PRIVACY POLICY

LAST UPDATED: April 15, 2021

I. INTRODUCTION

Puzzle Studio provides this Privacy Policy to explain how it collects, stores, and uses the information collected in connection with Puzzle Studio’s software applications, and websites (collectively, “services”). Puzzle Studio respects the privacy of their users and is committed to protecting the user’s information. You have a right to know our practices regarding the information we may collect and use when you use our services.

We will periodically update this privacy policy to reflect changes in our information practices, and to add additional third party operators. Please check back regularly, as your continued use of our services indicate your acceptance of any changes to this policy.

II. THE TYPES OF INFORMATION WE COLLECT

Most of the information we collect come directly from our user when they play our apps, interact with third party ads in our apps or with our ads in other publisher’s apps. These information are collected through SDKs (Software Development Kits) from third party app like Tenjin, Admob, Google Analytics integrated in our apps. In general, these SDKs are used for advertising to our users, analyze service usage, enabling in-app purchases, or providing game services like achievements and leaderboards. We allow third party operators this collected solely for internal operations of the service as permitted by applicable rules and laws. This could include, but is not limited to, persistent advertising identifiers, geolocation information, and IP address. We encourage you to review the policies of the third party operators listed below.

A. TECHNICAL INFORMATION

We collect technical information about your device that is necessary for you to use our apps and additional technical data that enables us to analyze the function of the apps. Those information includes the type of device(s) you are using to use our apps, browser type, screen resolution, language, type of operating system and geo location (only general location).

B. ADVERTISING AND APPLICATION USAGE INFORMATION

We collect information on how you use our apps, how you interact with third party ads that are shown to you in our apps and how you interact with our ads in other publisher’s apps using persistent advertising identifiers that permit identification of your device. Those information is used to deliver personalized ads to our users, improve our services and analytics purposes.

C. CLASSICAL PERSONAL INFORMATION

We do not collect classical personal information through our apps such as name, address, email, phone number. Our user can use our apps without providing us with provide classical personal information. Should a user explicitly provide it to us when prompted, we will collect email addresses of our users for our mailing list(s) and respond to your inquiries.

D. SERVICE SPECIFIC INFORMATION

Some of the services Puzzle Studio provides allow our users to send messages to each other while playing a game. These messages are then transmitted and store on Puzzle Studio controlled servers. In order to support some services, Puzzle Studio may collect identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle. Additionally, we may also use a user’s profile picture from social networks or game services, but this will stay on the device and will not be transmitted to us.

III. HOW WE USE THE INFORMATION WE COLLECT

Advertisers collect data regarding advertisement performance, user’s interaction with ads, our apps and user’s interests. Collected data may include user’s personal information in order to serve users ads and for the third parties’ legitimate business interests. Puzzle Studio collects persistent identifiers in order to provide support for our services to our users. Additionally, Puzzle Studio uses persistent identifiers to send promotions regarding new products or updates to our users. If we keep track of persistent advertising identifiers, it allows us to only notify these users about new products that they will actually be interested in. We collect email addresses in many of our services so that we can notify interested users of upcoming releases and updates of our products and services. These emails always include a way to unsubscribe from receiving future emails. When a service asks for a username, it is used to visually identify that user to other users playing the game. Puzzle Studio prohibits any user under the age of 13 from providing individually identifiable information in their username or screen name. This includes, but is not limited to the user’s first name, last name, email address, and physical address.

Third party operators are allowed to collect and use non-personal information to conduct research and analysis, or to target advertisements, or other limited purposes. This information cannot be user to individually identify any user. We encourage you to review the policies of the third party operators listed below. Similarly, Puzzle Studio also uses non-personal information to conduct research and analysis. We do this to improve our services in future updates or to gain knowledge about how our users our interacting with the service.

Each of our games that allow messaging other users provide an option for joining or creating publicly visible worlds/matches, or for playing only against other users known to the current user. Puzzle Studio prohibits any user under the age of 13 from joining or creating publicly visible worlds/matches in these services. Additionally, Puzzle Studio prohibits any user under the age of 13 from sharing personal or individually identifiable information while using the messaging functionality in these services. If Puzzle Studio collects identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle, then it is explicitly required for some feature in that service. For example, the identifier could be saved so that a user’s connections on the social network can see their high score or progress in the game. As stated elsewhere in this policy, you can contact us to have this information deleted for yourself or your child under the age of 13.

IV. HOW WE MAY DISCLOSE YOUR INFORMATION TO THIRD PARTIES

Puzzle Studio may share information we collect or derive with third parties for the following purposes:

1. With service providers that perform services on our behalf, including the ones referenced above under “Third Party Services”;

2. With our affiliates;

3. For analytics and research purposes;

4. In response to subpoenas, court orders, or other legal processes;

5. To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;

6. As part of a business transfer such as a merger, acquisition, or at bankruptcy

7. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties;

8. We may use analytics services provided by third parties, including Google Analytics ,Tenjin, AppFigures. These service providers may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes.

V. THIRD PARTY ADVERTISING COMPANIES

We follow generally accepted industry standards and internal procedures to protect personal information submitted to us, both during transmission and once we receive it.

Third-party Operators

1. Advertising Networks: Puzzle Studio allows advertisements from the Third Party ad networks to be displayed in our services. Puzzle Studio makes commercially reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws, and we reasonably believe this to be the case for each of them. Additionally, if we determine a service to be directed at children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA).

2. In-App Purchases: In order to make an in-app purchases, a user must use a third party checkout options that we have integrated with our services to finalize and pay for their order. The third party operator’s privacy policy and security practices will apply to this process a user’s information. We encourage you to read that privacy statement before providing your information.

3. Social Networks: Some of our services integrate a third-party social network such as Facebook or Twitter to allow sharing progress with friends, or allowing them to be invited to use our service. The privacy policy of each social network will indicate what data is available to us and how we use it.

4. Game Services: Many of our services integrate either Apple Game Center, Google Play Game Services, or Amazon Game Circle. Each of these third-party operators offer their own privacy policy (listed below), and we encourage you to review them.

EXTERNAL PRIVACY POLICIES

Apple, iAd, Game Center

http://www.apple.com/legal/privacy/en-ww/contact

http://www.apple.com/privacy/privacy-policy

AdColony

AppLovin

Chartboost

https://answers.chartboost.com/hc/en-us/articles/200780269-Privacy-Policy

Facebook, Inc.

https://www.facebook.com/help/contact/861937627253138

https://www.facebook.com/policy.php

Flurry

Yahoo! Inc.

https://policies.yahoo.com/us/en/yahoo/privacy/index.htm

Google Play, AdMob, Google Play Game Services, Google Anayltics, Firebase Analytics

https://support.google.com/policies/troubleshooter/2990837?hl=en

https://play.google.com/about/play-terms.html

https://www.google.com/intl/en/policies/privacy

UnityAds

https://unity3d.com/legal/privacy-policy

Vungle

Appsflyer

https://www.appsflyer.com/privacy-policy

Tenjin

https://www.tenjin.io/privacy

ironSource

VI. DATA SUBJECT RIGHTS

This section further describe your certain rights with respect to your information.

A. YOUR LEGAL RIGHTS

If you would like further information about your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time.

With regard to Puzzle Studio’s Services, under the EU’s General Data Protection Regulation (GDPR), we are the data controller. Puzzle Studio recognizes your right of access under Article 15 of GDPR. If you are a user of Puzzle Studio and wish to exercise your right of access, please contact us directly with the email we provided below.

Puzzle Studio also recognizes the Right to Erasure under Article 17 of GDPR. For erasure requests, please contact us directly with the email we provided below.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

If you no longer want us to use your information, contact us at hello@puzzle.sg. Place “Delete My Account” in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within the time period stated by applicable law. However, please note that if you make such a request, you may no longer be able to play such app or use our Services.

B. OUR POLICY REGARDING CHILDREN

We understand the importance of protecting the privacy and safety of children using our services, as outlined by the Children’s Online Privacy Protection Act of 1998 (COPPA). Accordingly, we do not knowingly collect, use, or disclose personal information from children under 13.

When we determine that a service is directed and children under the age of 13, we will configure all of our internal systems such that no personal information will be collected, and configure all relevant third-party integrations appropriately such that no personal information will be collected for users of that service. For additional information, please refer to the privacy policies of our third party operators to understand what they are doing to further protect your child’s privacy.

Services that are determined to be targeted at children will still receive advertisements from our third-party operators, and promotions from Puzzle Studio using its internal systems. In this case the ads and promotions will not be targeted at specifically for users, but will be broadcast to all users of the service.

If you are a parent of a child under 13 years of age and you believe your child has provided us with personal information, please contact us using the information below and we will delete the information from our systems.

C. DISCLOSURE OF PERSONAL INFORMATION

The scenarios in which we will share your personal data are as follows:

We determine that it is required by law;

We have a good faith belief it is necessary to protect our rights or property;

We are participating in a merger, acquisition, liquidation, dissolution or sale of assets;

We have your consent; and

As described above in relation third-party operators collecting information from our services.

Under no other circumstances will Puzzle Studio share, sell, rent, or release your data.

VII. CONTACT US

If you have any questions about our privacy policy, please contact us via email at hello@puzzle.sg