Effective Date: September 22, 2022
Table of Contents:
- About Us.
- Information We Collect.
- How We Use the Information We Collect.
- Maximum Information Retention Period.
- How We Share Information.
- How to Control Information.
- Third-Party Services.
- International Transfers.
- Contact Us.
- Representation for data subjects in the EU.
SuperSonic Studios Ltd. (“SuperSonic Studios”) develops and publishes game titles for mobile devices (each game title, “Title”).
We collect information in either of 2 ways:
Directly – through the Titles. For this purpose, we also engage with analytics partners that collect the information on our behalf.
Indirectly– through our advertising and analytics partners.
Information We Collect
Information collected through our Titles, and information provided to us by advertising and analytics partners:
- Advertising ID – Advertising ID refers to the Google Advertising ID (“GAID“) on Android devices, or ID For Advertising (“IDFA“) on iOS devices. The Advertising ID is a resettable persistent identifier generated by Android or iOS that allows online advertising companies to recognize a device across apps, for advertising purposes. Additional information about how to limit our use of the Advertising ID can be found under “How to Control Information”.
- IP address of the device.
- A unique ID generated by our advertising partners to recognize a device in a specific Title.
- ID of a device which is unique only to our Titles.
- The device type and language, operating system name and version.
- The device’s time zone.
- The amount of free memory on the device.
- The name and version of the Title.
- Battery status.
- The name of the mobile carrier.
- The device’s internet connection type (e.g., Wi-Fi).
Information received from advertising and analytics partners:
- Campaign information – An indication if an ad of a Title was viewed or clicked.
- The total amount of revenues received as a result of advertising served to a specific device.
How We Use the Information We Collect:
We use the information we collect mainly to provide services to players of our Titles. In addition, we use the information for the following purposes:
- to improve and optimize the Titles and our players’ experiences;
- to provide players with information about our Titles, including in-game updates, new Titles, and promotional offers;
- to provide technical support;
- to protect the safety and well-being of our players;
- to protect SuperSonic Studio’s rights and property in connection with the Titles;
- to prevent fraud or potentially illegal activities;
- to manage and deliver advertising, including for the purpose of analytics, measuring the effectiveness of ads, limiting the number of ads served, generating aggregated reports, and attribution;
- to administer rewards, or other promotional activities or events sponsored or managed by us or our business partners;
- To conduct marketing campaigns across our advertising and marketing partners, including campaigns that use audience lists created based on player interactions with the Titles;
- to comply with our legal obligations, resolve any disputes we may have with players, and to enforce our agreements with third parties;
- to conduct research.
The GDPR Angle:
Under the GDPR, we rely on the following legal basis for the processing of personal data:
- We process personal data for providing services to players of our Titles for the performance of our contract with them.
- We process personal data for the purposes of preventing fraud or potentially illegal activities, protecting our rights and property, serving advertising (except for personalized advertising), conducting marketing campaigns (except for audience lists based campaigns), improving and optimizing the Titles, providing information and promotional offers to players of our titles, administering rewards and conducting research, based on our legitimate interests.
- We, or our advertising partners, may process personal data for the purpose of serving personalized advertising, game usage analytics, or conducting marketing campaigns based on audience lists and creating such audience lists, if we, or our advertising partners, obtained that player’s consent.
- We may also process your personal data for compliance with applicable legal obligations.
The CCPA Angle:
Personal Information We Collect, Disclose for a Business Purpose, and Sell – We collect the categories of personal information about California users identified in the chart below. As further set forth in the chart below, in the past 12 months, we have disclosed and sold personal information about California users to third parties for business or commercial purposes.
Recipients of California Personal Information – Although we do not sell personal information for monetary consideration, we do sell personal information under the definition of “sale” in the CCPA, subject to our players’ choices with respect to “sale” of personal information, to the categories of third parties listed below:
- Advertising partners;
- Analytics partners;
Maximum Information Retention Period:
How We Share Information:
We share information with:
Other advertising partners – for the purpose of receiving, or delivering, advertising campaigns from such advertising partners.
Our corporate affiliates – from which we receive services, such as IT, security, storage, and other internal operations.
Advertisers – for the purposes of attribution.
Analytics partners – for the purpose of receiving analytics services.
Service providers – We share your information with our service providers for the purpose of receiving services such as fraud detection and prevention, analytics, reporting, and storage.
We may also disclose information if we have a good faith belief that disclosure of such information is reasonably necessary to:
- Comply with any applicable law, regulation, legal process or governmental request.
- Enforce our agreements and policies, including investigations of potential violations thereof.
- Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues.
- Establish or exercise our rights to defend against legal claims.
- Prevent harm to the rights, property or safety of us, our users, yourself or any third party.
- Collaborate with law enforcement agencies or in case we find it necessary to enforce intellectual property or other legal rights.
- When we are undergoing any change in control, including by means of merger, acquisition, or purchase of all or substantially all of our assets.
- The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected personal information, our purposes for collecting or selling personal information, the categories of personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
- The right to request that we delete the personal information we have collected from you or maintain about you.
- The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
How to Control Information:
Collection of device data – Updated versions of iOS, and Android, enable you to control how apps can collect the Advertising ID. please follow the below instructions:
iOS devices (iOS 14+): go to Settings > Privacy > Tracking > Allow Apps to Request to Track. Please note that if you use more than one device, you need to opt-out separately in each device
Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that if you use more than one device, you need to opt-out separately in each device.
The GDPR Angle:
Withdraw consent – You have the right to withdraw the consent you provided to us from within each of our Titles (this will affect only our processing within the specific Title), or by following the instructions above on how to control collection of device data (this will affect our processing of data in all our Titles on your device).
Data subject rights – Please note that you have the right to request from us access to and rectification or erasure of your personal data we process as controllers, or to restrict or to object to processing of your personal data in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please send an email with your request to the following address: firstname.lastname@example.org. Please note that we will process your request subject to verification of your identity.
Complaint to supervisory authority– You also have the right to file a complaint with the relevant supervisory authority (e.g., of your country or domicile) where SuperSonic Studios has not addressed your concerns.
The CCPA Angle:
Your Rights Regarding Personal Information – California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
Exercise your rights – To exercise your rights to know and to delete personal information, please contact us by sending an email to email@example.com.
To exercise your right to opt out of sale of your personal information, please open the privacy settings in the Supersonic app in which you would like to opt out, and toggle on the Do Not Sell My Personal Information button. For more information on how you can exercise your rights you may also call our toll-free phone number: +1(888)835-5392.
Verification Process and Required Information – Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address. We will also collect information that identifies your device when you submit a request in order to help us verify your identity.
Authorized Agent – You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and providing the agent with written permission to make the request on your behalf.
Information about California resident requests in 2021
SueprSonic Studios does not knowingly collect or maintain personal information collected online from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information without parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act without your required consent, please contact us at firstname.lastname@example.org and we will make reasonable efforts to delete the information from our records.
The GDPR Angle:
We do not collect or otherwise process personal data from individuals in the European Economic Area the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to perform the agreement with such individuals, to comply with law or to support our legitimate interests as described above.
The CCPA Angle:
We do not sell the personal information of minors under 16 years of age.
We store information that we collect from your device on our service providers’ servers in the United States. Accordingly, please note that if you do not live in the United States, we will transfer your information to and store it in, the United States.
The GDPR Angle:
Supersonic Studios is based in Israel, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State Residents.
We will transfer personal data to third parties located outside of the European Economic Area, the United Kingdom, or Switzerland based on standard contractual clauses. You can ask us for a copy of these clauses by contacting us through the below contact details.
SuperSonic Studios Ltd.
121 Menachem Begin Rd., Tel Aviv, Israel
Representation for data subjects in the EU
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website https://prighter.com/q/19023432211