PRIVACY POLICY

Last Update: July 21, 2020

This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We are HYPERHUG LTD, a company under laws of Republic of Cyprus, with registered address at: 1 Siafi Street, PORTO BELLO BUILDING, office 9, 3042 Limassol, Cyprus (“HYPERHUG”, “we”, “us”, “our”), a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our website, games, mobile applications and other products (“Apps”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

  1. INFORMATION WE COLLECT FROM YOU

    When you access or use our Apps, we automatically collect general information about you, including:
  1. Log Information: We log information about your use of our Apps, including the type of device you use, the features you use, access times and your IP address;
  2. Device Information: We collect information about the device you use to access our Apps, including information about the device manufacture, device model, device's OS, time zone of device, language of device;
  3. Device identifiers: We collect online identifiers of the device you use to access our Apps, including IDFA, Google Ads ID, Google Device ID, Game Center ID, Google Play Account ID;
  4. Usage Information: We collect information relating to your use of our Apps, including your game progress, scores, achievements and interactions with other players;
  5. Consumption information: We collect information about your consumption habits relating to your use of our Apps, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

If you log into our Apps using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.

You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:

If you log into our Apps using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with our Apps will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.

  1. HOW WE USE YOUR INFORMATION

    In general, we use the information we collect about you/your device to deliver services and our Apps to you and to operate our business. We use it also for improving our services and Apps, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Apps in our Apps and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes, for complying with our legal obligations and for our legitimate interests (for example, when we use your personal information for evaluation of possible employment relations with you).

    We use your information for the following purposes:
  1. Delivering and improving our services. We use your information for developing, delivering and improving our Apps, services, and content, tailoring our products and services, providing Apps updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Apps, and administering the Apps;
  2. Displaying advertisements. We use your information for showing advertisements for our Apps in other publisher’s apps and for displaying third-party advertisements in our Apps. Please see more in “How we share your information” Section of this Privacy Policy;
  3. Cross-promotion. We use your information for cross-promoting our Apps and services, meaning to promote one of our Apps while you are using any other App of ours;
  4. Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns;
  5. Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the Apps were downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new app features and content;
  6. Security. We use your information for enhancing the safety and security of our Apps, products and services;
  7. Customer Support. We use your information for providing customer support to you and to respond to your inquiries;
  8. Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes;

  1. HOW WE STORE YOUR INFORMATION

    We store your personal data for as long as necessary in order to provide you with our Apps or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.

    Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with our Apps has ceased.

  2. HOW WE SHARE YOUR INFORMATION

    We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
  1. Social networks. Please see more in “Social sharing” Section of this Privacy Policy;
  2. Third parties. If we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  3. The authorities. If we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of HYPERHUG or others;
  4. Other players. In order to provide certain in-app features, such as leaderboards, if you log into our Apps using a third-party service;

Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within our Apps. We use or may use the following advertising network companies:

The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.

In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:

  1. IN-APP PURCHASES

    Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

    Payment transactions for in-app purchases are completed through the app store via your App Store account, Google Play account or Amazon.com account (payment service providers). You are requested to provide your payment details and personal information directly to such payment service providers. We are not involved in the collection and processing of such information: instead, we will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

    Any post-purchase processes are controlled by the Apple, Google and Amazon.com stores and are subject to specific terms of such Apple, Google and Amazon.com stores. Please review privacy policy and terms of service of your Apple, Google and Amazon.com stores.

  2. SOCIAL SHARING

    Our Apps offer or can offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in our Apps with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in our Apps. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

  3. PUSH NOTIFICATIONS

    We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

  4. SECURITY 

    We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

  5. INTERNATIONAL TRANSFER

    The information is processed at the HYPERHUG’s operating offices and in any other places where the parties involved in the processing are located.

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.

  1. CHILDREN

    Use of our Apps and services is limited to users aged 13 years and above, except in European Economic Area, where our Apps and services are limited to users aged 16 years and above. If you are accepting this Privacy Policy and using our Apps or services, you warrant you are 13 (or 16, depending on what is applicable) or more years old.

    If you have additional questions about our privacy practices related to children under the applicable minimum age, please contact us at     [email protected].

  2. DO WE ACTUALLY "SELL" PERSONAL DATA?

    We do not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, HYPERHUG does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”How we share your information“, to the third parties for business purposes as explained under “How we use your information”.

    To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at     [email protected] to exercise your right to withdraw your consent on sharing your personal data with third parties.

  3. 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.
  1. 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:

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.

  1. 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.
  2. Right to rectification
    You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
  3. 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.
  4. 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.

    The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
  5. 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.

  1. 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.

    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 usable and should allow you to transmit the information from one entity to another entity without hindrance.
  1. Right to opt out
    Under CCPA each California resident can request any business stops selling personal information to third parties.
  2. 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.
  3. 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.

    You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access).

    When providing information under the right of access, we will provide you with the following information:
  1. The categories of personal data we are collecting about you,
  2. The categories of sources of the personal data,
  3. The purpose for collecting your personal data,
  4. The categories of any third parties with whom we share your personal data,
  5. The specific pieces of personal data collected about you.
  1. 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 your right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for a certain period of time. For instance, if we need to provide services to you, detect or resolve security issues 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.
  2. 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:
  1. Deny you our Apps,
  2. Charge you different prices or rates for our Apps, including through granting discounts or other benefits, or imposing penalties,
  3. Provide you a different level or quality of our Apps,
  4. Suggest that you may receive a different price or rate for services or a different level or quality of our Apps.

  1. HOW TO EXERCISE YOUR RIGHTS

    To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

    For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
  1. provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  2. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

  1. CHANGES TO OUR PRIVACY POLICY

    We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available     here.

    For previous versions of this Privacy Policy, please contact us via     [email protected]

  2. CONTACT US

    If you have questions or concerns about this Privacy Policy, please contact us via     [email protected]. 

    For information collected under this Privacy Policy, the data controller is HYPERHUG LTD, a company under laws of Cyprus, registered at 1 Siafi Street, PORTO BELLO BUILDING, office 9, 3042 Limassol, Cyprus.