Last Revised: March 2020
Flurfunk Interactive GmbH ("flurfunk", "we", "our" or "us") develops, publishes and operates social games for web and mobile environments "Games"), as well as web and mobile applications (each, an "App") for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).
We also operate the website www.flurfunk-interactive.com, its subdomains and its related features ("Site", and together with the Games and App, collectively - the "Services").
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still play our Games without connecting your Facebook account, but you will not be able to enjoy their social features).
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.
Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Such data includes your device advertising identifiers (e.g. IDFA, to the extent available), data related to your connected Facebook profile (if any, such as your gender, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described in Section 3 above). Please note that we do not share the data you provide us through your connected Facebook account with our advertising partners.
The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.
If you wish to prevent the use of your device's advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the "Privacy" or "Ads" section in your device settings).
Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see advertisements in our Games, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the Game, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service (for further information about cookies, please see the "Cookies" section in this policy).
We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies.
Google uses technologies such as cookies in order to track and analyse the use of our Site and/or an SDK to serve ads within our Games. To learn more about how Google processes data, we recommend you review Google's policies located at: https://policies.google.com/technologies/partner-sites. For additional information, please see Google Analytics' opt-out web tool available at: https://tools.google.com/dlpage/gaoptout. For additional information regarding the data which Google SDK processes and stores see: https://support.google.com/admob/answer/7665968
We use anonymous, statistical or aggregated information and may share it with our partners or service providers for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.
Your Personal Data may be maintained, processed, accessed and stored by us and our authorized affiliates, Service Providers and business partners in and from Europe and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. Flurfunk Interactive is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, Flurfunk Interactive has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your personal information if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy. If you have any questions about our Data Retention Policy, please contact us at email@example.com.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates - but only in accordance with this policy:
For the removal of doubt, Flurfunk Interactive may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.
While we do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, we cannot guarantee that our Services will fully operate should you choose to block cookies. For example, any preferences you may have defined on our Site or App will not be saved.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you wish not to receive such promotional communications, you may notify Flurfunk Interactive at any time by e-mailing us at firstname.lastname@example.org or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
In case we process personal information about you and if you are an EU resident or the resident of another jurisdiction that affords you with the below rights you:
have the right to know what personal information we maintain about you.
may, at any time, withdraw your consent for the collection, use and processing of your information, access, correct, request deletion, request restriction of our process of your personal information or object to the processing of your personal information, as set by applicable law. Please note that if you withdraw your consent for our use or disclosure of your personal information, or ask us to delete or restrict how we use or process your personal information, subject to applicable law, we may not be able to provide you with all of our Services and customer support or the quality of the Services may be diminished.
may ask to transfer your personal information in accordance with your right to data portability.
have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) please contact us at email@example.com
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with our Data Retention Policy.
If you wish to manage the information we receive about you from a third-party application or platform where you play our Games, such as Facebook, Apple or Google, please follow the third-party application's instructions for updating your information and changing your privacy settings.
You have the right to file complaints with a data protection supervisory authority.
The Games and Services are available only to individuals who are the greater of eighteen (18) years of age or the age of legal majority in your jurisdiction. We reserve the right to request proof of age at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.
If you believe that we might have any such data, please contact us at firstname.lastname@example.org