PRIVACY POLICY – FANHAPTIC STUDIO

Last update: March, 27th 2024

Welcome to the FANHAPTIC STUDIO Privacy Policy!

This policy outlines the procedures and reasons behind the collection and processing of information, including personal data, by FANHAPTIC STUDIO, its affiliated companies, and partners. We gather this data through our games and applications (referred to as the “Games”) or on our FANHAPTIC STUDIO website (referred to as the “Website”). Hereinafter, both the Games and the Website are collectively referred to as the “Services.”

This document furnishes essential details about the principles guiding the handling of this information, elucidating your “data subject rights” designed to safeguard your privacy.

It’s important to note that this policy exclusively pertains to information collected and/or processed by FANHAPTIC STUDIO through your utilization of the Services.

If you have reservations about the information you provide to us or its use as outlined in this privacy policy, we recommend refraining from using our Games or Website.

Feel free to reach out to us at contact@fanhapticstudio.com if you have any questions.

1. Our Games

Purpose and Legal Basis for Data Collection

When you install and engage with FANHAPTIC STUDIO’s Games, we may collect and process certain data, contingent upon your explicit consent or for various purposes.

In accordance with data protection laws, we, as a data “controller” (signifying that FANHAPTIC STUDIO is the primary decision-maker exercising comprehensive control over the purposes and methods of processing personal information), are only authorized to utilize your personal information when a legitimate legal basis exists. This may include:

  • Performance of Contract: Utilizing your personal information to fulfill our contractual obligations with you.

  • Consent: Processing your data based on your explicit consent.

  • Legal and Regulatory Compliance: Using your information to comply with our legal and regulatory obligations.

  • Legitimate Interests: Employing your personal information for our legitimate interests or those of a third party. Legitimate interests include business or commercial reasons, such as sustaining our free-to-play model, provided such usage does not override your rights and interests.

In instances where obtaining your consent is mandated by law or regulation (e.g., in countries that do not recognize legitimate interests as a legal basis), we will seek your explicit consent.

The following outlines the reasons why FANHAPTIC STUDIO may collect your personal information and the corresponding legal basis for each case:

  • Purpose of Processing: Furnishing the Services you’ve specifically requested.

    • Legal Grounds: Necessity arising from a contractual agreement.

  • Purpose of Processing: Tailoring personalized ads based on your preferences and interests.

    • Legal Grounds: Consent provided by you.

  • Purpose of Processing: Aggregating and furnishing third-party analytics; data garnered from our applications may be shared with third-party partners delivering analytics services to FANHAPTIC STUDIO.

    • Legal Grounds: Consent provided by you.

  • Purpose of Processing: Attribution, such as correlating an advertisement from one of our Games that you may have encountered in another application with the subsequent installation of that Game.

    • Legal Grounds: Justified interest in the normal course of business.

  • Purpose of Processing: Ensuring the operational functionalities of our applications, encompassing debugging and maintenance.

    • Legal Grounds: Justified interest in the normal course of business.

For all data processing activities dependent on users’ consent, you retain the ability to modify your preferences and revoke your consent within the privacy settings of any of our applications.

It’s important to note that opting out does not eliminate the visibility of ads in our applications. Some of our partners may continue to deliver ads to you based on non-personal information they possess, even if you choose to opt out.

Data Collection Scope

When utilizing any of FANHAPTIC STUDIO’s applications on a mobile platform, and specifically for the outlined purposes above, we may gather and process (which includes storage, sharing with our partners, and analytics processing) the following data, strictly adhering to the identified lawful bases:

  • Advertising ID: This encompasses the IDFA (Identifier For Advertising) / IDFV (Identifier For Vendors) if you are using an Apple device, or the GAID (Google Advertising ID) if you are using an Android device.

  • Location Data: Collected at a city/region level based on your Internet Protocol (IP) address.

  • Technical Information: This includes details about the device you are using and your connection, such as operating system, device model, connection type, language, and timezone.

  • App-related Technical Data: Information specific to the application you are using, including the installed app version.

  • Gaming Activity Data: Information related to your in-game activities and interactions with our apps, such as gameplay data, total playtime, usage patterns, your in-game level, and details of in-app purchases (excluding payment/credit card information).

  • Advertising-related Data: Details about the advertisements displayed in our applications, including the number of ads clicked, purchase times, and the quantity of in-app purchases made.

Data Collection Methods

The majority of the personal information processed through our Games is obtained directly from you.

Furthermore, we may collect personal information through the following methods:

  • Business Partner SDKs: Information may be acquired from our business partners’ Software Development Kits (SDKs), as detailed below.

  • Other Third Parties: Personal information may be obtained from any other third party to whom you have granted consent.

Data Sharing Recipients

When you provide consent for Data collection for advertising and third-party analytics, the data mentioned above may be shared with the following categories of recipients:

  1. Advertising Networks and Attribution Partners:In order to offer users free-to-play Games, we collaborate with third parties for two main purposes: (i) advertising our Games across various networks and other applications, and (ii) generating revenue through advertising within our Games and in-app purchases.These third parties typically gather user and device-related data through their Software Development Kits (SDKs), particularly for attribution purposes. For instance, you might come across our Games being promoted in other applications. If you click on one of these advertisements and install our Game, you become a user of our Services. To validate the installations, a device identifier may be shared with our attribution partner to ‘match’ the advertisement with your installation; this process is referred to as “mobile attribution.”The privacy policies of our partners may contain additional terms and disclosures regarding their data collection and tracking technologies. We encourage you to review those privacy policies to gain further insights into their practices and to directly exercise your rights with them:

  2. AdColony

  3. Adjust

  4. Adnet.qq

  5. Appier

  6. Apple Search Ads

  7. AppLovin

  8. Appodeal

  9. Chartboost

  10. Digital Turbine

  11. Facebook

  12. Fyber

  13. Google AdMob

  14. Google Ads

  15. InMobi

  16. IronSource

  17. Jetfuel

  18. Liftoff

  19. Mintegral

  20. MoPub

  21. MyTarget

  22. Nativex

  23. Ogury

  24. Pangle

  25. CSJ

  26. ShareIt

  27. Snap

  28. TapJoy

  29. TikTok

  30. Unity Ads

  31. Verizon Media

  32. Vungle

2. Analytics Partners

We collaborate with the following analytics partners, who provide us with tools and technologies to enhance our understanding of user interactions with our Games, ultimately aiding us in continuous improvement:

  1. Adjust

  2. GameAnalytics

  3. Amplitude

  4. Facebook

3. Storage / Servers

FANHAPTIC STUDIO utilizes either AWS or GCP for the storage of the data collected through our apps:

  1. Amazon Web Services

  2. Google Cloud Platform

In addition to the aforementioned disclosures in this Privacy Policy, we may share your information:

  • Legal Obligation: As required to comply with any legal obligations.

  • Corporate Transactions: In the event of a sale of FANHAPTIC STUDIO’s assets, corporate restructuring, or a change of control of FANHAPTIC STUDIO, or in preparation for any of these events. Any third party to whom FANHAPTIC STUDIO transfers or sells its assets will retain the right to continue using the data provided by you in accordance with the terms outlined in this Privacy Policy.

Data Retention Duration

We retain the data collected and processed for the purposes outlined in this policy only for the duration necessary.

Furthermore, we will continue to store and utilize your information for as long as it is essential to fulfill our legal obligations.

Our Policy Regarding Children

To play our Games and access our Services, you must meet a certain age requirement determined by your place of residence. For a comprehensive list of age restrictions by country, please refer to this page published by the European Union Agency for Fundamental Rights.

We neither knowingly nor willingly collect or solicit personal information from individuals below the specified age, nor do we allow such individuals to use our Services.

If you are below the legal age in your country, kindly refrain from playing our Games or using our Services.

If we become aware that we have inadvertently collected personal information from individuals below the legal age, we will promptly delete that information. If you suspect that we may possess information from or about individuals below the legal age, please contact us at contact@fanhapticstudio.com.

Data Storage and International Transfers

Our data is stored on servers located in Europe through either Amazon Web Services or Google Cloud Platform.

In order to provide you with our Services, there are instances where it becomes necessary for us to share your data outside of your country or region, including:

  • With our offices and affiliated companies.

  • With our service providers.

Consequently, we may transfer the information we collect about you to our third-party partners across borders, potentially outside of the European Economic Area (EEA).

It’s important to note that countries outside of the EEA may not have the same data protection laws as your own jurisdiction. To ensure the protection of your information, we take measures to implement adequate safeguards and mechanisms, including the utilization of EU Standard Contractual Clauses, allowing the secure transfer of your information outside of the EEA.

We also verify that any third parties with whom we share information have suitable transfer mechanisms in place.

Security

We implement suitable security and technical measures to safeguard your information against unauthorized access, loss, and misuse.

Furthermore, we stipulate that our suppliers, who process personal information on our behalf, adopt a variety of security measures. These measures are specifically designed to protect your personal information and uphold an appropriate level of security.

2. Our Website

When you navigate our FANHAPTIC STUDIO Website, the following information may be collected and processed:

  • Browsing Events and Interactions:

    • Details regarding interactions with the Website’s contents and services, such as operating system, IP address, access times, browser type, and language.

  • Form Submissions:

    • Information provided by you when filling in forms on our Website.

  • Communication Records:

    • If you reach out to us or respond to messages and communications, a record of that correspondence may be retained.

  • Social Media Interactions:

    • Your engagements with us on our social media channels.

  • Cookie and Technology Data:

    • Information gathered through cookies and similar technologies. For more details, refer to the “Cookies” section below.

We, or our partners, may utilize this information:

  • Website Operation and Optimization:

    • To manage and enhance the functionality of the Website.

  • Communication:

    • To contact you, such as sending updates about our Games or the Website.

  • Research and Engagement:

    • For research, surveying, and engaging with you, including sending communications (such as emails) for these purposes.

If you no longer wish to receive such emails, you can opt-out at any time by contacting us at contact@fanhapticstudio.com.

Cookies

Cookies are diminutive data files deposited on your computer or mobile device when you visit a website. These small text files, stored in your browser, facilitate the gathering of information pertaining to your interactions on a website, encompassing interactive content and analytics.

FANHAPTIC STUDIO employs Google Analytics to amass information regarding web traffic on our website. The ensuing cookies have been implemented on our Website:

  • _ga: Utilized to differentiate between users.

  • _gid: Employed to distinguish users.

  • ga<container-id>: Employed for maintaining session state persistence.

  • gac_gb<container-id>: Encompasses campaign-related details. If you’ve linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.

Opt-Out from Google Analytics Data Collection: To opt-out from Google Analytics data collection, you can use the following link: https://tools.google.com/dlpage/gaoptout

In adherence to guidelines from our Data Protection Authority:

  • Cookies exempted from consent are valid for a maximum of 13 months.

  • Cookies requiring consent typically remain valid for 6 months.

Moreover, the maximum data retention period for information collected via technical cookies is set at 25 months.

3. Your Choices and Rights

According to data protection laws, you have specific rights concerning your personal information and its handling. You can exercise these rights anytime by reaching out to us at contact@fanhapticstudio.com:

  • Right of Access: You have the right to be informed about the information we hold about you and, in certain cases, to receive a communication of this information. To exercise this right, please contact us and specify the particular information you would like to receive. We reserve the right to request reasonable evidence to verify your identity before providing any information.

  • Right to Rectification: You can request the correction of personal information you believe is inaccurate. Additionally, you have the right to ask us to complete information you find incomplete.

  • Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal information.

To permanently erase data previously collected by FANHAPTIC STUDIO regarding you and/or your device, please contact us as indicated in the “Contact” section below.

Furthermore, to prevent future data collection, you can:

  1. Activate “Limit Ad Tracking” (LAT): Adjust your device settings to opt-out of having an ID for Advertisers, thereby avoiding specific targeted ads.

  2. Uninstall Our Games

  3. Reinstall Our Games:

    • This step helps ensure a fresh start in terms of data collection.

Where we delete personal information about you, it’s possible that we might retain some or all of that information for other purposes, such as maintaining financial records or protecting and enforcing legal rights. Your information may also be retained in an anonymous form.

  • Right to Restrict Processing: In certain cases, you may have the right to request a restriction of the processing of your personal data. This could apply, for instance, when you are disputing the accuracy of the data we hold about you.

  • Right to Data Portability: When the processing of your personal data is based on consent or contract, you may have the right to request that the personal data you provided to us be transferred to another data controller of your choice in a portable format.

  • Right to Object to Processing: You have the right to object to the processing of personal data about you that is carried out on the grounds of legitimate interests.

Exercising your rights does not incur any charges, and we have one month to respond to your request.

For any inquiries or to exercise your rights, please contact us at contact@fanhapticstudio.com.

4. Contact Information

FANHAPTIC STUDIO SARL (984 153 668 R.C.S Reims)

Address: 55 rue Coquebert – 51100 Reims, France

As a data subject, you retain the right to file a complaint with CNIL, our French data supervisory authority: www.cnil.fr

For any inquiries or questions regarding this Privacy Policy, please reach out to us at contact@fanhapticstudio.com.