PRIVACY POLICY

This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We are Omuamua Studios Pvt Ltd., a company under laws of India, developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

1. INFORMATION WE COLLECT FROM YOU

Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publisher’s Games. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information).

The information that we may collect about you through the Services broadly falls into the following categories:

(a) Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit inquiries to us, such as:

your name, email address or other details, necessary to process your inquiries;
any information you submit to our support team via email.
The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.

(b) Information that we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

Data and analytics about your use of our Services (e.g. in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, the means by which you were referred to our Services)
Your IP address and device identifiers such as your Advertising ID, Device ID numbers.
Your device type and the operating system that you use
Your Service communications (e.g. in-game emotion signals which you exchange with other players)
Broad geographic location (e.g. country or city-level location) based on your IP address

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for the mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt-out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt-out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Device identifier/information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Some of this information may be collected through cookies as explained further under the heading Cookies below.

(c) Information we obtain from third-party sources

Third-party service providers. We may receive personal information about you from third-party sources. We may get your personal information for example when you installed our Game and prior to installing you have clicked an advertisement for the same Game.
Advertising partners. From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of one of our Games in other publisher’s game), we will be provided with information from which ad network and advertising campaign the install originated from.

2. HOW WE USE YOUR INFORMATION

2.1. In General

We use the information we collect about you/your device to deliver services and our Games to you and to operate our business. We use it also for improving our services and Games, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Games in our Games and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations.

We use your information for the following purposes:

Delivering and improving our services. We use your information for developing, delivering and improving our Games and other products, services, and content, tailoring our products and services, providing Game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Games, and administering the Games.


Displaying advertisements. We use your information for showing advertisements for our Games in other publisher’s apps and for displaying third-party advertisements in our Games. Please see more in the Advertising Section of this Privacy Policy.


Cross-promotion. We use your information for cross-promoting our Games and services, meaning to promote one of our Games while you are playing a different Game of ours.


Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.


Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Games, gathering demographic information about our user base, data about where the Game was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example, to track potential problems or trends with our Games and services, or to test our new game features and content.
Security. We use your information for enhancing the safety and security of our Games, products, and services.
Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.

3. HOW WE SHARE YOUR INFORMATION

We cannot provide all the services necessary for the successful operation of the Games by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

Our analytics providers. We use third-party analytics such as Unity, Firebase, Tenjin, Game analytics for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking feature.


Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform;


Our tracking and fraud prevention providers. For some of our Games, we use tracking and fraud prevention providers, such as Tenjin for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such providers may use APIs, and SDKs in our Games to enable them to collect and analyze user and device-related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.
Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Games for free or at a low cost.


Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.
Other third-party service providers. For our Games, we use Unity Software to develop such Games. For the data processing by Unity please see Unity’s privacy policy available at https://unity3d.com/legal/privacy-policy. For some Games, we partner with third-party development studios to develop such Games. Such third-party development studios do not have access to your personal information, they can only access aggregated data that they cannot trace back to you.


We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Games. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.

4.ADVERTISING

4.1. In General

We use advertising to fund our Services and to make our games available for free. We offer our Games for free and in order to do that we need to share the information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base.

If you are a European Economic Area (EEA) – based user be aware that:

(a) When you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR.We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.

(b) Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at the relevant button at the loading of the Game. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you ACCEPT to show you personalized ads at the loading of the Game. The list of our current advertising partners with links to their privacy policies is available here. The legal basis to show personalized ads to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve our Games and provide the player with more relevant ads. You have an option to withdraw your consent to share your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Game settings and clicking the terms & Privacy button therein, in section Personalized Ads Consent Withdrawal of the Privacy Policy you will be able to manage your preferences by choosing to which advertising you would like to get. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

4.2. In-game advertising (i.e. when you view ads in Our Games)

To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads.

Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

limit the number of times you see the same ad;
ensure they are dealing with humans with real devices and not ‘automated’ bots;
serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as an intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;
keep track of what games you have used to market you similar kinds of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at the city level).

4.3. View of Our ads on third-party services

We also advertise Games in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs).

The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ games);
informing players, that have not been playing for a while, about new content in the Game. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content;
not showing ads on a game that a player is already playing. We can send a list of active players in the form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad;
marketing games to a group of potential players.

6. COOKIES

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.


We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options for our Service.

7. CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 16 (“Children”). When we collect personal information, we do not know the age of our players. We do not knowingly collect personally identifiable information from children under 16. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 16 without verification of parental consent, we will take steps to remove that information from our servers.

8. Does Omuamua Games actually "sell" personal data?

Omuamua Games does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, Omuamua Games does not sell your data.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us to exercise your right to withdraw your consent on sharing your personal data with third parties.