EFFECTIVE JANUARY 26, 2019
Our Policy applies to all users and others who access the Service (“Users“).
For purposes of data protection laws, Fun and Games, LLC is the “data controller” of any information collected for the purpose of providing you with the best game experience possible.
We may collect and store any information that you provide to us, such as when you create your account or a player profile.
Some parts of our Services may use an account set-up process where you may be asked to give us information such as:
- a username;
- your e-mail address;
- a password; and/or
- other information that helps us make sure it’s you accessing your account or helps us improve our services.
We may also let you create a player profile that other players in our network can see. Your player profile may include information like:
- your profile photo;
- your first and last name;
- your game username; and/or
- your biographic details that you choose to provide
We may collect information that you provide to us about your contacts, but make sure you ask their permission first.
We may give you the ability to import your address book contacts or to manually enter them so that you can locate your contacts and invite them to join you in our games or other aspects of our Services. You are responsible for getting permission from these persons before you give their contact details to us. We may also get information about you from other Fun and Games, LLC players importing or entering their contacts. We use and may store this contact information to help you and your contacts connect through our Services. If you want to remove your contacts stored by us, contact us via email. If you need to enter a password to allow us to access your address book, we will not store that password.
When you use our Services, we may collect information about the ways in which you use and interact with our Services, such as when and for how long you play our games, virtual items you add to your game inventory, features and other players you interact with, purchases you make, and other gameplay activities.
If you choose to use communication features in our Services that allow you to communicate or share information with other players, then we may temporarily collect information on what is communicated or shared. This may include messages or chats made to other players, whether public or privately through in-game features; it includes any other content generated by you as the user shared with any other users. We may access in real-time, record, and/or store archives of these communications, comments, photos, drawings, and other user-generated content to make use of them to protect the safety and well-being of our players; to protect Fun and Games, LLC’s rights and property in connection with our Services to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this. However, Fun and Games, LLC is not obligated to store or make available to the player any content that may have been generated or shared within your use of our Services.
We may collect information related to any purchases you make.
We may maintain a record of any communications between us in order to provide better customer support and improve your experience.
When you contact F&G, we may collect and store the contact information you provide (such as your name and e-mail address), information about your game play or activity on our Services, and your player and/or social network ID number. We may collect some information from other companies, such as social networks, if you access our games through your accounts with those companies or you choose to associate your accounts with those companies to our services.
Better Letters and other parts of the Service do use third party services that may collect information used to identify you.
We may employ third-party companies and individuals due to the following reasons:
- To facilitate our Service;
- To provide the Service on our behalf;
- To perform Service-related services; or
- To assist us in analyzing how our Service is used.
We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
Additionally, in order to improve the technical performance of our services, we may collect other technical information about your device and how you use our Services, including:
- the type of mobile device you use;
- platform type (such as Apple iOS or Android);
- The operating system version;
- your mobile device’s identifiers, such as your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
- application performance and de-bugging information;
- referring and exit pages, and URLs;
- the number of clicks on a feature in an app;
- the amount of time spent on a given feature within an app; and/or
- game state and the date and time of activity on our Services.
- the name you have associated with your device;
- your country;
- your telephone number (if you provide it); and/or
- your mobile contacts (with your permission).
We may collect or receive information about you from other sources such as third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.
Fun and Games, LLC expects to collect and use the information described above to provide, secure, and improve the Services you use; to maintain our business operations; and to exercise, defend or establish our rights.
We collect, maintain, and use this information under several legal bases, including to perform our contract with you, for our legitimate business interests, to comply with our legal obligations, or otherwise with your consent.
The primary reason we collect the information we store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well, such as:
- to improve and optimize our Services and our players’ experiences;
- to create your game accounts and allow you to play our games;
- to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
- to enable players to communicate with each other;
- to provide technical support;
- to protect our players and keep them safe as reasonably practicable;
- to protect our rights, property, and interests in connection with our Services;
- to prevent potentially illegal activities;
- to enforce our Terms of Service;
- to work with third party providers to manage and deliver advertising;
- 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; and/or
- to conduct research.
If you are in a location that is subject to the jurisdiction of the General Data Protection Regulation, our legal basis for collecting and using the information laid out above depends on the type and context of the information being collected.
However, we typically collect information from you only where we need it to perform our contract with you (i.e., our Terms of Service), where the processing is in our legitimate interests (unless such interests are overridden by your rights), or if we otherwise obtained your consent.
In some cases, we may also have a legal requirement or need to collect information from you to protect your vital interests or those of another person (for example, another player).
If we ask you to provide information to comply with a legal obligation or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information, and, if not, we will provide an explanation to you at that time.
If we collect and use your information based on our legitimate interests, it will be made clear to you at the relevant time what those legitimate interests are.
If you have questions or need further information about the legal bases on which we collect and use your personal information, please contact us.
Some situations will arise where we may share certain information about you with third parties when you use our Services, including:
- with your friends and other players that you’re playing with to enhance your gaming interactions with them.
- with third parties or allow third parties to collect this information from our Services in instances such as:
Playing with Friends – If you play through a social network or connect to a social network such as Facebook, your social network friends who also play a F&G game may see your name, photo, player profile, and descriptions of your in-game activity.
In addition, other players outside of your social network connections may be able to see your player profile (as described above); view descriptions of your in-game activity; communicate with you within our Services; and send you game requests or friend requests through our Services.
We may share some of your information with advertisers to manage the advertisements you may see in our games and to enable us to provide some of our Services for free. Some advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task in the game. Offer walls are hosted by third-party offer wall providers, and the offers are made and managed by third-party advertisers, not by us.
Fun and Games will not share personal information that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.
To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:
- performance data (like the number of clicks on an advertisement);
- certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
- a unique identifier, such as your social network ID; and/or
- other contextual data about your game play.
In addition to serving you with relevant ads, the information collected may be used to:
- measure ad effectiveness;
- offer you targeted advertising by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
- undertake analytics to analyze traffic and other player activity to improve your experience.
Of note: after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Fun and Games, LLC, or the social network through which you are playing our games.
If you do not want to receive tailored in-application advertisements from third parties, please contact us. Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies.
SAFETY, SECURITY, AND COMPLIANCE WITH LAW
We’ll share your information if necessary for safety, security, or compliance with law.
Your information, and the contents of all of your online communications in our Services and between you and F&G may be accessed and monitored as needed to provide our Service and may be disclosed:
- to satisfy any laws or regulations that apply;
- when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
- when we believe in our sole discretion that our Services are being used in committing a crime, including to report such 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; and/or
- to protect the rights or property of F&G or applicable third parties, including to enforce our Terms of Service.
THIRD PARTY SERVICE PROVIDERS
We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services.
We will share your information with third-party companies who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, Amazon, etc.). Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).
Sale or Merger
We’ll share your information with the interested party if we undergo or evaluate undergoing a sale or merger.
In the event that F&G undergoes or evaluates undergoing a business transition, like a merger, acquisition by another company, or sale of all or part of its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know of the business transition before transferring your personal information.
Other Third Parties
We may share some of your information with other third parties if we have your consent to do so.
Accessing and Deleting Personal Information Held by F&G
To review and update personal information associated with your F&G player profile in certain games, visit the “settings” page in that game.
If you want to review or delete personal information associated with your game account data, contact us.
For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We’ll also keep information in order to exercise, defend, or establish our rights.
Managing Personal Information We Receive From Third-Party Applications / Platforms And From Your Mobile Device
To manage the information we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by the third-party application and your mobile device.
To manage the information F&G receives about you from a third-party application or platform where you play our games, like Facebook, Apple, Google, or Amazon, you will need to follow the third-party application’s instructions for updating your information and changing your privacy settings.
You also can manage many aspects of information collection and use from your mobile device by visiting the “settings” page of your mobile device or web browser and reviewing the access permissions of each F&G game / application.
To the extent that one of our games is collecting information about non-F&G applications you have on your mobile device, the game will provide you with an option to stop making that information available to us in the game’s “settings” page.
Opting Out of Promotional Communications from F&G
You can opt out of mobile push notifications in your device’s settings page.
If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our games also offer the ability to turn off push notifications in the in-game “settings” page.
Opting Out of Third-Party Behavioral Advertising
You can opt out of third-party behavioral advertising through your device settings and other third-party opt-out tools.
PRIVACY POLICIES OF LINKED THIRD-PARTY SERVICES AND ADVERTISERS
We aren’t responsible for the ways in which third parties use your information (other than our service providers acting under our instructions).
Our websites and games may contain advertisements from “Third-Party Services,” meaning companies other than F&G, 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-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.
OUR POLICIES CONCERNING CHILDREN
We seek to ensure that we do not collect information from children.
Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.
If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.
HOW LONG WE KEEP YOUR INFORMATION
We’ll keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights.
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.
We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
SECURITY OF YOUR INFORMATION
We work hard to protect your information but you also have a role to play.
If you have an account registered directly with F&G, your profile information is protected by the password you use to access your F&G account. It is important that you protect and maintain your F&G account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your F&G account, the Services allow you to request that instructions be sent to you that explain how to reset your password. If you access our Services through a social network and your social network account is hacked or otherwise compromised, this may lead to someone accessing or deleting your F&G game accounts without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well. We urge you to log out of your F&G account and any social network account you have used to access our Services when you are finished using them.
When you sign into your F&G account or enter payment information, we and our third-party payment processor use encryption to transmit that information.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and 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.