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Privacy Policy!

Last updated: 03 September 2024

1. Introduction

At Sablo Studio, the trust and confidence of our gaming community are paramount. We understand the significance of safeguarding your personal data and are committed to transparency in our practices. This Privacy Policy serves as a guide to inform you about how we handle, use, and potentially share the personal data you provide us, emphasizing our unwavering commitment to maintaining the highest standards of data privacy and protection.

By engaging with our games, you entrust us with your information, and we take this responsibility seriously. We encourage you to read this policy carefully to understand our approach to data privacy and your rights related to it.

2. INFORMATION WE COLLECT AND HOW

While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information” or “Personal Information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes

  1. Basic Identifier and Contact Information: We collect some information from you when you provide it to us directly, such as via an email or online form, through the support feature embedded in our Services, or through another form of inquiry. This information may include your name, email, and phone number. If you apply for a job on our website, information you submit may also include a cover letter and any details included in your resume or curriculum vitae (CV).
  2. Device Information: When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID or advertising ID), language, time zone and IP address.
  3. Usage Information: We collect information automatically about your activity through our Services (Usage Information), such as the date and time you used a service, features you have used, your in-app purchase history, subscriptions, your interaction with advertisements, and data generated when you use our Services (for example your game progress which may be stored with your Apple ID on iCloud for iOS Devices, with your Google Play Games profile for Android Devices and with Facebook, in some of our Services).
  4. Location: When you download and use our Services, we automatically detect your general location, namely country and state through your IP address. We may collect, with your consent if applicable, other location information through your IP address, such as the city you are in.
  5. Media and other files: We may ask for access to your camera in case you want to use certain features of our Services. In case you contact us through our in-app support feature and you need to upload any media or files as attachments, we shall ask for access to such files.
  6. Information we obtain from third parties: We may receive information about you from our third-party service providers, who collect this information through our Services in accordance with their own privacy policies.
  7. Information we obtain when you connect with third parties: In cases we provide the option, and you decide, to connect our Services to your account with third parties like Apple, Facebook or Google, we may receive certain publicly available information about you, as well as any information that you allow or your settings enable to be accessed, including your Apple ID, Facebook user ID, Android Gamer Name, name and email subject to your permission. If you would like to manage your use of “Sign in with Apple” please go to Apple’s website to find out more. If you would like to edit the privacy and settings on Facebook, please go to Facebook’s website to find out more. If you would like to manage your use of “Sign in with Google Play Games” please go to Google’s website to find out more.
  8. User generated content we obtain from you:We may collect content from posts or uploads on social networks or platforms or direct contact, subject to your consent if applicable. Such content may include, your name, social media username, image, likeness, voice, other identifiable information available in such user generated content.
  9. Cookies and similar data collection technologies:We and our third-party advertising networks and their partners may use cookies and similar technologies, such as mobile “SDK”, to provide and personalize our Services and to provide targeted advertisements. Some of these technologies can synchronize behavior across different mobile apps, devices and websites so that advertisements can be tailored to your interests. This process is called personalized advertising. In addition, we and certain advertising networks may access your inventory of installed apps to avoid advertising already installed apps.

3. HOW WE USE INFORMATION AND OUR LEGAL GROUNDS

We use the information we collect within Sablo Studio as follows, pursuant to various legal bases:

4. USE OF DATA

  1. Provide Services:This indicates that the collected data is used to deliver the main services of the game. For example, if a user encounters an error or needs assistance, the game's customer support can reference the data to understand the issue and provide help. This category also includes general game services like syncing progress, allowing multiplayer matches, or saving user settings.
  2. Improvements:Data is used to enhance the game's features and content. By understanding how users interact with the game, developers can identify areas for improvement or expansion. For instance, if analytics show that a particular level has a high failure rate, the developers might use this data to adjust its difficulty.
  3. Personalized Experience:This indicates that the game will use the data to offer tailored content. For example, if a user frequently plays certain types of levels or uses specific characters, the game might suggest similar content or offer customizations that align with those preferences. This aims to make the gameplay more engaging and relevant to individual players.
  4. Marketing and Advertising:Data is employed to send marketing materials to users, which might include newsletters, promotional offers, or news about upcoming games or in-game events. This ensures that the marketing content is relevant to the user. For instance, if a user often makes in-game purchases, they might receive special offers or discounts.

In summary, this "Use of Data" policy outlines how a game collects and uses player data to enhance the gaming experience, support its functionalities, and provide targeted marketing and advertising to its users. It's essential for players to understand and consent to these uses, ensuring they have a clear idea of how their data is being utilized.

5.SOURCES OF INFORMATION WE COLLECT

How we obtain information depends on how you use the Services. For example, we collect information:

6. INFORMATION YOU PROVIDE

You provide us with information when you use the Services, such as when you:

Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, password, platform ID, software products played, survey data, geolocation, and the systems or platforms you play on. We combine this information across devices that you use.

  1. Gameplay Information:When you use the Services, we automatically receive information about your gameplay. Gameplay information includes your platform ID or gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device IDs, other platform / device information, and other information and statistics regarding your use of the Services. We collect gameplay information even if you do not register for the Services. We may combine gameplay information with other information we have about you. We also may use internal and third-party anti-cheat technologies to detect and prevent cheating within our Services.

7. CHILDREN'S PRIVACY

Children’s Privacy in a Privacy Policy refers to special provisions and protections given to the data of children, usually under the age of 13 in the U.S. This is largely because children may not fully understand what it means to provide personal information online, and are considered a vulnerable group.

Under laws such as the Children’s Online Privacy Protection Act (COPPA) in the U.S., websites and online services (including mobile apps and games) that are either directed at children or knowingly collect personal information from children must include certain disclosures in their Privacy Policies and obtain parental consent before collecting this information.

Typically, this section of a Privacy Policy will:

  1. Specify Age Limitations:Explicitly state the age limit, e.g., "Our games are not intended for children under 13."
  2. Address Data Collection Practices:Mention that the company doesn't knowingly collect data from children under this age without parental consent.
  3. Parental Control and Access:Describe how parents can review or delete information about their children, and refuse any further collection or use of their child's information.

8. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The California Consumer Privacy Act (CCPA) is a data protection law that came into effect on January 1, 2020, in the state of California, USA. It provides California residents with certain rights over their personal information.

Under the CCPA, consumers have:

  1. The Right to Know:They can request businesses to disclose what personal information is collected, used, shared, or sold.
  2. The Right to Delete:They can request the deletion of personal information a business has collected from them, though this is subject to certain exceptions.
  3. The Right to Opt-Out:They can direct a business to stop selling their personal information.
  4. The Right to Non-Discrimination:They have the right not to be discriminated against for exercising their CCPA rights.

Businesses that are subject to CCPA need to provide notices to consumers at or before data collection. Many companies incorporate these requirements into their Privacy Policies to ensure they're easily accessible.

For both COPPA and CCPA, non-compliance can lead to heavy penalties. Therefore, if you believe either of these regulations (or any other data protection laws) applies to your company, it's essential to consult with a legal professional to ensure compliance.

9. WHEN WE SHARE INFORMATION

As detailed below, we share your information with:

Sablo Studio has shared unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences with third-party advertising providers to enable us to provide personalized advertising to you and others like you. We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent's) consent.

10. ADVERTISING

We use Sablo Studio and third-party advertising to support our Services, such as ad networks, data exchanges, traffic management service providers, social networks, and marketing analytics service providers. These providers use cookies and similar tracking technologies to collect information about your device and your Service use. This information, along with information that we share with them, enables us or our providers to recognize you or your device and to serve ads to you or your device and measure the effectiveness of those ads. This includes Identifiers / Contact Information, Internet / Games Activity, Device and Usage Data, and Profile Inferences.

  1. We collect or share this information when you use our Services, click on a site or an ad, or launch one of our games or other mobile applications.
  2. This information: allows us to accurately and properly pay for ads placed on our behalf (e.g., an ad that led you to purchase or download one of our games) and get paid when you see an ad on our Services;
  3. helps prevent you from repeatedly seeing the same ads;
  4. helps select and display targeted ads or other content on your device (such as on a site or social networking service you are visiting or a mobile application you are using) that may be of particular interest to you
  5. helps with measuring and analyzing the effectiveness of our ads, popularity of content, and traffic on our Services; and
  6. helps us improve our Services.

You can learn more about managing how we and our providers use your information in the Manage Your Account, Communications, and Data section; and, as applicable for the Service, by using our cookie preference tool, where available, or visiting the Cookie Policy posted on the Service.

11. AD NETWORKS

We may feature advertising in our Services via showing third party advertisements in our Services, as well as advertise our own Services via third parties.

Sablo Studio may disclose your personal information to advertising networks for the purpose of their direct marketing. Thus, we may send your advertising ID and IP address to ad networks to enable our partners to serve appropriate ads in accordance with GDPR article 6(1)(f). "Advertising ID" means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that SABLO STUDIO and our advertising network partners use for interest-based advertising (targeted). They are consistent across all apps and thus allow cross-app tracking. These identifiers are used by ad networks for a number of purposes, in addition to targeted advertisement, thus we encourage you to check the Privacy Policies of our partners. These advertising networks may be located in countries outside EU/EEA that have less restrictive data protection legislation. For such advertising networks in countries outside EU/EEA, the legal basis for the transfer is always in accordance with one of the lawful instruments set forth I GDPR article 44-50. If you use an Android device, navigate to the Google Settings page, select Ads and then choose to reset your Android Ad ID or opt-out of targeted ads.

12. THIRD PARTIES

We share your information with third parties as described in this Privacy Policy, including as follows:

  1. Collaborative Relationships:When we offer services or promotions in collaboration with a third party who will receive your information for its own use, we will inform you of that at the time of collection and you may choose whether to participate in the offering.
  2. Legal & Safety:We may share your information to protect the security of our Services, servers, network systems, databases, users and business and in connection with an investigation of fraud, intellectual property infringements, interference with our rights, property or users, or other activity that is illegal or may expose you or us to legal liability, including as required or requested by law enforcement or other government officials. We also may share your information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that it is necessary to protect our rights, investigate, or enforce our policies, terms, combat fraud, or comply with a judicial proceeding, court order, or legal process served on Sablo Studio. We also may share your information when we have reason to believe it is necessary to investigate or enforce our policies, terms, or other legal document or contract related to the Services or rights of a third-party.
  3. Sale or Transfer of Business or Assets:We may sell or purchase assets during the normal course of our business. We may disclose information about you and transfer that information to another entity as part of a potential or actual acquisition or merger of Sablo Studio or any of our assets. If we bring or are defending a reorganization, bankruptcy, or similar event, such information may be considered our asset and sold or transferred to third parties.
  4. As Disclosed to You:We may share your information as disclosed to you at the time of collection.
  5. Other Users:If you participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as your user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites. If you participate in tournaments or other online game events, we must publicly post your information.

We publish gameplay boards and multiplayer match records that contain information based on your use of the Services, such as your user name or ID, when they are essential components of the Services that we offer you and others. Like other gameplay statistic services, your game activity, leaderboards, and multiplayer match information may appear nested in the Services or third-party webpages.

Some third-party services also let you post information about your game activity to their sites to share with others. If you use these features, those third-party services' privacy policies and terms govern your actions on those sites and the information that those services collect.

We combine information collected through various Services and display it publicly, including on our Services, in our games, or in multiplayer game lobbies. For example, if you link your game platform account with us, we may display your in-game achievements along with your account name.

13. DATA RIGHTS

Depending on your location, you may have certain rights over your personal information, including the right to:

14. SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS

We are committed to protecting your privacy and ensuring that your personal information is handled in accordance with applicable privacy laws in the United States, including the California Consumer Privacy Act, Virginia Consumer Data Protection Act, the Colorado Privacy Act and the Connecticut Data Privacy Act (“US Privacy Laws”). For more information about specific states, please visit their relative section below.

We aim to respond to your request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we cannot satisfy your request, we will respond to you with our justification for declining to take action. If you wish to appeal this decision, you can contact us through email support@sablostudio.com,

15. THE CALIFORNIA CONSUMER PRIVACY ACT

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”). The California Consumer Privacy Act (“CCPA”), as amended and expanded by the California Privacy Rights Act (“CPRA”) provides California residents with the additional rights listed here. To exercise these rights, see the Section of privacy right.

19. COLORADO, CONNECTICUT AND VIRGINIA

This Supplemental Privacy Notice only applies to our processing of personal information of personal data that is subject to the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) and the Connecticut Data Privacy Act (“CDPA”). These State Laws provide their respective state’s residents with certain rights listed here. To exercise these rights, see the subsection below.

  1. Right of Access:You have the right to request from us to confirm whether or not we are processing their personal data and to obtain a copy of the personal data that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
  2. Right of Rectification: Depending on your area, you have the right to request that we correct inaccuracies in their personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data
  3. Right of Erasure: You have the right to request that we delete the information we have collected from you.
  4. Right to object / Right to opt-out:You have the right to “opt-out,” from targeted advertising, to the sale of your personal data, or depending on your state, to profiling in furtherance in decisions that produce legal or similarly significant events. To submit an opt-out request, please follow the instructions under the Opt-Out of targeted Advertising, to configure the Privacy Setting in any of our apps or by checking your device privacy settings.
  5. Non Discrimination: In certain states, residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the US State Laws.

20. EXERCISE YOUR PRIVACY RIGHTS

Any requests to exercise your rights should be made through the Privacy Setting tab in any of our apps located by going to your home page and tapping to Gear Icon (Click on three dots (or more)) -> About -> Privacy Settings and select which rights you want to exercise. You can also contact us through our support feature located in our apps by going to your home page and tapping to Gear Icon (Click on three dots (or more)) -> click help (or support) -> and then click on the Start Conversation button, and place your request. You can also send us an email at support@sablostudio.com, however, we may still redirect you to make the same request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

You may also contact your local data protection authority within the European Economic Area or the UK or a relevant national authority for unresolved complaints.

  1. Opt-out of targeted advertising To show you personalized advertisements in our apps we use third-party advertising networks and their partners, including those that need your consent and are listed in advertising network and third parties, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers i.e. the Android advertising ID and/or Apple's ID for advertising (IDFA), device data and/or other tracking technologies to enable and optimize this advertising procedure.

You can opt-out from personalized advertisement experience, at any time by checking the Privacy Setting tab in any of our apps or under the privacy settings of your iOS or Android device.

Method 1 (depending on your local privacy laws) - App Settings:

  1. Open app Settings
  2. Select About/About Game
  3. Select Privacy Setting
  4. Select Advertising Preferences (or “Privacy Preferences” or “Do Not Sell or Share my Personal Information” )
  5. Switch off the Enable All toggle, and then click Confirm Choices (Android) or Save & Exit (iOS)

Method 2 - Device Settings:

  1. For iOS 14 and later:
  2. Open device Settings
  3. Select Privacy (& Security)
  4. Select Tracking and disable "Allow Apps to Request to Track" or disable permissions for specific app

For iOS 13 and older:

  1. Open device Settings
  2. Select Privacy
  3. Select Advertising and enable "Limit Ad Tracking"

For Android:

  1. Open device Settings
  2. Select Google
  3. Select Ads and enable "Opt out of Ads Personalization" or "Delete advertising ID" accordingly.

When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests.

Note: Irrespective of your choice and/or your device settings, you will continue to see non-customized advertising (e.g. “contextual” advertising) and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites.

21. Advertisement business partners

Your personal data may be transferred to our advertisement partners who enable the Games to be provided free or for low cost.

You may find the list of our service providers and business partners and their privacy policies below:

Service provider/Business Partner
(Analytics services)		 Privacy Policy
Appsflyer https://www.appsflyer.com/legal/privacy-policy/
Meta https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect
Google LLC (Firebase https://firebase.google.com/support/privacy
Game Analytics https://gameanalytics.com/privacy
Google LLC (Google Cloud) https://cloud.google.com/terms/cloud-privacy-notice
Adjust https://www.adjust.com/terms/privacy-policy/
Tenjin https://tenjin.com/privacy/
ByteBrew https://docs.bytebrew.io/BBSettings/privacypolicy


Below you may find the list of our advertisement networks (acquisition & monetisation) and their privacy policies below:

Advertisement business partners
(advertisement networks)		 Privacy Policy
AppLovin Corporation https://www.applovin.com/privacy
Facebook Inc. (FB Ads, FB Audience Network) https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect
Digital Turbine https://www.digitalturbine.com/legal/privacy-policy
Google LLC (Google Ads) https://policies.google.com/privacy
InMobi https://advertising.inmobi.com/privacy-policy
IronSource Ltd. https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Mintegral https://static.mintegral.com/document/privacy
Smaato, Inc. https://www.smaato.com/privacy/
Tapjoy, Inc. https://dev.tapjoy.com/en/legal/Privacy-Policy
Unity Technologies https://unity.com/legal/privacy-policy
Vungle Inc. https://vungle.com/privacy/
Apple https://www.apple.com/privacy/
Snapchat https://values.snap.com/privacy/privacy-policy
Amazon.com https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ
Yandex https://yandex.com/legal/confidential/
Tiktok https://ads.tiktok.com/i18n/official/policy/privacy
Chartboost https://docs.chartboost.com/en/legal/privacy-policy/
Verizon Media https://legal.yahoo.com/ie/en/yahoo/privacy/index.html
Ogury https://ogury.com/ogury-website-and-customer-privacy-and-cookie-notice/
Pangle https://www.pangleglobal.com/privacy/enduser-en
Google Ads https://business.safety.google/adsservices/

22. Your Rights Regarding the Protection of Your Personal Data

  1. Rights of EEU residents We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
  2. Right to request access:You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:

    3. Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

  3. The right to object:You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.
  4. Right to rectification:You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
  5. The right to restriction:You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
  6. The right to withdraw consent:If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

    7. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

  7. The right to data portability:You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
  8. Rights of California residents:We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.

    9. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

  9. Right to opt out:Under CCPA each California resident can request any business stops selling personal information to third parties.
  10. Right to be informed:You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.
  11. Right to disclosure:You can request us to disclose what personal data we have collected on you in the past 12 months. We can assure you that our Privacy Policy is an relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.

    12. You also have a right to get a free copy of your personal information disclosed in a readily.

    When providing information under the right of access, we will provide you with the following information:

  12. Right to deletion:You can request us to delete the personal data we have collected on you in the past 12 months.
    We fully recognize you right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.
  13. Data Deletion Request:You may request Sablo Studio to erase without undue delay your personal data when it is no longer necessary for Sablo Studio to retain such data. In order for your data to be erased you can contact Sablo Studio by support@sablostudio.com with request.
  14. Right to equal services and prices:California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

23. CHANGES TO THE POLICY

We reserve the right to change this Policy at any time. If we decide to change this Policy, we will post those changes on this page and update the date at the top of the page. The changes will be effective when posted. Please check this page on a regular basis so that you remain aware of what information we collect and how we use it.

24. CONTACT US

Sablo Studio

Contact us: support@sablostudio.com