PRIVACY POLICY

Effective Date: 01 January 2020

We, at OUTLOUD SOFTWARE DEVELOPMENT LTD ("OUTLOU:D", "OUTLOUD" "we" or "us"), are committed to respecting your privacy and the integrity and security of your personal data.


OUTLOUD SOFTWARE DEVELOPMENT LTD is a data controller with a registered office at Cyprus, Limassol, Vasileos Georgiou, 9, SOFIRINI COURT 1, Germasogeia 4040.


This Privacy Policy applies to https://outloud.games, all other sites or online services that is owned or operated by OUTLOUD SOFTWARE DEVELOPMENT LTD, all mobile games published by OUTLOUD SOFTWARE DEVELOPMENT LTD, OUTLOUD, OUTLOU:D (and other companies related to them) games that can be played through third party platforms (collectively “Services”) We reserve the right to change our practices and this Privacy Policy at any time. Each time a user accesses our Services the current version of the Privacy Policy applies, and you agree that the personal data we collect will be subject to the Privacy Policy, as updated. We encourage you to check this page regularly so that you know our current practices.


By downloading, accessing and/or using our Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to OUTLOUD SOFTWARE DEVELOPMENT LTD’s and our partners’ use of your data for the purposes as described below. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, you should not use our Services.


1. WHAT DATA WE COLLECT

The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from our partners.


a. Data you provide to us

  • Contact information (such as name and email address)
  • Your messages to the Services (such as chat logs and player support tickets)
  • Limited and tokenized payment information may be collected when making a purchase
  • Other data you choose to give us

b. Data we collect automatically

  • Data about your game progress
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
  • Data about your device, such as device name and operating system, browser type and language
  • General location data
  • Precise geo-location data (GPS, with your consent)
  • Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services

c. Data we collect from our partners

  • Data we receive if you link a third party tool with the Services (such as Facebook, or Google)
  • Demographic data (such as to determine the coarse location of your IP address)
  • Data to fight fraud (such as refund abuse in games or click fraud in advertising)
  • Data from platforms that the games run on (such as to verify payment)
  • Data for advertising and analytics purposes, so we can provide you a better Services


2. WHY DO WE COLLECT YOUR DATA

To make the Services work

To perform the contract, we process data necessary to:

  • Allow you to use our Services
  • Operate the Services
  • Verify and confirm payments
  • Provide and deliver products and services you request
  • Send you Services-related communications

To make the Services more suitable for our players

To provide a great Services to our players, we have a legitimate interest to collect and process necessary data to:

  • Develop and improve the Services and player experience
  • Manage our relationship with you
  • Provide social features as part of the Services
  • Customize your Services experience
  • Respond to your comments and questions and provide player support
  • Provide you our offers in the Services
  • Send you related information, such as updates, security alerts, and support messages
  • Enable you to communicate with other players

To show personalized advertisements

To show you personalized advertisements in the Services we have a legitimate interest to process necessary data to:

  • Track the content you access in connection with the Services and your online behavior
  • Deliver, target and improve our advertising and the Services
  • For information on how to opt-out from personalized advertisements, see section “Your rights and options” below.

To keep the Services safe and fair

In order to keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

  • Analyze, monitor and moderate use of the Services and its social features
  • Take action against fraudulent or misbehaving players

To analyze, profile, and segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data.


3. WHO CAN SEE YOUR DATA

Apart from OUTLOUD SOFTWARE DEVELOPMENT LTD, your data can be accessed by others in the following situations:

Other players and users

Social features are a core component of our Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.


Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.


We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.


Our Service Providers and Partners

We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.


For further information please visit websites of our partners, here the list including but not limited to:


4. INTERNATIONAL DATA TRANSFERS

Our Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.


5. YOUR RIGHTS AND OPTIONS

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device.


Apple devices:

  • Open Settings
  • Select Privacy
  • Select Advertising and enable "Limit Ad Tracking"

Android devices:

    Open Settings Select Google Select Ads and enable "Opt out of Ads Personalization"

Access the personal data we hold about you

If you request, we will provide you a copy of your personal data in an electronic format.

Your other rights

You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.


We will respond to all requests within a reasonable timeframe. You may also contact your local data protection authority within the EEA for unresolved complaints.


Opt-out of marketing emails and other direct marketing

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.


6. COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may then not function properly.


7. HOW DO WE PROTECT YOUR DATA

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.


Data retention

We keep your information only so long as we need it to provide our Services to you and fulfill the purposes described in this Privacy Policy. We do periodic status checks to review when personal data needs to be deleted. However, as we process your personal data for various purposes, the actual period for which the personal data will be stored will depend on the circumstances. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that we cannot identify you.


8. AGE LIMITS

We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 16 and over. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.


9. CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS

If you are a California resident, the California Consumer Privacy Act (CCPA) gives you the right to request disclosure of information that we collect about you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information). This section describes how to exercise those rights and our process of handling those requests. We reserve the right to ask for reasonable information to verify your identity before we process your request.


Right to know


You may submit once a year, free of charge, a verifiable request to disclose what personal information we collect about you. The easiest way to submit a request is to use the in-app support feature (“Contact Us”) in our games. You may also submit your request via e-mail at bizdev@outloud.games


Right to delete


You have the right to request that we delete any of your personal information we collected and retained, subject to certain exceptions. Once we receive and verify your consumer request, we will delete your personal information from our records. However, we may deny your deletion request if retaining the information is necessary for us or our service providers under certain circumstances, which will be explained to you at the time of the denial, if any. Should you wish any information about you deleted, you may use the in-app support feature (“Contact Us”) in our games or submit your request via e-mail at bizdev@outloud.games


Right to opt-out


You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances we may share your information with our partners, who help us deliver advertisements in our games tailored to your interests. To learn what information we collect and how we share it with third parties for advertising purposes, please, visit out partners policies.


If you would prefer that your personal information is not shared with third parties in this way, please, check clause 5. of this privacy policy.


Right to be free from discrimination


We may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny your our Services; (ii) charge you different prices or rates for our Services; (iii) provide you a different level or quality of Services; (iv) suggest that you may receive a different price or rate for Services or a different level or quality of Services.


Authorized agents


You may exercise your CCPA rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. We reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, we may deny the request.


10. CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact us at bizdev@outloud.games