Last Updated: 1st Jan 2019
Remit of the personal data protection policy
This personal data protection policy is applicable to all of our applications.
What data is collected?
With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications.
- IDFA publicity identifiers (for IOS devices) and GAID (for Android devices)
- Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the publicities we display (for instance, time spent on these, potential clicks)
- Data pertaining to your geographical position (IP address)
This data is collected via external tools (Software Development Kit or « SDK ») implemented by our partners, which are an integral part of the application.
You will find hereafter the list of our partners implementing SDKs through our applications:
- Games Analytics (analytical SDK)
- MixPanel (analytical SDK)
- Oath (SDK advertising)
- Ogury (SDK advertising)
- MoPub (SDK advertising)
- InMobi (SDK advertising)
- AppLovin (SDK advertising)
- Admob (SDK advertising)
- Vidcoin (SDK advertising)
- Vungle (SDK advertising)
- UnityAds (SDK advertising)
- Ironsource (SDK advertising)
- Tapjoy (SDK advertising)
- Adcolony (SDK advertising)
- Facebook Audience Network (SDK advertising)
- Mobvista (SDK advertising)
- Fractionnal (SDK advertising)
- Apponboard (SDK advertising)
- Fyber (SDK advertising)
Purposes of processing UNDERTAKEN by Inkfood Games and legal basis for processing
Data collected by Inkfood Games is used to:
- Provide our applications
- Guarantee use and improvement of our applications
- Develop new applications
- Understand your centers of interests and, thanks to this profiling, propose you targeted and relevant advertisements (SDK advertising),
- Make statistics on your use of the games, including the number of games played, your duration of use or the advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).
- Communicate with you, notably when you contact us by any means whatsoever
Term of data storage
Inkfood Games stores your personal data for a maximum duration of 13 months after collection. Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature whatsoever.
Categories of recipients of data collected
The recipients of the Data are the teams of Inkfood Games that need to have access as well as the partners mentioned above in article 2. We may however share Data collected with our technical service providers for the aforementioned purposes. We stringently request that our partners always act in compliance with Data protection legislation applicable and grant special attention to confidentiality of this Data. By application of the applicable regulation, any sub-contractor who may process this personal data for Inkfood Games undertakes as follows:
- to solely process data for the purpose(s) which is/are sub-contracted,
- to process data in pursuance with Inkfood Games instructions,
- guarantee the security and confidentiality of Data.
Inkfood Games may also disclose/transfer your personal data to third parties in the following particular circumstances:
- by virtue of legislation, as part of legal proceedings, a dispute and/or request issued by the public authorities in your country of residence or otherwise;
- if disclosure is necessary for national security, application of legislation or any other matter of public interest;
- in the event of restructuring, transfer, merger or sale to the third party concerned.
In such instance as your Data is transferred outside of the European Union, we ensure that:
- the personal data is transferred to countries recognised as offering an equivalent level of protection.
- Personal data is transferred via certified entities under the Privacy Shield.
- For personal data transferred outside of countries recognised by the Federal Data Protection and Information Commissioner (FDPIC) as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of template contractual clauses.
Personal data concerning children
Inkfood Games does not knowingly collect any personal data concerning children under 15 years old.
Your rights concerning data collected
If you request, we will provide you a copy of your personal data in an electronic format.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.
We will respond to all requests within a reasonable timeframe.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. This may also affect our Services to you, for example, you may not be able to enter any competitions or make any in game purchases. Please make all requests to firstname.lastname@example.org
If you consider that Inkfood Games has defaulted in respect of its obligations in light of your personal data, at any time you may issue a complaint or make a claim to the competent authorities.
Federal Data Protection and Information Commissioner(FDPIC)
Personal data security
We take all necessary security measures so as to prevent as far as practically possible any alteration or loss of your data or any unauthorised access thereunto.
In such instance as we should be aware of any illegal access to personal data concerning you and corresponding to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if this fulfils a legal requirement.
Updating the present policy
The present policy may be updated at any time, notably pursuant to legal and/or regulatory provisions and/or any recommendations of the Federal Data Protection and Information Commissioner(FDPIC). We hereby invite you to consult this page regularly.