This player’s privacy policy (the “Policy”) applies to personal data that we, hold about our players (“you”, “your”). This Policy is drafted in the English language and will be translated into other languages. The English language version of this Policy shall prevail if there is any conflict or inconsistency that requires clarification.

This Policy deals with where we are acting as a ‘data controller’ under the data protection legislation: which essentially means where we are responsible for deciding what personal data we collect and how we use it. We also may operate as a ‘data processor’, meaning that we are processing personal data on behalf of another entity (for example a publisher of one of our games). When we refer to “Personal Data” we mean “personal” relating to you personally or from which you can be identified. Some of the information mentioned in this Policy is not “Personal Data” as is meant under data protection legislation, but we may refer to it to help you understand what we do.

We are committed to protecting and respecting the personal data of everyone we deal with – that is important to us and we know it is important to you.

In this Policy, you will find information about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find information about your rights and how you may exercise them.

If you are younger than 18 years of age, you must review this Policy with your parent(s) or guardian(s) and they have agreed to these terms on your behalf and take full responsibility for your compliance with them.

Please read this Policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal data, you can reach us by email at smart.futher.tech@gmail.com.

You’ll find in this policy information about the following:

1. What information do we collect about you?

We will collect some information about you. The type of personal data that we collect about you depends on how you use our Services. In general, we collect the following information:

A. Personal data that you provide directly to us:

1. Your contact information such as email address;
2. Your player username and password;
3. Data that you provided to us to verify your account;
4. Other data you choose to provide us such as data to identify a lost or lapsed account or the answer to a special question we may ask you in order to permit you to unlock or recover a lost or lapsed account;
5. Information about your purchase and payment (in addition, exclusively our payment service providers will collect your payment details in connection with any purchases you make through our webstore);
6. Personal data you provide in connection with surveys, promotions, sweepstakes, competitions, campaigns and other events; and
7. Other Personal data that may be collected based on your explicit consent or our legitimate business interest for a specific purpose.

B. Personal data that we collect automatically when you use our Services:

1. Your game profile, including your profile picture and any information needed for the game to function, such as an inventory of in-game items;
2. Your game user account or role ID(s) –specific ID(s) generated by our game server for you;
3. Analytics ID – a randomly generated anonymous identifier used to distinguish activity from one game account versus another in our analytics data;
4. Your internet protocol (IP) address and mobile device identifiers (such as for example your device ID, advertising ID, MAC address, IMEI);
5. Data to fight fraud (such as refund abuse in games or click fraud in advertising);
6. Usage data including information about how you use our website, products, and services, and your game progress;
7. Data about your device, such as device name and operating system, browser type, and language; and
8. Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences and it is at your full own discretion and control to adjust the settings on your device to turn off the function.

3. How we use your information

• To send you communications related to our services and games, answer your enquiries or deal with your complaints;
• Providing, managing, and customising our services including our games;
• Enable you to purchase virtual items and complete the related payment transactions;
• Account verification and clearance;
• Technical and usage information/analytics to help us develop games that our customers want to play and to improve them and to detect cheating and activities that ruin the experience of players using our games, security risks, fraud and other unlawful activity;

4. Legal basis for processing

There are a number of different legal grounds for processing personal data. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:

• You have provided your consent to us using your personal data in that way (for example where you provide us with consent to send you marketing communications about our products and services); and/or
• Our use of your personal data is in our legitimate interest as a commercial organisation provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights; and/or
• Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your account); and/or
• Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation.

We generally do not collect or process any ‘special categories’ of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life, and sexual orientation). If this would apply, we will generally rely on obtaining additional specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.

5. Sharing your information

The personal data you provide to us may be shared with third-party companies, agents, contractors, service providers, or our affiliated companies if this is necessary to provide you with our services, respond to your inquiries, or for any of the purposes described in this Policy. This may include:

• Our business partners and suppliers;
• Payment service providers. For payment purposes on our webstore, your payment data may be transmitted to the payment service provider with whom we work. For more information on how the payment service providers process your personal data, please read their privacy policies;
• Sub-processors who store or process the information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be ‘personal data’;
• Our auditors, insurers, lawyers, and other professional advisers;
• Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
• Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

6. Contact

Questions, comments, and requests regarding this Policy are welcomed. Email us at smart.futher.tech@gmail.com.