Funtra Games Privacy Policy

Last updated: June 8, 2022

This privacy policy (“Privacy Policy”) explains how we, Funtra Games Ltd. (“Funtra Games”, “we”, “us”, “our”) collect, use, share and otherwise process Personal Data in connection with your use of our mobile application and website (“App” and “Services”).

When we refer to “Personal Data” in this Privacy Policy, we mean data which relates to an identified or reasonably identifiable individual. This does not include aggregated, non-personal, anonymous, or statistical data, even if it is derived from Personal Data. Other capitalized terms used in this Privacy Policy which are not defined, have the meaning given to them in our Terms of Service, which govern your access and use of the Services.

We may update this Privacy Policy from time to time in order to keep you apprised of our data collection and use practices. Such changes will come into effect ten (10) days following the posting of the new Privacy Policy. We therefore encourage you to return and review this Privacy Policy from time to time.

Table of Contents

  1. What Information We collect and How We Use It
  1. When you visit our application (automatically collected data)
  2. When you receive our push notifications or to receive updates or other communications from us
  1. Automatically collected information: SDKs and Cookies
  2. How (and with whom) we Share Personal Data
  1. Cloud and Hosting Services
  2. Law Enforcement or other Government Entities
  3. With your Consent
  4. Disputes
  5. Mergers and Acquisitions
  6. Affiliates
  7. Additional Information on our Service Providers
  1. How Long we Retain Personal Data
  2. Your GDPR Rights
  3. Transfers of Personal Data to other Countries Outside the EU or EEA
  4. Your California Privacy Rights
  1. Disclosure of Direct Marketing Practices (“Shine the Light”)
  2. Removal of Public Information of Minors
  1. California Do Not Track Notice
  2. How (and With Whom) We Share Personal Data
  3. Personal Data of Children
  4. Anonymous Information
  5. Contact Us

  1. What Information We Collect and How We Use It

We collect and receive Personal Data from outside our company and affiliates, such as from users of our products and services as described in the table below. Certain Personal Data is collected automatically, while other Personal Data is provided by you voluntarily, for example, when you contact us. The description in the table may be supplemented by additional information in other parts of this Policy. For example, you may find for more information on third-parties to whom your information may be transferred in Section 3 below.

When we Collect Data

Type of Personal Data we Collect

Purposes of Processing the Data

Retention Period (How long we store the data)*

Legal Basis under the GDPR

Third Parties with Whom We Share your Personal Data**

Consequences of not Providing the Personal Data

1.1 When you access our App

(automatically collected data)*

  • Device Information: such as IDFA, Android Ad ID, IDFV, MAC address.
  • User device information: such as IP, Operating system identifier.
  • Location information
  • Game play activity and actions
  • Log information such as: IP address, browser information, cookie information, login data, language preferences, time of access and tome zone settings etc,
  • Developer Software information
  • Facebook audience network
  • Analysis of App activity
  • protecting the security of the App;
  • Enable App functionality;
  • Identify unique users, track user activity on the App.
  • Display and personalization of advertisements.

  • Your consent
  • Legitimate interest (e.g. essential cookies)
  • Google
  • Unity
  • Facebook
  • Depending on the cookie Type you may not be able to access or use the App.

1.2 When you  receive our  push notifications to receive updates or other communications from us

  • Consents
  • Token number
  • Send you our newsletter and other marketing communications.
  • when you unsubscribe from the Push Notifications.
  • Your consent.
  • Google
  • Unity
  • We will not be able to send you communications.

  1. Automatically Collected Information: SDKs and Cookies*

When you visit and use the Services we automatically collect information about you, your device, location and your activities on the App. To do so we, or our third party service providers or partners may employ tracking technology such cookies, web beacons, pixels, SDKs or other tools.  

Software Development Kits (shorten as SDKs) are programming packages that allow us to develop the App and designed it to work on or with a specific platform. The Analytics SDK will allow us or our third parties to track and measure certain data about the way users interact with our App.

Analytics SDKs collect information about our App usage including data about many users are using the app, the number of sessions running on an app and how long each session is, from where in the world these users are logged in from, how many times an app is crashing, what operating systems and devices are running the app, the amount of money spent within apps by users, and how many times certain app features are used. By seeing how an app is used with the information gathered through an Analytics SDK, an app can be accordingly improved (please review other purposes in the table above).

Cookies may be used for different purposes such as: (i) allowing you to navigate between pages efficiently, (ii) enabling automatic activation of certain features, (iii) remembering your preferences, and (iv) making the interaction between you and our Services quicker and easier. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising).You can find more information about cookies at www.allaboutcookies.org.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies and SDKs, or receive a warning before a cookie is stored. You may remove cookies by following the instructions in your device preferences. However, please note that if you choose to disable cookies, some features of our Platform may not operate properly and your online experience may be limited.

  1. How (and with whom) we Share Personal Data

In addition to the ways in which we share or allows others to collect or access Personal Data described above, we may disclose or share Personal Data with third parties in order to use the data for the purposes listed above, including in the following ways:

  1. Cloud and Hosting Services. We use cloud storage provider to host the Services and store all information we collect. We currently Google Drive for such services and in addition to the third parties listed in Section ‎1 and 2 above, copies of all data we collect are stored on their servers

  1. Law Enforcement or Other Government Entities. We may disclose Personal Data relating to you when we believe we are required to do so by any law, regulation or government or court order, or in order to prevent, investigate, or mitigate any harm or damage to any person, entity or property, or any misconduct or negligence.

  1. With your Consent. In the event that you have requested or have consented to the transfer of Personal Data relating to you to a third party (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.

  1. Disputes and Legal Advice. In case of any dispute or request with, by or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.

  1. Mergers and Acquisitions. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users, to the purchaser or the entity with which we are merged.

  1. Affiliates. We share personal data with our affiliates, who assist us in processing personal data and providing our Services.

  1. Additional information on our Service Providers (listed in Section 1). To help you understand where data about you is transferred, here is more information about the service providers listed above whom we engage to process Personal Data that we collect. Where such service providers have made available information about their data security or processing practices which we think is relevant to you, we have provided links to such information. We take no responsibility for information found on their websites, including, without limitation, whether it is accurate or up-to-date. Please note that the listing of these service providers in this Privacy Policy is not a guarantee or undertaking that only these service providers will be used. We may change service providers or add news ones. We make commercial reasonable efforts to update this Privacy Policy to reflect these changes.
  • Unity Gaming Services provides us an end-to-end platform that is designed to help us build, operate, and manage our game. You can read more about Unity Gaming Services' legal policy in connection with the data received from its customers in https://unity3d.com/legal/privacy-policy.
  • Unity Ads provides us with solutions for placing and filling ads in our game, as well as for fininding and acquiring players. You can read more about Unity Ads' legal policy in connection with the data received from its customers in https://unity3d.com/legal/privacy-policy
  • Facebook SDK enables mobile developers to build Facebook apps through tracking analytics, data trends prediction, insights on the traffic and more.  You can read more about Facebook SDK's legal policy in connection with the data received from its customers in https://www.facebook.com/about/privacy .
  • Google Analytics is a sales platform that helps us optimize the prospecting workflow by allowing sales representatives to find, capture, and sequence contact data directly. You can read more about LeadIQ Inc legal policy in connection with the data received from its customers in https://leadiq.com/legal/privacy-policy.

  1. How Long We Retain Personal Data

We may store Personal Data for longer periods of time than stated in Section 1 above: (i) where we believe we are required to do so to comply with laws or in connection with legal proceedings; (ii) to resolve disputes; (iii) to enforce agreements between us and others; (iv) when the information is related to a potential or actual legal dispute.

Please note that if we receive Personal Data relating to you in multiple contexts, such as if you have separately provided information or we have another basis to use it, then we may keep such information for the longer of the periods listed in this Privacy Policy. For example, you are a customer or are a representative of a customer who has subscribe to receive our push notifications but later unsubscribes, then we will retain such information for the period listed in connection with customer or business contact information as described in this Privacy Policy, even if we remove you from the applicable email list.

  1. Your GDPR Rights.

Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member state or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:

  • Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

  • Right to Rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, you may also request to complete incomplete Personal Data we maintain.

  • Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.

  • Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.

  • Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.

  • Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.

  • Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, when the decision produces legal effects concerning you or significantly affects you.

  • Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.

  • Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.  

You can exercise your rights that apply to us by contacting us by email at privacy@funtra.games. We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

  1. Transfers of Personal Data to other Countries outside the EU or EEA

We transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and European Economic Area. If Personal Data from the EU is transferred outside the EU to our affiliates or to third-party service providers, to countries which the European Commission has not determined to adequately protect Personal Data, we take steps to ensure that such Personal Data receives the same level of protection as if it remained within the EU. This includes entering into data transfer agreements and using the European Commission approved Standard Contractual Clauses.

  • The United States, is where Facebook, Unity and Google store information they receive from us.

If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).

  1. Your California Privacy Rights

If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at privacy@funtra.games. Please note that certain exceptions may apply.

  1. Disclosure of Direct Marketing Practices (“Shine the Light”). Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties. This right only applies if our relationship is primarily for your personal, family or household purposes and related to the purchase of our products and services.
  2. Removal of Public Information of Minors. If you are under the age of 16 and have an account with us, under California Business and Professions Code Section 22581, you may request the removal of content or information you have publicly posted on our services that is identified with you or your account. Please be aware that certain exceptions may apply and we may not be able to completely remove all such information.

  1. California Do Not Track Notice.

                

We do not track individuals’ online activities over time and across third-party web sites or online services (though we do receive information about the webpage you visited prior to access our websites, products and services such as our Website, social media accounts, and advertisement landing pages). We do permit third-parties to track individuals’ online activities on our Site and App, including Google and Facebook which provide us with the analytics and tracking services described above. We do not respond to Web browser “do not track” signals or similar mechanisms. You can find out more information about do not track signals at: http://www.allaboutdnt.com/.

  1. Third Party Sites & Content

The Services may include content provide or made available by third parties (“Third Party Content”) or link to other websites or applications of third parties (“Third Party Sites”). When interact with Third Party Content or you arrive at any such Third Party Site information may be automatically collected or you may provide information about yourself. Funtra Games is not responsible for the data collection and use practices of third parties in connection with Third Party Content or Third Party Sites. We recommend that learn about the privacy practices of any Third Party Site or Third Party Content before providing them with any Personal Data or interacting with the Third Party Content or Third Party Sites.

  1. Personal Data of Children. 

The Services are not intended for, and we do not intentionally collect Personal Data from persons under the age of sixteen (16). If you believe that a person under the age of sixteen (16) has provided us with Personal Data, or if we have received the Personal Data of such person, please contact us at privacy@funtra.games 

  1. Anonymous Information.

We do not treat information we collect or receive which cannot be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or reasonably be used to identify any particular person as Personal Data even if it was originally linked to or stored with or as Personal Data. We use anonymous information internally for a variety of purposes, and may share it with third parties or even publish it for any reason.

  1. Contact Us

Please contact us with any questions you may have about this Privacy Policy or our Personal Data practices at privacy@funtra.games or by address at Krinizi 73, Ramat Gan, Israel.