PLAYLITHIUM PRIVACY NOTICE
Last updated: Nov 4, 2018
This Privacy Notice explains who we are, how we collect, share and use personal
information about you, and how you can exercise your privacy rights. The Services are
also governed by the Terms of Service.
We are Playlithium Interactive, LLC, maker of Super Ball Escape, King of Frogs, Datou
Datou and many more. For details about how to contact us, see the “How To Contact
Us” section below.
This Privacy Notice applies to personal information that we collect through our games,
mobile applications and other products (“Games”) and websites we control, like at
www.playlithium.com (“Website”) (collectively “Services”).
1. WHAT PERSONAL INFORMATION DOES Playlithium COLLECT?
The personal information we may collect about you through the Services falls into the
following general categories:
1.1. Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily.
For example, we may ask for certain information in order to register an account with us,
to begin playing Games, to subscribe to marketing communications from us, and/or to
submit enquiries to us, such as:
• your name, email address or other contact details
• any information you submit to our customer service team in the Game or via
The personal information that you are asked to provide, and the reasons why you are
asked to provide it, will be explained to you when we ask you to provide your personal
information.
1.2 Information we collect automatically
When you use our Services, we may also collect certain information automatically from
you and/or your device which may be considered personal information under applicable
data protection laws, such as:
• Your Service communications (e.g. in-game chats and messages with other
players)
• Data and analytics about your use of our Services (e.g. in-game play progress,
levels, games played, session length, preferred settings, which in-game adverts
you may have viewed, in-game preferences or just game preferences, which
friends you connect with, the means by which you were referred to our Services)
• Your IP address and device identifiers such as your Advertising ID, Device ID
numbers (for more see here “Advertising IDs and Device IDs”)
• Your device type and the operating system that you use
• General geographic location (e.g. country or city location) based on your IP
address
• GPS location, with your consent
“Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple, and
Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices
that advertisers use for interest-based advertising. They are consistent across all apps
and thus allow cross-app tracking. On Apple, you can opt out by choosing the “limit ad
tracking” option in the privacy settings. On Google Android, you can opt out by choosing
the “Opt out of interest based ads.” Advertising IDs are non-permanent, non-personal
identifiers uniquely associated with your device. Similar technologies include tracking
pixels within ads. These technologies allow companies (including marketers and
advertisers) to recognize your device when you use websites and applications.
“Device identifier / information” means device type, device model, device manufacturer,
device operating system and language, or other technical data like screen size,
processor, or a combination of this data, available from a device for a developer to check the
device’s compatibility with a particular application.
Some of this information may be collected using cookies and/or similar technologies (such
as ” software development kits, or “SDKs”), as explained in the
“Cookies and similar tracking technology in websites” section below.
1.3 Information we obtain from third party sources
(a) Information from social media platforms. You may choose to connect to our
Services via your social media account. The exact information we receive from you will
depend on your social media privacy settings, but it will typically include your basic
public profile information, such as:
• your username
• profile picture
• age range
• gender
• your friends playing the same Game
Typical uses include updating game progress on multiple devices you may own so that
you can continue your progress using multiple devices. In addition, we may show your
Facebook friends in the Game and show your public Facebook profile name and picture
in Game leaderboards and in your Game profile.
(b) Third party service providers. We may receive personal information about you
from third-party sources. We may get your personal information, for example, when you
installed our Game or when, prior to installation, you click on an advertisement for the
Game (see “Third Parties” section below for further detail).
(c) Advertising partners. From time to time, we may also receive personal information
about you from other third-party sources. For example, if you clicked on an
advertisement directing you to one of our Services (such as an ad for one of our Games
in another publishers’ game), we will be provided with information about which ad
network and advertising campaign the install originated from (See also “Advertising”
below).
1.4 No special categories of information
We do not request or intend to collect any “special categories of information” such as
any information on health, race, religion, political opinions or philosophical beliefs,
sexual preferences or orientation. Please, be cautious when sharing this information
about yourself (or others) in our forums.
2. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the following
purposes:
2.1 To provide and operate our Services:
• To create user accounts/profiles to enable you to play our Games
• To provide you with the correct versions of our games and/or applications (e.g.
knowing which language to make our games available to you in)
• To enable you to communicate with other users (including via chat rooms, forums
and/or private messages) and leaderboards local to you
• To send you service-related communications including confirmations, technical
notices, updates, security alerts, and support/administrative messages
2.2 To improve our Services and keep them secure:
• To respond to your customer support requests (e.g. if you write to us with a
complaint)
• To receive error messages about any issues you/your device encounters with our
Services to enable us to fix bugs and interoperability issues
• To detect and prevent illegal activities (e.g. hacking or cheating)
• To track game installs (for purposes of measuring the effectiveness of marketing
campaigns).
• To conduct optional user feedback surveys
• To understand you, your preferences and user traffic to enhance your experience
and enjoyment using our Game
• To conduct research
2.3 To personalize our Services:
• To remember you next time you visit one of our Services
• Communicate with you about promotions, rewards, upcoming events, and other
news about products and services we offer
2.4 For promotional activities (including marketing and advertising)
• To provide you with in-game offers and rewards based on your in-game behaviors
• To serve you with relevant targeted advertisements (necessary to fund our Services)
• To make you offers to purchase in-game items on discount based on your ingame
activity and purchase history.
• To send you marketing communications and/or newsletters about rewards and
promotions if you have subscribed to them
2.5 Other
• To comply with our legal obligations
• To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
• To prevent and/or detect fraud or fraudulent behavior
3. ADVERTISING
3.1 We use advertising to fund our Services and to make our games available for free.
We show third-party advertising in our Games and also advertise our Services via third
parties. We want to provide you with more detail about how we use information for
advertising, both in our properties and in third-party properties. When you view ads
in Playlithium properties(e.g. in our games)
3.2 To enable us to show in-game ads, we may send your advertising ID and IP
address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you
in our Games and on third-party properties. You can control and limit our use of your advertising
ID in your device settings. Playlithium does not control which specific ads are shown in
our games (this is controlled by ad networks), but we do prohibit certain types of ads.
3.3. Advertising IDs are used by ad networks for a number of purposes (please refer
to the Privacy Notices of our advertising partners listed herein as “Third Parties”) including, for
example, to:
(a) limit the number of times you see the same ad
(b) ensure they are dealing with humans with real devices and not automated “bots”
(c) to serve you with advertisements likely to be relevant to you based on your advertising
ID, your engagement with other brands and ads which is recorded using your advertising
ID, and to use your general geographic area.
(d) Other brands buy ad placements via an ad network or ad exchange to advertise their
products in Playlithium Games. The ad network or ad exchange acts as intermediary between the
other game companies and Playlithium. In order for an ad network to charge the company
purchasing the ad, clicks from the ad and potential installs of other developers’ apps are
tracked. Views, clicks and installs from ads are measured using the Advertising ID.
(e) Ad networks track which games you have used to market you similar kind of games.
Your IP address is typically used by advertisers to identify your general geographic location,
for example, your country, state and, sometimes, your city).
When you view Playlithium ads on third-party services
3.4 Playlithium also advertises its games on other apps by asking ad networks to place
ads for audiences that will be interested in them (determined using Advertising IDs).
3.5 Ad networks use Advertising IDs for this and other purposes (please refer to the
Privacy Notices of our advertising partners listed as “Third Parties”) including, for
example, to:
(a) Measure ad effectiveness (looking at total views, clicks and installs generated by
its advertising in other publishers’ games);
(b) Inform players that have not played for a while about new content in the Game.
Playlithium gives a list of these users in the form of Advertising IDs to an ad network.
The ad network then shows these users ads about the new content.
(c) Not display ads for a game a player is already playing. Playlithium may send a
list of active players in the form of Advertising IDs to an ad network. The ad network then
excludes these players from seeing the ad.
(d) Market games to a group of potential players. Playlithium provides Facebook a
list of Advertising IDs to match them with similar type of Facebook users to whom
Playlithium could then market its games. Playlithium does not have information on how
Facebook identifies or creates profiles of similar type of users.
3.6 You can opt out of interest-based advertising on mobile applications by changing
the privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out
of interest-based ads” (Android).
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN WEBSITES
The Services may use “cookies” and other technologies such as pixel tags, local shared
objects, hardware-based device identifiers, flash cookies, operating system-based
identifiers, clear GIFs and web beacons.
Cookies: A “cookie” is a small file your browsers stores when told to do so by a website.
Typically, websites place a number of different cookies on an end-user’s device. Some
are “First-party” cookies,’ i.e. from the website itself, and others are “Third-party”
cookies, meaning they belong to advertising and analytics entities or social networks.
Cookies are personal information. However, Playlithium’s cookies do not include any
other personal information and are typically used to quickly identify your device and to
“remember” your device during subsequent visits for purposes of functionality,
preferences, and website performance. You can disable cookies on your device or set
your device to alert you when cookies are being sent to your device; however, disabling
cookies may affect your ability to use the Services.
5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above 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 need
the personal information to perform a contract with you, (ii) the processing is in our
legitimate interests and not superseded by your rights, or (iii) we have your consent to
do so.
(a) Under our terms of service, “performance of contract” as a legal basis for processing
your information refers to when we make the Game and Services available to you,
provide customer support, integrate Games with technology and distribution platforms
such as Apple iOS and Google Android, and inform you of service-related changes and
Game progress.
(b) We process your personal data on the basis of our legitimate interests for example
when we provide you the Game and Game events, serve interest based advertisements
to you (both in-game and on third-party properties), carry out marketing, keep our
games secure, for engineering purposes, analyzing the users’ behavior across our
Games, moderating chat discussion.
(c) We have a “legal obligation” to process your personal data when complying with a
legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal information to comply with a legal requirement or
to perform a contract with you, we will make this clear at the relevant time and advise
you whether the provision of your personal information is mandatory or not (as well as
of the possible consequences if you do not provide your personal information).
If you have questions about, or require, further information concerning the legal basis
for collecting and using your personal information, please contact us using the contact
information provided in the “How To Contact Us” section below.
6. WHO DOES Playlithium SHARE MY PERSONAL INFORMATION WITH?
We may share your personal information with the following types of recipients:
(a) With companies in our business group, third-party service providers and partners
who provide data processing services to us (for example, to support the delivery of,
provide functionality on, or help enhance the security of our Services), or parties that
otherwise process personal information for the purposes described in this Privacy
Notice or communicated to you when we collect your personal information.
(b) With any competent law enforcement body, regulatory authority, government
agency, court of law or other third party where we believe disclosure is necessary (i)
as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal
rights, or (iii) to protect your vital interests or those of any other person
(c) With a potential or actual buyer (and its agents and advisers) in connection with
any proposed or actual purchase, merger or acquisition of any part of our business,
provided that we inform the buyer it must use your personal information solely for the
purposes disclosed in this Privacy Notice
(d) With any other person, with your consent for such disclosure.
7. HOW DOES Playlithium KEEP MY PERSONAL INFORMATION SECURE?
We use appropriate technical and organizational measures designed to protect the
personal information that we collect about you and process. The measures we adopt
are designed to provide a level of security appropriate for the degree of risk involved
with processing your personal information. Specific measures include encrypting your
personal information in transit and at rest.
8. INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than
the country of which you are a resident. These countries may have data protection laws
that are different from the laws of your country.
Specifically, our Game servers are currently located in the United States, and our
business group members, third-party service providers and partners operate around the
world. This means that when we collect your personal information we may process it in
any of these countries. However, we ensure appropriate safeguards are in place so that
your personal information will remain protected in accordance with this Privacy Notice.
This includes complying with the European Commission’s Standard Contractual
Clauses for transfers of personal information among companies in our business group
and third-party service providers and partners, which require all members of our
business group to protect the personal information they process from the EEA in
accordance with European Union data protection law. It also includes the transfer of
personal information to third-party service providers and partners that are certified under
the EU-US Privacy Shield.
The Standard Contractual Clauses can be provided on request. We have implemented
similar appropriate safeguards with our third-party service providers, and partners and
further details can be provided upon request.
9. DATA RETENTION
We retain personal information we collect from you where we have an ongoing
legitimate business need to do so. For example, to provide you with a Service you have
requested, or to comply with applicable legal, tax or accounting requirements. For
example, we periodically de-identify unused Game accounts and regularly review and
de-identify unnecessary personal information.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or de-identify it, or, if this is not possible – for example,
because your personal information has been stored on a backup server – then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
10. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(a) To access, correct, update or request deletion of your personal information. You
may do so by contacting us using the information in the “How To Contact Us” section
below.
(b) To object to the processing of your personal information (which is processed on
the grounds of legitimate interests), ask us to restrict processing of your personal
information or request portability of your personal information. Again, you may do so
by opting out of personalized offers based on in-game behavior, or by contacting us
using the information in the “How To Contact Us” section below.
(c) To opt out of marketing communications we send you, at any time.You can
exercise this right by clicking on the “unsubscribe/opt out” link in the marketing
communications we send you or by contacting us using the information in the “How To
Contact Us” section below.
(d) If we are processing 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 the processing of
your personal information conducted pursuant to lawful processing grounds other than
consent. You may do so by contacting us using the details at “How To Contact Us”
heading below.
(e) You have the right to file a complaint with a data protection authority about our
collection and use of your personal information. For more information, please contact
your local data protection authority.
You can control and limit the type of personal information we collect and process about
you in a number of ways. For example, you can disconnect your social media
account(s) from our games or control your social media privacy settings to limit the
information shared with us. You can also reset your mobile advertising identifier or limit
ad tracking altogether using the settings on your phone. You can also limit or disable the
use of cookies (or similar technologies).
We will respond to all requests we receive from individuals wishing to exercise their data
protection rights in accordance with applicable data protection laws.
11. AGE LIMIT
When we collect personal information we do not know the age of our players. If a player
has a Facebook account and has logged into a game, we obtain the age information
from the player’s Facebook profile. If we discover we has inadvertently gathered
personal information from a minor under 13 years of age, we will take reasonable
measures to promptly delete such personal information from our records.
12. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in response to changing legal,
technical or business developments. When we update our Privacy Notice, we will take
appropriate measures to inform you, in accordance with the significance of the changes
we make.
13. HOW TO CONTACT US
Data controller: Playlithium Interactive, LLC,
401 Ryland St STE 200-A, Reno, Nevada, USA. Email: privacy@Playlithium.com.
Please note that other third parties (our data partners) may be data controllers of your
information.