PRIVACY AND DATA POLICY
ISSUED BY CONFUSED PIGEON STUDIOS LLC
Last Updated: 20 June 2020
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by Confused Pigeon Studios (‘TBB’ / ‘Pet Friends (623166351969609)’ / ‘RKR, BBT’).
This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the "Game(s)"), as well as any other online features relating to the Games including our website (the “Website”). Together the Game(s) and the Website “Online Services”.
If you have any questions or comments about this Privacy Policy, please contact us at contact@confusedpigeonstudios.com
We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “controller”. We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and California Consumer Privacy Act 2018 (“CCPA”).
Please read this Privacy Policy carefully as it contains important information about the following:
  • What information we may collect about you;
  • How we will use information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal information you have provided to us.
This Privacy Policy forms a part of and should be read in conjunction with our terms of use.
We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
a) Information provided by you when using the Games
(“Basic Information”)
We will collect the following information from you when you play our Games:
  • your mobile device’s unique device ID (Device ID) and device name;
  • your user preferences; and
  • Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).
b) Contact information provided by you when using the Forums or Support Centre
(“Contact Information”)
We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums or Support Centre.
This may include:
  • your avatar/profile picture (Forums only);
  • your username (Forums only);
  • your email address;
  • your name (Forums only), and
  • your password (Forums only).
c) Information used for the purposes of serving advertisements
(“Advertising Data”)
Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
  • the make, model and operating system of your device;
  • properties of your device, such as screen size and orientation, audio volume and battery;
  • the mobile network operator linked to your device;
  • the Games played;
  • the country, time zone and locale settings on your device (i.e. country and preferred language);
  • network connection type and speed;
  • IP Address;
  • MAC address;
  • internet browser used to access the Games; and
  • the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.
d) Information collected for the purposes of providing analytics
(“Analytics”)
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
  • your Device ID;
  • your user ID (which is generated by us and allocated to you when you first play our games);
  • your device operating system & version;
  • your device make and model;
  • game play attempts, progression and results;
  • session game time start, end and duration;
  • purchase transaction types and spend you have made using virtual items in the Games;
  • the country of your Device;
  • the time, date and install source of your first download (e.g. from a clicked advertisement);
  • advertisements viewed and clicked; and
  • identification of crashes and defects.
f) Content created by our users which we host and display on the Forums and in the Support Centre
(“User Content”)
When users submit their own User Content to the Forums or Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Online Services.
3. WHY WE COLLECT INFORMATION ABOUT YOU
a) To provide our Online Services to you
We will use information about you (including Basic Information, Third Party Log In Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.
We will use information about you (including your Contact Information, User Content and Third Party Log In Information) to provide you with the Forums under the terms of use agreed between us. The processing of information in this way is necessary for us to provide you with the Forums’ functionality and to ensure that you have the best experience when using the Forums.
b) To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Online Services; and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.
c) To respond to your enquiries and requests for support
We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre or Forums or through contact@confusedpigeonstudios.com
d) To acquire new users
We use various forms of marketing to acquire new users, working with a variety of third party user acquisition partners to deliver our marketing campaigns on external websites and apps. As part of this we may process your Advertising Data to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences where your Advertiser ID may be shared with our user acquisition partners.
We may process your Basic Information and Advertising Data to help us report and understand the effectiveness of our marketing campaigns, working with our user acquisition partners and a third-party marketing analytics provider called Adjust. Adjust may collect analytics and some advertising data on our behalf and in accordance with our instructions, and its applicable privacy notice.
We work with the following third party user acquisition partners:
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
We may process this information to pursue our legitimate interests of acquiring new users for our Games.
e) To improve the monetisation of the Games via in-app purchases
We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include segmenting and analysing users according to various relevant factors, such as geography, gameplay progression and playing behaviour so that we can offer personalised and temporary promotional discounts and offers.
We will not pass your information to third parties for the purposes of dynamic pricing unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.
f) For advertising purposes
We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.
The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.
We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.
We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.
We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
g) To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
4. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know by sending an email to contact@confusedpigeonstudios.com.
a) Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
b) Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
  • you consented to our processing the personal data, and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of FTG or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations;
  • the personal data is processed in relation to the offer of a service to a child.
c) Obtain a machine readable copy of your personal data, which you can use with another service provider
  • If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
  • If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
d) Make a complaint to a Supervisory Authority
  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
  • If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
5. DATA RETENTION
We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.
6. CHILDREN
We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at contact@confusedpigeonstudios.com
7. SECURITY
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as FTG management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
8. INTERNATIONAL DATA TRANSFERS
Where you make in-Game purchases via Google’s Play store, the confirmation that your purchase is valid as required by Google for such purchases will be processed using servers hosted in Singapore in the event that there is a problem with the servers hosted in Ireland. The servers we use for this purpose are hosted by Amazon Web Services.
Basic Information used for Matchmaking services, where users may play against other users, may be processed using servers based in Singapore or US in addition to Ireland and Germany, reflecting the global player base of the Games. The servers we use for this purpose are hosted by Amazon Web Services.
It is possible that your personal information may be transferred outside of the EEA by Ad Networks, Adjust, or Zendesk. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.
Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to contact@confusedpigeonstudios.com
9. CALIFORNIA RESIDENTS & CCPA
If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.
If you have questions or concerns about our privacy policies and practices, please contact us at the details set out at the end of this Policy.
Please see above for:
·  the date on which this Policy was last updated (at the top of this Policy)
·  categories of personal information collected about you in the last 12 months (see paragraph 2)
·  categories of sources from which the personal information was collected (see paragraph 2 and 3)
·  purposes for collecting personal information (see paragraph 4)
·  categories of third parties with whom we share personal information (see paragraph 5)
·  categories of personal information we have disclosed within the last 12 months (see paragraphs 2 and 5)
·  categories of personal information we have sold within the last 12 months (see paragraph 2c and 4f)
We have disclosed and sold personal information to third parties within the last 12 months to our third-party advertising networks (see paragraph 4f). We do not sell the personal information of minors under 16 years of age without affirmative authorisation.
You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.
You have the right to:
·  request access to your personal information;
·  request deletion of your personal information;
·  opt-out of the sale of your personal information (see paragraph 7 above or email us at contact@confusedpigeonstudios.com);
·  not be discriminated against for exercising any of your rights under the California Consumer Privacy Act of 2018 (CCPA).
To make a verifiable consumer request of access or deletion, please contact us by email at contact@confusedpigeonstudios.com or by mail to First Touch Games Ltd, 264 Banbury Rd, Oxford, OX2 7DY, UK. We may verify your request by asking for proof of identity such as your device ID and/or User ID.
CONTACT INFORMATION
All questions, comments or enquiries should be directed to FTG at contact@confusedpigeonstudios.com. We will endeavour to respond to any query or questions within three business days.
© 2020 Confused Pigeon Studios LLC. All trade marks are the property of the relevant owners. All rights reserved.

©2019  Confused Pigeon Studios. 

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