FingerLegend Games Privacy Policy

Effective date: Aug 28th, 2020.

FingerLegend Games publishes applications for the mobile devices. Our apps, in most cases, are a free to play games (with optional in-app purchases), and in order to maintain the high quality and great user experience we process information from and about you in particular to improve the entire experience in the apps and to support our internal operations. FingerLegend Games respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR"). We recognize that privacy is an important issue, so we design and operate our services with the protection of your privacy in mind. This Privacy Policy explains how we protect your information and the security of your information in relation to our mobile services. This Privacy Policy applies whenever you play our apps or otherwise access any of our other products. By using any Service, including when you play or access Services through social networks or mobile devices, you agree to the collection and use of your information as set forth in this Privacy Policy and our Terms of Use. If you do not want FingerLegend Games to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play FingerLegend Games™s apps or use FingerLegend Games™s Services. This Privacy Policy describes:

• Information we collect and how we collect it;
• How we use the information we collect;
• Legal bases for use of your information;
• How we share and disclose your information;
• Data subject rights and your choices;
• California online privacy protection act notice;
• Privacy policies of linked third party services and advertisers;
• Policies Concerning Children;
• How long we keep your information;
• Security of your information;
• California privacy rights;
• Changes to our Privacy Policy;
• How to contact us. Information We Collect and How We Collect It The information we collect about you falls into two categories: information you provide directly to us, and information we collect automatically.

1. Information about You That You Share with Us Directly When you use our apps, you can provide us information directly. We will store the information you provide us directly on our systems and use it for the purposes described in this Privacy Policy. (1). Account and Profile Information Some apps or parts of our Services use a registration or account set-up process where you will be asked to give us certain information, including:

• A nick name to be used in the game
• (2). Payment Information If you make a purchase in our Services, such as purchasing in-app virtual currency or virtual items in an app you play, our third party payment processor will collect the billing and financial information to process your charges. FingerLegend Games does not collect or store your financial information. However, FingerLegend Games™s payment processors may share non-financial information with us related to your purchases, like transaction information, transaction ID, the items purchased and value in order to fulfill your order. Please note that purchases of third party credits or currencies may also be subject to those parties™ policies. 
• (3). Customer Support Correspondence When you contact our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address). In order to solve the problem you encountered, we may need you provide further information (such as your device type, system version, your network type). We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support.

2. Information We Collect Automatically Tracking Technologies We, and service providers acting on our behalf, like Unity Analytics, store log files and use tracking technologies such as:

• Device identifiers such as the IDFA on mobile devices;
• Login time;
• Login count. We and our service providers use these technologies to collect and analyze certain kinds of technical information, such as:
• Your mobile device™s identifiers, such as your identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• Your system language. Please note that companies delivering advertisements on our Services may also use other technologies as described below in - Third Party Advertising and Analytics, and those practices are subject to those companies™ own policies. How We Use the Information We Collect We, or our service providers, primarily use the information we collect and store to understand users™ needs and improve the experience, but we will also use that information for other purposes, including:
• To keep internal record;
• To personalize our Services for you;
• To provide technical support and respond to player inquiries;
• To protect the safety and well-being of our players;
• To protect user's rights and property in connection with our Services;
• To prevent fraud or potentially illegal activities;
• To enforce our Terms of Use;
• To manage and deliver contextual and behavioral advertising;
• To notify players of in-app updates, new products or promotional offers;
• To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• To comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties;
• To conduct research. Legal Bases for Use of Your Information 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:
• Where use of your information is necessary to perform our obligations under a contract with you (œContractual Necessity);
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (œLegitimate Interests), for example, to provide security for our Services; to make and receive payments; to comply with legal requirements and defend our legal rights; to prevent fraud and to know the customer to whom we are providing Services;
• Where we need to comply with a legal or regulatory obligation (œCompliance with Law);
• Where we have obtained your prior consent (œConsent). How We Share and Disclose Your Information We will share your information (which may include personal information) with third parties or allow third parties to collect this information from our Services in the following circumstances:

1. Aggregated/Anonymous Information We also collect, use and share œAggregated/Anonymous Data such as statistical or demographic data for any purpose. These kinds of Data may be derived from your Personal Data, but once in aggregated/anonymous form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data and Technical Data to calculate the percentage of users accessing a specific app feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
2. Third Party Advertising and Analytics We allow advertising on our Services. The third parties (e.g., ad network and ad servers) may serve tailored ads to you in our apps, and to access their own cookies or tracking technologies on your mobile device, or other device you use to access the Services. When advertisers or ad networks place ads in our Services, they may collect or we may share with them and with analytics providers the following types of information from our Services:

• Performance data (like the number of clicks on an advertisement);
• Aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (for example, players between the ages of 29 and 34 who live in Berlin);
• Certain technical information (such as, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
• Your social network ID;
• Other contextual data about your game play (such as, your level and session duration). This information may be used to:
• Measure the effectiveness of advertising and/or
• Show you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising) Advertisers or advertising networks may collect this information by using one of more tracking technologies described above, such as browser cookies and web beacons. Please note, if you click on a third party advertisement, you may no longer be in FingerLegend Games™s apps. We may also use third-party analytics services (such as those of Unity Technologies) on our Services to collect and analyze traffic and player activity to improve your experience; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you.

3. Safety, Security and Compliance with Law Your information, the contents of all of your online communications in our Services, and the communications between you and FingerLegend Games may be accessed and monitored as needed to provide our Service and may be disclosed:

• When we have a good faith belief that we must disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
• To comply with any applicable laws or regulations;
• Where, in our sole discretion, we believe that the Service is being used to commit a crime, including in order to report criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• When we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally;
• To protect the rights or property of FingerLegend Games and other applicable third parties, including to enforce our Terms of Use.

4. Third Party Service Providers We may share information we collect with our third party service providers that perform services on our behalf, including, but not limited to, payment processing, e-mail delivery, hosting services, and customer service. Data Subject Rights and Your Choices You have certain rights with respect to your information as further described in this section.
5. Your Rights in Connection with Your Personal Data Under certain circumstances, by law you may have the right to:

• Request access to your Personal Data;
• Request correction of the Personal Data that we hold about you;
• Request erasure of your Personal Data;
• Object to processing of your Personal Data;
• Request the restriction of processing of your Personal Data;
• Request the transfer of your Personal Data;
• Withdraw consent.

2. How to Exercise Your Rights If you want to exercise any of the rights described above, please contact us using the contact details listed below. Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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 Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data 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. California Online Privacy Protection Act Notice At this time, there is no general agreement on how companies like FingerLegend Games should interpret Do Not Track signals. FingerLegend Games does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. Privacy Policies of Linked Third Party Services and Advertisers Our Services may contain advertisements or other services from third parties, which are companies other than FingerLegend Games that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these third parties, and the collection, use, and disclosure of your information will be subject to the privacy policies of those third parties. If you have any questions about how these third parties use your information, you should review their policies and contact them directly. Please see the links below to learn more about the data practices of our third-party partners that we use or may use:

• Unity3D Technologies
• Policies Concerning Children We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any other personal information, without their parents™ prior permission. We consider a user to be a child if they are under the age of 16, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. We do not direct our Services to children. We also do not intentionally collect personal information from children through our Services. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us as described in the Contact Us section of this policy and we will delete the information from our records. How Long We Keep Your Information 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. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights. Security of Your Information We implement appropriate security measures to protect the security of your information. If you have an account registered directly with FingerLegend Games, your profile information is protected by the password you use to access your FingerLegend Games account. It is important that you protect and maintain your FingerLegend Games account™s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your FingerLegend Games account, the Service allows you to request that instructions be sent to you that explain how to reset your password. We urge you to log out of your FingerLegend Games account you have used to access our Services after you use it. When you sign into your FingerLegend Games account or enter payment information, we or our third party payment processor use secure socket layer technology ("SSL") to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. Although we strive to protect your personal information, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us as described in the Contact Us section of this policy. California Privacy Rights California law permits users who are California residents to request and obtain a list of the third parties to whom we disclose their 'personal information' (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year. However, we do not share personal information (as defined by such law) with third party advertisers for their direct marketing purposes. Changes to Our Privacy Policy We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. You should periodically check this privacy page for updates. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. Your continued use of the Services signifies your acceptance of our Privacy Policy as modified. Contact Us If you have any questions or concerns regarding privacy using FingerLegend Games services, please send a detailed message to: FingerLegend Gamesgamesfeedback@gmail.com. We will make every effort to resolve your concerns.