SMART GAME STUDIO Privacy Policy

Effective Date: August 16, 2018

INTRODUCTION

This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We are SMART GAME STUDIO, (“SMART GAME STUDIO” or “we”, "our" or "us"), a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”), and websites we control, including smartgamestudio.io (“Website”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

1. INFORMATION AND DATA WE COLLECT FROM YOU

When you use our Services, you may give us your contact information directly on our website, generally your name and email address. We also collect certain information and data, such as your application usage, access, session times and in-app purchases, your unique device ID, hardware type, the version of your operating system (“OS”), your device name, your name, email address and cover photos (if you have connected to Facebook or Google+), and your general (city/country) location (based on your Internet Protocol (“IP”) address).

In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your profile information to track our Games you are playing. We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

We may collect non-personal information about you through our Service. Such information may include your operating system type and version, and the time and date of your visit to the Service.

We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

2. HOW WE USE YOUR INFORMATION

2.1 In General

We use the information we collect about you/your device to deliver services and our Games to you and to operate our business. We use it also for improving our services and Games, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Games in our Games and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations. We use your information for the following purposes:

2.2 In-App Purchases

Our Games enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your App Store account or Google Play account. Any post-purchase processes are controlled by the Apple and Google stores and are subject to specific terms of such Apple and Google stores. Please review privacy policy and terms of service of your Apple and Google stores.

3. LEGAL BASES

If you are located in the EU/EEA, the legal bases for using your information as set out in this Privacy Policy are as follows:

4. DATA SHARING

We will not share your personal information outside SMART GAME STUDIO except in limited circumstances, including: When you allow us to share your personal information with another company, such as: Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services Directing us to share your personal information with third-party sites or platforms, such as social networking sites Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices. When companies perform services on our behalf, like package delivery and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law When we share personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

5. YOUR CONTROLS AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices may include:

Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences.

If you have questions regarding the specific personal information about you that we process or retain, please contact us at games@bap.jp.

6. USE OF YOUR INFORMATION BY OTHERS

Our Services may contain third party tracking and data collection and analytics tools from some service providers such as Tenjin and GameAnalytics. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device related data and information on our behalf. To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads to you

The privacy policies of these service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices. If you have any questions about how these third parties use your information, you should review their policies and contact them directly. Below is the list of third party services that we may use :

7. CHILDREN's PRIVACY

Our Service does not address anyone under the age of 13 (“Children”). When we collect personal information, we do not know the age of our players. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible.

8. INTERNATIONAL TRANSFER

We operate globally and may transfer your personal information to individual companies of SMART GAME STUDIO or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we abide by the Safe Harbor Principles as set forth by the U.S.Department of Commerce, use standard contract clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of the Safe Harbor Principles when transferring personal information from Australia.

9. DATA RETENTION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

10. SECURITY OF YOUR INFORMATION

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases contain encrypted and anonymised information only, are password protected and limited to essential employees only. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. CHANGES TO OUR PRIVACY POLICY

We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if SMART GAME STUDIO needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

12. CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us at games@bap.jp. All other inquiries should be directed to SMART GAME STUDIO 's Support Page. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

Copyright © 2018 SmartGameStudio.