Effective Date: November 7, 2021
Table of Contents:
- About Us.
- Information We Collect.
- How We Use the Information We Collect.
- Maximum Information Retention Period.
- How We Share Your Information.
- How to Control Your 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 – from your device through the Titles. For this purpose, we engage with analytics partners that collect the information on our behalf.
Indirectly– through our advertising and analytics partners.
These disclosures cover laws and regulations applicable to the following regions:
Individuals who we deem to be located in the European Economic Area, the United Kingdom or Switzerland – With respect to the collection and processing of their personal data, as defined by the General Data Protection Regulation (“GDPR”), and the UK Data Protection Act.
Information We Collect
Information collected directly from you through our SDK, and information provided to us by advertising and analytics partners:
- Identifiers associated with your device:
- Advertising ID of the device – Advertising ID refers to 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 non-affiliated apps. Additional information about how to limit our use of your Advertising ID can be found under “How to Control Your Information”.
- The IP address of the device.
- Information about the device type and settings known as “User Agent“.
- The ID For Vendors (“IDFV“, on iOS devices), which is a persistent identifier that allows companies to recognize a device across apps of a specific vendor.
- 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.
- The battery status.
- The device’s limit ad tracking status.
- The name of the manufacturer of the device.
- The name of the mobile carrier.
- The device’s internet connection type (e.g., Wi-Fi).
Information received from advertising and analytics partners
– The total amount of revenues received as a result of advertising served to a specific device ID.
How We Use the Information We Collect:
We use the information we collect mainly to provide you with the Services you request from us. In addition, we use the information for the following purposes:
- to improve and optimize the Titles and our players’ experiences;
- to communicate with you about the Titles you’re using, including in-game updates, new Titles, and promotional offers that we think might be of interest to you;
- to provide technical support and respond to player inquiries;
- 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 contextual and behavioral advertising, including for the purpose of 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 personalized campaigns based on your interactions with the Titles;
- 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;
- to conduct research.
The GDPR Angle:
- We process personal data for providing you with the Services on the basis of our contract with you.
- We process personal data for the purposes of preventing fraud or potentially illegal activities, protecting our rights and property, serving contextual advertising, conducting non-personalized marketing campaigns, improving and optimizing the Titles and our players’ experiences, communicating with you about the titles you are using, administering rewards and conducting research, based on our legitimate interests.
- We, or our advertising partners, may process your personal data for the purpose of serving you with personalized advertising, or conducting personalized marketing campaigns based on your interactions with our Titles, if we, or our advertising partners, obtained your 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.
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 your choices with respect to “sale” of personal information, to the categories of third parties listed below::
- Advertising/marketing companies;
- Analytics companies; and
- Attribution companies.
Maximum Information Retention Period:
We will keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights.
How We Share Your Information:
We share your information with:
Other advertising and marketing 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, delivery of advertising campaigns, personalized advertising, and other internal operations.
Advertisers – for the purposes of attribution.
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.
How to Control Your Information:
Opt out from personalized ads
If you do not want us to transfer your information to third parties for personalized ads, please follow the below instructions:
iOS devices: go to Settings > Privacy > Advertising > enable Limit Ad Tracking.
Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/2662922?hl=en.
Scope of the opt-out
Please note that if you use more than one device, you need to opt-out separately in each device. In addition, if you reset your advertising ID through your device’s platform settings, you should follow the steps above to reset your opt-out choice. Please note that opting out may not stop data from being collected from your device or transferred for other, non-personalized advertising purposes such as optimization, reporting, frequency capping, internal operations, and fraud prevention.
The GDPR Angle:
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: email@example.com. 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:
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 your personal information, our purposes for collecting or selling your personal information, the categories of your 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.
Exercise your rights – To exercise your rights to know and to delete personal information, please contact us by sending an email to firstname.lastname@example.org.
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 name and 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 2020 – We did not receive any requests under the CCPA in 2020.
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 email@example.com 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.
We store information that we collect from your device on our analytics partners’ 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:
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we will only transfer your information to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
When we enter into EU standard contractual clauses (“Model Contracts”) for the transfer of information, 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/19359051762