We at Spiral Interactive Ltd. (“Spiral“, “we”, “us”, “our”)
recognize and respect the importance of maintaining the privacy of our users.
This Privacy Notice (the “Notice“) describes the ways your personal data is collected and used on our mobile applications (each an “App”). It also describes the rights and options available to you with respect to your information.
PERSONAL DATA WE COLLECT
We collect the following information from users of our App. This is also the information we have collected about users of our App in the past 12 months. The source of all personal information we collect is the App users themselves.
|Categories of Personal Information||Specific Types of Personal Information Collected|
|Identifiers||Name, Facebook unique user ID (only when connected to the App via Facebook), email address.|
|Information that identifies, relates to, describes, or is capable of being associated with, a particular individual||Facebook unique user ID, gender, country, birthdate, name and your in-game Facebook friends, inquiry information, player profile, survey answers.|
|Commercial information||Information about the amount of purchase, units purchased, currency, date of purchase and a copy of the receipt.|
|Internet or other electronic network activity information||Online identifiers, such as advertiser ID (IDFA on iOS device) and Android ID (for Android devices), the device type and operating system; its language, time zone settings, and screen resolution; the IP address of the device, and the country, city and region corresponding to that IP address; time and date of access to the App, game events and actions you took while using the App, such as game levels attempted, bets made, offers presented and accepted and game achievements.|
IN MORE DETAIL:
We collect information associated with your device
We collect your mobile device’s online identifiers, such as advertiser ID (IDFA on iOS device) and Android ID (for Android devices). We also collect the device type and operating system, its locale (language), your time zone settings on the device, the screen resolution on your device, the IP address that your device uses for Internet connectivity and the country, city and region corresponding to that IP address. We refer to all of this as “Device Information“.
You do not have a legal duty to provide the information. However, the App cannot operate without collecting this information
If you connect to the App with Facebook, we will retrieve information from your Facebook
If you choose to log on to the App with your Facebook account, we will obtain the following information from your Facebook profile: a unique user ID created by Facebook, your gender, country, birthdate, name and your in-game Facebook friends. We refer to this as “Facebook Information“. Note that at any time, you can withdraw your consent to us processing your Facebook Information. When you make an in-app purchase, we will collect information relating to the purchase.
When you make an in-app purchase, we will collect information relating to the purchase.
When you make an in-app purchase, we obtain information about the amount of purchase, units purchased, currency, date of purchase and a copy of the receipt. We do not, however, collect your payment method information (e.g., credit card information). We refer to this as “Purchase Information“.
When collect information from your inquiry, if you contact us with one
If you submit an inquiry via email, we will have your email address as well as any other information you share with us in the course of your Inquiry. We refer to this as “Inquiry Information”.
We also collect analytical information about your use of the App.
When you use the App, we will record and collect certain information in relation to your use of the App: time and date of access, game events and actions you took while using the App, such as game levels attempted, bets made, offers presented and accepted and game achievements. We refer to this as “Analytical Information“.
The overall personal data outlined above will be referred to as the “Information“.
Note that once you remove the App from your smartphone device, we will no longer collect additional information from you.
We collect information in order to create your in-game Player Profile.
Your Player Profile will consist of information gathered from the following sources.
Facebook Information. Your name and your country of origin will be automatically derived from your Facebook account when you login. It is up to you whether to log in with your Facebook account or not. If you wish to be able to edit these details on your Player’s Profile you need to remove your game’s connection with Facebook and start using the App without it.
User-Selected Information. Information provided by you independently, that you can control and edit, such as your favorite game, your ‘what’s on your mind’ status and the Avatar you choose to play the game with.
Automatically Populated Information. This information consists of your level and tier in the game, ‘online now’ indicator the number of mutual friends and their list.
The information in your Player Profile will be publicly displayed for other players to see. However, you can opt-out of having this information displayed publicly.
Survey Information. From time to time, we will perform online and offline researches via surveys. Participation in surveys is voluntary.
HOW WE USE PERSONAL DATA
The following are the business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided above. More details about the business or commercial purposes are provided below.
|Categories of Personal Information||Business or commercial purposes pursuant to the CCPA||Specific purposes|
|Identifiers||Auditing relating to a current transaction with the customer.
Providing customer service, processing or fulfilling orders and transactions, verifying customer information.
|To provide our products and services
To verify your identity
To communicate with you
To improve our products and services and prevent fraud
|Information that identifies, relates to, describes, or is capable of being associated with, a particular individual|
|Internet or other electronic network activity information||Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal
activity, prosecuting those responsible for that activity.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality of the service and to improve, upgrade or enhance the service.
Debugging to identify and repair errors.
IN MORE DETAIL
To provide you the App’s features, functionality and game experience.
We use Device Information, Analytical Information, Purchase Information, Player Profile and Facebook Information to provide you the App’s features, functionality and game experience, including in-app notifications, promotions and offers.
For technical troubleshooting of the App and to provide user support
We use Device Information, Analytical Information, Purchase Information and Facebook Information for technical troubleshooting of the App and to provide user support.
To respond to your inquiry
We will use your Inquiry Information to contact you about your inquiry and handle your inquiry. To address your inquiry, we will also use your Device Information, Facebook Information, Purchase Information and Analytical Information, depending on the nature of your inquiry.
For App marketing purposes
We use Device Information, Analytical Information, Purchase Information and Facebook Information to optimize and improve our advertising and user acquisition activities.
For App and business development.
If you choose to participate in a survey, we will use the information that we collect in the survey for research and reporting purposes, and to help us to improve the quality of our Apps and services. We use the survey responses to characterize typical player profiles (groups). This will help us deliver a more tailored App experience. We also use the survey responses to determine the effectiveness of our services, including the quality of our communications and our functionality and game experience and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
For financial record-keeping purposes
We use Purchase Information for financial book-keeping purposes.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent. These are also the categories of third parties with whom Spiral has disclosed personal information in the preceding 12 months.
We share your personal information with our subsidiaries.
We will share your Information with members of our family group of companies, who help us process the data for the purpose set out above.
We share your Information with our service providers helping us operate our business and the App
We will share your personal information with our service providers who assist us with the internal operations of the App. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes.
We share Analytical Information and Purchase Information with advertising providers
We will share your Analytical Information with third party advertising companies, who will use the data for ad serving and user acquisition purposes.
Your Player Profile will be publicly accessible to other users
The information in your Player Profile will be publicly displayed for other players to see. However, you can opt-out of having this information displayed publicly.
We will share your Information with competent authorities, if you violated the terms of your engagement
We will share your Information if we are legally required to do so.
If we are required to disclose your information by a judicial, governmental or regulatory authority.
We will share your Information with a third-party in any event of change in Spiral’s
If the operation of the App is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information to enable the structural change.
We do not sell your information
Note that we do not sell your personal data to any third party and have not done so in the preceding 12 months.
SECURITY AND DATA RETENTION
We will retain your personal information for as long as we need it to operate the App, and thereafter as needed
for record-keeping matters.
We retain personal data for the duration needed to support our ordinary business activities operating the App. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
We implement measures to secure your Information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.
THIRD PARTY CONTENT
We have no control over third-party content presented on the App and are not responsible for the privacy
policies of such third parties
Portions of the App link to or present content from third parties, including ads. We have no control over this third-party content and are not responsible for the privacy policies of such third parties. We do not endorse any products offered by third parties and we urge our users to exercise discretion in their reliance on third party content.
ADDITIONAL INFORMATION FOR USERS IN THE EU
Spiral Interactive Ltd is the data controller of the personal data we collect via the App.
Spiral Interactive Ltd. (“we”, “us”, “our”) is the data controller for the purposes of the personal data we collect via the App and for the performance of the services offered through the App.
We are based at P.O. Box 10, Bar Lev Industrial Park, Misgav 20156, Israel
To contact our European representative
If you are within the European Economic Area, you may contact our European representative at the following address:
3rd Griva Digeni Av, Patsalos House, 5th floor, 6030, Larnaca, Cyprus
Legal bases for processing your information
Our legal bases for processing information to provide you the App’s features, functionality and game experience, is its necessity for the fulfillment of our contract with you under the Terms.
Our legal basis for processing information for technical troubleshooting of the App, for user support, and for inquiries, is our legitimate interests in operating the App and our business.
Our legal basis for processing information for App marketing purposes is your consent.
Our legal basis for processing Survey Information is your consent when you participate in the survey.
Our legal basis for processing Player Profile information and publicly sharing it with other users is our legitimate interests in enhancing the social-sharing component of the App’s business.
We will transfer your Information internationally only in accordance with applicable data protection
Spiral is based in Israel. Information we collect from you will be processed in Israel, which is recognized by the European Commission as having adequate protection for personal data.
If we transfer your Information from within Europe to other jurisdictions outside Europe, this will be done under the terms of a data transfer agreement which contain standard data protection contract clauses with adequate safeguards determined by the EU Commission.
You have certain rights to access, update or delete your information, obtain a copy of your Information,
withdraw your consent and object or restrict certain data processing activities
If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Withdraw Consent to processing your personal data, at any time. If you do that, we will still process certain information on legal basis other than consent, as described in this Notice. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at firstname.lastname@example.org.
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
ADDITIONAL INFORMATION FOR USERS WHO ARE CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
If you are a California resident you have the following rights with regards to your personal information:
|Disclosure of Personal Information We Collect About You||You have the right to know:
· The categories of personal information we have collected about you;
· The categories of sources from which the personal information is collected;
· Our business or commercial purpose for collecting personal information;
· The categories of third parties with whom we share personal information, if any;
· The specific pieces of personal information we have collected about you.
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we
· Delete your personal information from our records; and
· Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
· Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
· Debug to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
· Comply with the California Electronic Communications Privacy Act;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
· Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
· Comply with an existing legal obligation; or
· Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your
rights under the CCPA. This means we cannot, among other things:
· Deny goods or services to you;
· Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
· Provide a different level or quality of goods or services to you; or
· Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
|Designate an authorized agent to submit CCPA requests on your behalf||You may designate an authorized agent to make a request under the CCPA on your behalf. To do
so, you need to provide the authorized agent written permission to do so and the agent will need to
submit to us proof that they have been authorized by you. We will also require that you verify your own
identity, as explained below.
- Email/ write us at: email@example.com.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing
the personal data requested to you, by using a two or three points of data verification process, depending on
the type of information you require. If you have a password protected account with Spiral, we may ask to verify
your request through the account’s existing authentication methods. If you request that we disclose or delete
your information, we will require you to re-authenticate with your account.
We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You must be 18 years of age or older in order to use the Service.
The Service is not intended for minors under the age of 18. IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE IN ANY WAY.
CHANGES TO THIS PRIVACY NOTICE
If we change this Notice, we will provide you notice of such change through the App.
From time to time, we may change this Notice, in which case we will inform you of the updated Policy through the App. The latest version of the Notice will always be accessible on the App.
Last Update: April 26, 2022