DJINNWORKS GMBH PRIVACY POLICY

INTRODUCTION

Thank you for choosing to be part of our community at Djinnworks GmbH (“Djinnworks”, “company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@djinnworks-prime.com.

For the purposes of data protection laws, Djinnworks GmbH is the data controller of your personal information. In order to maintain the high quality and great user experience and to personalise our services, respond to queries and to monitor the use of our services, we process information from and about you.

When you visit our website https://www.djinnworks-prime.com, use our mobile applications and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our apps and our services.

This privacy policy applies to all information collected through our mobile applications, (“Apps“), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the „Sites“). 

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. 

1. WHAT INFORMATION DO WE COLLECT?  

A. Information about You That You Share with Us Directly

When you use our Services, we will store the information you provide us directly on our systems and use it for the purposes described in this privacy policy.

Some Apps use an account set-up process where you will be asked to give us certain information, including:

• your username
• your e-mail address
• a password

If you sign in through or link to your social media profile, information associated with your profiles on that social network will be stored.

• your name
• your player profile picture

If you make a purchase in our Services, such as a license to use in-app virtual currency or virtual items in an app you play, we will store the overall value of your purchases.

B. Information We Collect Automatically

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

We collect information about your visit, use or navigate within the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes. 

If you play Djinnworks Apps in combination with a link to your social media profile (such as Facebook), we automatically receive certain information about you from the social network which includes

• your first and your last name
• your profile picture or its URL

As we use tracking technologies, we and service providers acting on our behalf, like Game Analytics, store log files and use tracking technologies such as:

• device identifiers such as the IDFA on mobile devices and
• cookies on our websites, which are small pieces of data transferred to your mobile device or computer that enable us to (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

We and our service providers use these technologies to collect and analyze certain kinds of technical information, such as

• the type of mobile device you are using
• your operating system version and platform type
• your mobile device’s identifiers, such as your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI)
• App activity
• App state and the date and time of activity our Apps

Third Party Advertising and Analytics, and those practices are subject to those companies’ own policies.

If you play Djinnworks Apps using account set-up process we may also automatically collect:

• your device configuration
• your game progress
• the individual offers you have received
• your activity within the App
• your inventory
• statistics about your progress

2. HOW DO WE USE YOUR INFORMATION?  

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.  

We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests („Business Purposes“), in order to enter into or perform a contract with you („Contractual“), with your consent („Consent“), and/or for compliance with our legal obligations („Legal Reasons“). We indicate the specific processing grounds we rely on next to each purpose listed below.  

We use the information for the following purposes:

• To facilitate account creation and logon process with your consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
• To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
• Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, services, marketing and your experience.  
• To provide technical support and respond to player inquiries
• To prevent fraud or potentially illegal activities
• To enforce our Terms of Service
• To manage and deliver contextual and behavioral advertising
• To notify players of in-app updates, new products or promotional offers
• To comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties

If you provide your e-mail address to Djinnworks, we will use it to respond to your customer support inquiries.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?  

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.   

We only share and disclose your information in the following situations: 

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.  
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology in the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.   
• With your Consent. We may disclose your personal information for any other purpose with your consent.  
• Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.  

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  

We use technologies like cookies (small files stored by your browser or operating system), web beacons, or unique device identifiers to anonymously identify your computer or device. Our systems also logs information like your browser, operating system, IP address and anonymous usage data  so we can deliver a better experience.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?  

If you choose to log in to our Apps using a social media account, we may have access to certain information about you.  

Our Apps offer you the ability login using your third party social media account details (like your Facebook logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.  

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.   

6. WHAT IS OUR STANCE ON THIRD-PARTY SERVICES?  

The Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Apps. You should review the policies of such third parties and contact them directly to respond to your questions. 

7. HOW LONG DO WE KEEP YOUR INFORMATION?  

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.  

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?  

We aim to protect your personal information through a system of organizational and technical security measures.  

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.  

9. WHAT ARE YOUR PRIVACY RIGHTS?  

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.  

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.   

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm 

Account Information  

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.   

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.  

Regarding cookies and similar technologies, most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps.

Regarding Opting out of email marketing, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may contact us using the contact information provided.   

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?  

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.   

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. DO WE MAKE UPDATES TO THIS POLICY?  

Yes, we will update this policy as necessary to stay compliant with relevant laws.  

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

If you have any further questions or comments about us or our policies, email us at support@djinnworks-prime.com or by post to: 

Djinnworks GmbH  

Weidingerweg 22   

A – 4600 Wels  

Austria   

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us anytime. We will respond to your request within 30 days.

Last edit by: Heiko Hufnagl

on Jun 04, 2018