Sinlaa Innovation - Privacy Policy

1. Data Collection
2. Data Usage
3. Storage and Retention
4. Personal Data Deletion and Account Termination
5. Data Sharing
6. Communication
7. Data Security Measures
8. Cookies and Tracking Technologies
9. Advertising
10. Data Transfers
11. Amendments and Governing Version
12. Contact Us

Data Collection

1. Data Collected or Generated Automatically:
   When visitors interact with or use our services, including emails or messages they receive from us or through our services, we may collect or generate technical data about them. We collect or generate such data independently or with the assistance of third-party services, including the use of "cookies" and other tracking technologies (details provided below). This data includes the ability to link, technical usage data, or summarized usage data, such as IP address, in-game identifiers, game statistics, game settings, unique advertising identifiers (such as IDFA; you can reset such IDs by following the instructions below for your operating system), non-personally identifiable device information, operating system, browser, or app version, mobile carrier, location settings, and language. User activities within our services and activities in apps or games (e.g., gameplay/content interactions and advertising data), diagnostic data (e.g., error data and game performance data). We do not use this data to learn the true identity of individuals or their contact details, but mostly to better understand how our users use and engage with our services. The use of such technical data and device data also helps us and our partners to deliver targeted advertisements and content, or provide more effective advertising and content experiences in other ways, to improve overall efficiency and user experience in our services. For more information on our advertising practices, please see Section 9 below.
2. Data Received from You:
   You may provide personal data to us voluntarily, such as when you create an account with us, contact us (via Facebook, Messenger, email, in-game chat, or any other channel, including any support services), post in our forums or public groups, provide your email address to us (e.g., when you sign up to receive newsletters or email-based gifts), participate in competitions, contests, tournaments, and other promotions, make any purchases within any of our games, interact with other users via in-game chat, or when you choose to link your Facebook, Google, or Apple account or similar accounts with any of our games.
3. Data Received from Facebook and Other Channels:
   When you link a game to your Facebook, Google, or Apple account or similar accounts, we may access your public profile (as permitted by you to be "public"), including your full name, email address provided to Facebook, Google, or Apple, gender, profile picture or similar images, location, timezone, and the list of your friends who play the game (along with profile pictures and other public profile data of those individuals). This also helps us to display your and your friends' public profile pictures in the game and to create your in-game friends list. Additionally, we or our advertising partners may receive general data related to the targeting of our advertising campaigns, such as age groups or interests, from Facebook and other marketing channels. We or our partners may also link such general data to other data within our possession for further insights into our advertising practices. To learn more about our advertising practices, please see Section 3 below.
   If you access our services through third parties such as Facebook, Google, or Apple or link our services with any third-party accounts, you should review their terms and conditions and privacy policies. If you are unclear about the information shared with us by third-party applications, please visit the third-party application's website to learn more about their privacy practices.
4. Transaction Data:
   Generally, in-game purchases are processed by the relevant platform service providers (such as Apple, Google, or Facebook), and we do not collect or store your financial information, such as credit card numbers or bank account details. However, we may still receive non-financial personal data related to your purchases, such as name, billing address, email address, and the items you purchase, to process your orders and for our accounting purposes.

Data Usage

1. Contractual Performance: We will use this basis for processing that is necessary to provide the game features, including your social features in the game when you choose to log in with Facebook, Google, or Apple, and the available support services, as well as for sending in-game communications, gifts, and rewards.
2. Consent: In certain limited cases (where you opt-in to receive direct marketing emails by accepting cookies on our website), we will process your personal data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 12.
3. Legitimate Interests: We will process your personal data in accordance with our legitimate interests under the law in maintaining and improving our services and offerings, understanding how our services are used, providing effective in-game and other advertising services, matching users to create in-game friends lists, improving our customer service and support operations, detecting fraud, and protecting and maintaining the security of our users, ourselves, and our services.
4. Legal Compliance: In some cases, we may process your personal data where necessary to comply with legal obligations, such as those set forth in applicable laws or regulations, or if we receive orders from a court or regulatory authority.

1. For convenience, operation, and provision of our services.
2. To verify the identity of our players and allow them access to additional features.
3. For customer care, assistance, and technical support services to our users.
4. To enable you to interact with other players in the game.
5. For the development, customization, and enhancement of our services and user experiences, depending on both aggregate and individual preferences, including using profiling methods to tailor profiles and friend lists specifically for you.
6. For contacting our users (via email, Facebook, push notifications, or other available channels) to send general messages or service-specific messages (such as order confirmations or system maintenance announcements), to reach out to our users for sales promotions (such as game updates, bonuses, new features, VIP services, etc.), and for the convenience, support, and offering of certain activities and promotions.
7. To support and improve our data security measures, including for the purpose of preventing and mitigating risks of fraud, errors, or any unlawful or prohibited activities.
8. For generating aggregate statistical data, non-personalized data, or pseudonymized data (converted into non-personal data) which we or our service providers may use for providing and improving our services.
9. To comply with any relevant laws and regulations.

Data Storage and Retention

Data Deletion and Account Termination

Data Sharing

1. Compliance with Laws, Legal Orders, and Authorities: We may disclose or permit government and law enforcement authorities to access certain personal data pursuant to subpoenas, warrants, court orders (or similar requirements), or as required by applicable laws and regulations. Such disclosure or access may occur with or without notice to you. If we believe in good faith that we are compelled by law to do so, or such disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activities, fraud, or other wrongdoing.
2. Service Providers: We may engage third-party companies, contractors, and service providers to supplement our services (such as hosting services, data analytics services, marketing and advertising agencies and tools, data security and cybersecurity services, fraud detection and prevention services, payment processing services, customer support partners, external auditors and testers, user engagement services, email distribution and monitoring services, session recording, and legal, regulatory, financial, and compliance services) (collectively referred to as "Service Providers"). These Service Providers may access your personal data depending on their specific roles and purposes in facilitating and enhancing our services, and shall process personal data as per the purposes we instruct. Additionally, we may share anonymized, statistical, or aggregate data with our Service Providers for lawful business purposes only.
3. Integration with Third-Party Services: Services may allow you to integrate with certain third-party services, such as connecting your Facebook, Google, or Apple accounts with certain games, logging in with Google, Facebook, or signing in with Apple, or making purchases. In such cases, you will be bound by the terms and conditions and privacy policies of such third parties (such as Apple, Google, or Facebook). Therefore, please ensure that you have read and accepted such terms and conditions and privacy policies in advance. We do not receive or store your passwords for any third-party services.
4. Protection of Rights and Security: We may share your personal data with others, whether or not we notify you, if we believe in good faith that such action is necessary to protect the rights, property, or personal safety of Sinlaa Innovation, our users, or the public.
5. Subsidiaries and Affiliated Companies: We may share personal data internally with various companies within our corporate family for the purposes explained in this privacy policy. Additionally, if Sinlaa Innovation or any of its affiliated companies undergo a change in control, including through merger, acquisition, or asset sale, your personal data may be shared with relevant parties in such events. If we believe that such changes in control may significantly impact the personal data we hold, we will notify you of such events and any available options through email and/or clear notices within our services.

Privacy PolicyCommunication

1. Service Communication: We may contact you to provide important information about our services. For example, we may notify you (via any available method) about changes or updates to our services, billing issues, etc. You will not be able to opt out of receiving such service-related communications.
2. Sales and Marketing Communication: If you opt in to receive such communications from us, we may inform you about services, events, new opportunities, or other information that we believe may be valuable to you. We may deliver such announcements through any available contact channel we have (such as mobile phone or email), through our service, or through our marketing campaigns on websites or other platforms.

Data Security Measures

Cookies and Tracking Technologies

Advertising

Data Transfer

Amendments and Effective Version

Contact Us