensors, and/or licensees, or the general public;

e. when 1Game is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or

f. pursuant to the approval of a Kid’s legal guardian, in order to supply certain services that such legal guardian or the User of the Kids Apps may have requested from the Company;

For avoidance of doubt, 1Game may transfer and disclose Kids Non-personal Information to third parties at its discretion.

5. Advertising

We accept advertisements from Third Party ad networks which may be displayed in our Kids Apps. These Third Parties ad networks are carefully selected to preserve compliance with applicable privacy laws, and we confirm that they are compliant with COPPA in performance of their services for 1Game. Note that if the User of the Kids Apps clicks on any of these advertisements, the User will leave our Kids Apps and go to the advertisers’ site the User selected, and the advertisers may use cookies and other web-tracking technologies to collect Kids Non-personal Information and/or Kids personally identifiable information. We recommend that you, as the legal guardian of a Kid, review the terms of use and privacy policy for any advertiser with whom you and/or the User of the Kids Apps are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

In addition, 1Game may, at its discretion, advertise other 1Game Apps within the Kids Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random 1Game Apps.

6. Security

Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. 1GAME SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.

7. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Apps and any information collected therein. The Company reserves the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Apps. Such material changes will take effect seven (7) days after such notice was provided on our App and/or Site, whichever is the earlier. Otherwise, all other Changes to this Privacy Policy are effective as of the stated «Last Revised» and your continued use of the Apps on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

8. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: 1game.mob.apps@gmail.com and we will make an effort to reply within a reasonable timeframe.