31 Games Limited Privacy Policy
Last Updated: November 15, 2024
This privacy policy explains how we, as data controllers, process (i.e., collect, record, organize, structure, store, adjust or alter, retrieve, consult, use, disclose, disseminate or otherwise make available, adjust or combine, restrict, erase, or destroy) your personal information, as well as how you can exercise your privacy rights. We are 31 Games Limited, a developer and publisher of games and mobile game applications, and our products and applications are available through app stores, including the Apple App Store and Google Play Store. This privacy policy applies to the personal information we collect through our games, mobile applications, and other products (collectively referred to as "Services"). By using our Services, you agree to be bound by this privacy policy and consent to our processing of information as described herein.
1. Information We Collect From You
Most of the information we collect about you comes directly from your interactions with our games or with third-party advertisements in our games or other publishers' games. Generally, the information we collect about you relates to the type of device you use, information that helps us identify your device, how you play our games, and may include information you voluntarily submit to us when you contact us. We may also collect information from app store platforms, 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 we may collect about you through our Services can be broadly categorized as follows:
(a) Information You Provide Voluntarily
Certain parts of our Services may require you to voluntarily provide personal information. For example, we may ask you to provide certain information to submit an inquiry to us, such as:
- Your name, email address, phone number, or other contact information to process your inquiry;
- Any information you submit to our support team via email.
We will make efforts to explain the personal information we request and the reasons for requesting this information when we ask you to provide personal information.
(b) Information We Collect Automatically
When you use our Services, we may also automatically collect certain information 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., game progress, levels, games played, session length, preferred settings, in-game advertisements you may have viewed, in-game references, or simply game preferences, and how you were referred to use our Services).
- Your IP address and device identifiers, such as your advertising ID and device ID (for more information, see here: Advertising ID and Device ID).
The advertising ID refers to the Identifier for Advertisers (IDFA) on Apple and the Google Advertising Identifier (GAID). These are unique identifiers for mobile devices used by advertisers to personalize ads. They are consistent across all mobile applications, allowing for cross-app tracking. On Apple, you can opt-out by selecting the "Limit Ad Tracking" option in your privacy settings. On Google Android, you can opt-out by selecting "Opt-Out of Personalized Ads." The advertising ID is a non-permanent, non-personal identifier that is uniquely associated with your device.
Device identifiers/information refers to the type of device, device model, device manufacturer, device operating system and its language, or other technical data (such as screen size or processor), or a combination of these data provided by the device for developers to check compatibility with specific applications.
(c) Information We Obtain From Third-Party Sources
- Third-Party Social Networks: Google Play Games Services, Apple Game Center, Facebook ("Third-Party Social Networks"). You may choose to connect to our Services through your social media accounts. The specific information we receive from your social media will depend on your social media privacy settings, but generally includes your basic public profile information, such as your username, gender, and friends who play the same game (see also the section below on "Third-Party Social Networks").
- Third-Party Service Providers: We may receive personal information about you from third-party sources. For example, when you install our game and click on an advertisement for the same game before installation, we may obtain your personal information.
- Advertising Partners: We may also receive personal information about you from other third-party sources. For instance, if you click on an advertisement that directs you to one of our Services (e.g., an advertisement for our game displayed in another publisher's game), we will obtain information about which advertising network and campaign the installation originated from (see also the section below on "Advertising").
(d) No Special Categories of Information
We do not request or intend to collect any "special categories of information," such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data used for the unique identification of natural persons, data concerning health, or data concerning a natural person's sex life or sexual orientation. Please exercise caution when sharing such information about yourself (or others) on our forums.
2. How We Use Your Information
(a) Overall
We use the information collected about you/your device to provide you with our Services and games and to operate our business. We also use this information to improve our Services and games, enhance security, and conduct analysis and research to ensure we provide you with the best experience. Additionally, we use your information to promote our Services and games within our games and in other publishers' applications, and to show you third-party advertisements. We also use your information for advertising tracking and fraud prevention, as well as to fulfill our legal obligations.
We will use your information for the following purposes:
- Provide and Improve Our Services: We will use your information to develop, provide, and improve our games and other products, services, and content, customize our products and services, provide game updates, troubleshoot technical issues, understand and analyze trends related to game usage, and manage the games.
- Display Advertisements: We use your information to display advertisements for our games in other publishers' applications and to show third-party advertisements in our games. Please refer to the advertising section of this privacy policy for more information.
- Cross-Promotion: We will use your information to cross-promote our games and services, meaning we will promote one of our games while you are playing our other games.
- Tracking and Fraud Prevention for Advertising Purposes: We use your information to track the effectiveness of our advertising campaigns and to identify and prevent fraudulent activities related to those campaigns.
- Analysis and Research: We use your information to understand and analyze trends related to game usage, collect demographic information about our user base, and gather data on the sources of game downloads. We may also create reports and analyses for research or business intelligence purposes, such as tracking potential issues or trends with our games and services or testing new game features and content.
- Security: We use your information to enhance the security of our games, products, and services.
- Customer Support: We use your information to provide customer support and respond to your inquiries.
- Our Legal Obligations: We will use your information when required by law, for example, we will use your country or region for tax reporting purposes.
(b) In-App Purchases
Our games support in-app purchases. We do not process payments for in-app purchases and do not have access to your credit card information.
Payment transactions for in-app purchases are completed through your App Store account, Google Play account, or Amazon.com account in the app stores. Any post-purchase processes are controlled by Apple, Google, and Amazon.com stores and are subject to the specific terms of those Apple, Google, and Amazon.com stores. Please review the privacy policies and terms of service of your Apple, Google, and Amazon.com stores.
3. How We Share Your Information
We cannot provide all the services necessary for the successful operation of our games on our own. Therefore, we must share the information we collect with third parties in order to develop and provide our services, display advertisements, conduct analysis and research, and measure the effectiveness of our advertising campaigns with our partners. We also reserve the right to disclose your information (including personally identifiable information) as required by law, and to disclose your information in an anonymous and aggregated manner, meaning you cannot be identified from it.
We may share such information with:
- Our Analytics Providers: We use third-party analytics tools (e.g., TapJoy, Unity, Firebase) to provide our services, conduct analysis and research. The device data we share with these providers is encoded. Providers may assign a random ID to this data and cannot match it to you. We can aggregate data for benchmarking purposes.
- Our Cloud Service Providers: We store the 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 (e.g., AppsFlyer, Tenjin) to measure effectiveness and optimize our advertising campaigns, display advertisements, conduct analysis to improve our services, and for fraud prevention purposes. These providers may use APIs and SDKs in our games to collect and analyze data and information related to users and devices, such as impressions, clicks, installs, or other advertising campaign performance metrics, as well as in-app events post-installation.
- Third-Party Advertising Partners: We have contracted with certain third-party advertising networks to assist us in delivering advertisements to you, allowing us to continue providing games for free or at a low cost.
- Third-Party Tracking Providers of Advertising Partners: We allow our advertising partners to track impressions, clicks, installs, or other advertising campaign performance metrics through their tracking providers to measure the effectiveness of their advertising campaigns. 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 information on Unity's data processing, please refer to Unity's privacy policy at https://unity3d.com/legal/privacy-policy. For certain games, we collaborate with third-party development studios to develop such games. These third-party development studios do not have access to your personal information; they can only access aggregated data that cannot be traced back to you.
We may enter into agreements with other partners in the future or replace existing partners to provide any services related to the games. These changes will be updated from time to time or promptly updated when there are significant changes in our data processing practices.
We provide a list of current service providers and partners:
| Third-Party Service Provider | Privacy Policy Link |
| Google SDK | https://policies.google.cn/privacy |
| firebase SDK | https://policies.google.cn/privacy |
| unity SDK | https://unity3d.com/legal/privacy-policy |
| Applovin SDK | https://www.applovin.com/privacy/ |
| Appsflyer SDK | https://www.appsflyer.com/legal/privacy-policy/ |
| facebook SDK | https://www.facebook.com/about/privacy/update |
| fyber SDK | https://www.digitalturbine.com/legal/privacy-policy |
| bigo SDK | https://www.adsbigo.com/privacy.html |
| inmobi SDK | https://www.inmobi.com/privacy-policy-for-eea/ |
| Mintegral SDK | https://www.mintegral.com/en/privacy/ |
| pangle SDK | https://www.pangle.cn/privacy |
| TradPlus SDK | https://www.tradplusad.com/privacy-policy |
| vungle SDK | http://vungle.com/privacy/ |
| yandex SDK | https://yandex.com/legal/confidential/ |
| maticoo SDK | https://www.yuque.com/yuque/qeyyk7/bl95f1imynp9u6pg?view=doc_embed&title=0 |
| Sanyi SDK | https://www.31gamestudio.com/policy.html |
| bugly SDK | https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56 |
We reserve the right to disclose your information (including personally identifiable information) in accordance with legal requirements, legal processes, litigation, and/or requests from public and governmental authorities inside and outside your country/region. If we determine that disclosure is necessary or appropriate for national security, law enforcement, or other public important issues, we may also disclose information about you. Additionally, if we determine that disclosure is reasonable and necessary to enforce our terms and conditions or to protect our operations, users, or user experience, we may also disclose information about you. Furthermore, in the event of a reorganization, merger, or sale, we may transfer any and all information we collect (including personally identifiable information) to the relevant third parties.
For any further questions regarding third-party information collection, please refer to privacy-cyprus@playgendary.com.
4. Advertising
(a) General
We utilize advertising to fund our services and provide our games for free. We offer our games for free or at a low cost, and to achieve this, we need to share the information collected from you with third-party advertising partners. To protect your privacy, we only temporarily store personal information. The information collected helps us improve our website and games while keeping our games free for a wide audience.
If you are a user in the European Economic Area (EEA), please note:
(1) When you use our games, we rely on our legitimate interests to display advertisements to you. The legal basis for displaying advertisements to EEA users is the legitimate interests under Article 6(1)(f) of the GDPR, which we have assessed together with our Data Protection Officer. Additionally, in accordance with Article 28 of the GDPR, data processing agreements have been signed with external ad tech provider networks. We also ensure that our external service providers are committed to a high level of data protection by entering into data protection agreements.
(2) Before sharing any information with our advertising partners for personalized advertising, we will always obtain your consent, which is when you press "Accept" on the relevant button when loading the game. We only allow our advertising partners to show you personalized advertisements if you press "Accept" in the relevant pop-up and agree to share your personal information for personalized advertising. Our advertising partners use different technologies to implement personalized advertising, which process your personal information in various ways. Therefore, before you consent to personalized advertising when loading the game, please review their data processing practices. A list of our current advertising partners and links to their privacy policies are available for review. The legal basis for displaying personalized advertisements to EEA users is consent under Article 6(1)(a) of the GDPR. Additionally, in accordance with Article 28 of the GDPR, we have signed data processing agreements with external ad tech provider networks. We also ensure that our external service providers are committed to a high level of data protection through data protection agreements. The purpose is to improve our games and provide players with more relevant advertisements.You can always choose to withdraw your consent for sharing personal information for personalized advertising purposes. You can withdraw your consent by going to the game settings and clicking the Terms and Privacy button. In the personalized advertising consent withdrawal section of the Privacy Policy, you will be able to manage your preferences by selecting the type of advertisements you wish to receive. When you decide to withdraw your consent or choose not to provide your consent, you may still see the same number of advertisements on your mobile device; however, these advertisements may be less relevant as they are not based on your preferred topics, interests, behaviors, demographics, etc. Our advertising partners may continue to show you advertisements based on the content of the application you are using.
(b) In-Game Advertising (i.e., when you view ads within our games)
To enable us to display in-game advertisements, we may send your advertising ID and IP address to advertisers (or ad networks) so they can find suitable ads for our games and third-party properties. You can control and limit our use of your advertising ID in your device settings. While we cannot control which specific ads are shown in our games (this is managed by ad networks), we do blacklist certain categories of advertisements.
Ad networks use advertising IDs for various purposes (see the privacy statements of our listed advertising partners), including:
- Limiting the number of times you see the same ad;
- Ensuring they interact with real devices rather than “automated” bots;
- Providing ads that may be relevant to you based on your interactions with other brands and ads, recorded using your advertising ID and approximate geographic location. Other brands purchase ad space via ad networks or ad exchanges to promote their products within our games. Ad networks or ad exchanges act as intermediaries between other game companies and us. To allow ad networks to charge the companies purchasing ads, metrics like ad clicks and potential app installations from other developers are tracked. Ad views, click rates, and installation numbers are measured using the advertiser ID;
- Tracking games you have interacted with to promote games of a similar type to you. Advertisers typically use IP addresses to approximate your general geographic area (e.g., country, state, and sometimes city level).
(c) Viewing Our Ads on Third-Party Services
We also promote our games in other apps by displaying ads to audiences who may be interested (identified using advertising IDs) through ad networks.
Ad networks use advertising IDs for various purposes (see the privacy statements of our listed advertising partners), including:
- Measuring the effectiveness of advertisements (e.g., aggregate views, clicks, and installations resulting from ads placed in other publishers’ games);
- Informing players who haven’t played our game for a long time about new content in the game. We provide a list of these users in the form of advertising IDs to ad networks, which then display ads about the new content to these users;
- Excluding ads from being shown in the game a player is currently playing. We can send a list of active players in the form of advertising IDs to ad networks, which then exclude these players from advertisements;
- Marketing the game to a group of potential players.
(d) Who Can Show You Personalized Ads?
Please refer to the list of advertising providers allowed to show personalized ads and review their data processing practices, including the technologies they use for personalized advertising.
(e) How to Disable Personalized Ads?
In addition to the specific tools provided through the game for EEA users, you can also use your device settings:
iOS
Open the “Settings” app on iOS, select the “Privacy” menu item, and then choose the “Advertising” subsection. If you activate the “Limit Ad Tracking” option, we will only take limited measures, such as identifying unique users or combating fraud. In the same menu, you can delete the IDFA at any time (“Reset Advertising ID”), which will create a new ID that will not be merged with previously collected data.
Android
Open the “Settings” app and select the “Google” menu item. Depending on your device, this option may not appear in the main menu, but you can use the search function at the top of the “Settings” menu to find it. From there, select the “Ads” subsection and activate the “Opt out of Ads Personalization” option to prevent profile creation and personalized ads. You can also delete the advertising ID at any time in the same menu (“Reset Advertising ID”), which will create a new ID that will not be merged with previously collected data.
5. Third-Party Social Networks
(a) Connecting to Third-Party Social Networks
Some of our games use third-party services, such as Google Play Games Services, Apple Game Center, and Facebook (“Third-Party Social Networks”). These games allow you to log into your Third-Party Social Network account and connect to our application using the “Sign In” feature. You can also share content created within the application on Third-Party Social Networks.
Please note that Third-Party Social Networks are governed by their own privacy policies, terms, and end-user agreements. We are not responsible for the sharing practices or policies of the third parties operating these websites and have no control over them. For further inquiries, please contact us at 31gamestudio@gmail.com.
(b) Information We May Receive When You Connect to Third-Party Social Networks
The information you allow us to access varies depending on the application and is influenced by the privacy settings you have established on these Third-Party Social Networks. You can control these settings and learn more about them through the relevant Third-Party Social Network. When you use the “Sign In” feature, we may access and store some or all of the following information, depending on your permission, the Third-Party Social Network, and your preferences:
(i) Basic information from your public profile, such as your nickname and profile picture;
(ii) Login ID and/or player identifier string;
(iii) Your friends list;
(iv) Any additional information detailed in the notification displayed to you during the “Sign in with...” process.
We may share your name and game data (such as actions, game progress, and scores) within the applicable application with friends or contacts from your Third-Party Social Media Network account who have also used the “Sign in with...” or “Connect to” feature.
The application may also request permission to post information (e.g., status updates) on your behalf to the Third-Party Social Network. Please note that we will only do this with your explicit permission, and we will store your ID and full name for user identification purposes. Other information will only be stored within the application on your device to allow it to communicate directly with the Third-Party Social Network.
(c) How You Share Your Information on Third-Party Social Networks
If you use Third-Party Social Networks to participate in game-related activities, such as leaderboards and multiplayer games, you will share your information (e.g., scores, rankings, and achievements) with other players and the Third-Party Social Network.
6. Cookies
Cookies are small files that may contain an anonymous unique identifier. Cookies are sent to your browser by websites 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 certain features of our services.
7. Children's Privacy
In accordance with applicable laws, we do not knowingly collect or seek personal data from children under the age of 13, nor do we intentionally allow such individuals to use our services. If you are a child, please do not send us any personal data about yourself. If we become aware that we have collected personal data from a child, we will delete that data as soon as possible. If a guardian or parent believes that we may have data from or about a child under 13, please contact us at 31gamestudio@gmail.com so that we can correct the situation.
8. Your Rights
If you are an EEA user, you have certain rights regarding your personal information and how we process it. Some of these rights may be subject to certain exceptions or limitations.
Your rights include:
- The Right to Withdraw Consent under Article 7(3) of the GDPR (For example, you can withdraw your consent for personalized ads by going to "Terms and Privacy" in the game settings and following the instructions in the “Withdrawal of Personalized Ads Consent” section in the privacy policy, applicable only to EEA users).
- The Right to Access Your Data under Article 15 of the GDPR (For example, you can view what data we have collected and stored about you, and whether this data will be shared or sold. To do this, go to “Terms and Privacy” in your game settings and follow the instructions in the “Request Summary of Personal Data” section of the privacy policy, applicable only to EEA users).
- The Right to Rectify Your Data under Article 16 of the GDPR (You can request that we correct any inaccurate personal data we have collected from you or that you have provided to us. For example, if your email address has changed, you can contact us to update your old email address).
- The Right to Erase Your Data under Article 17 of the GDPR (For example, if you want us to delete certain data we have stored about you, you can contact us by going to “Terms and Privacy” in your game settings and following the instructions in the “Request Deletion of Personal Data” section of the privacy policy, applicable only to EEA users).
- The Right to Restrict Processing of Your Personal Information under Article 18 of the GDPR (For example, if you want to restrict processing, you can contact us).
- The Right to Data Portability under Article 20 of the GDPR (For example, if you want to upload your data to another service, you can contact us to receive your data).
- The Right to Object to Our Processing of Your Data under Article 21 of the GDPR (For example, if you disagree with any user analysis processes described in this privacy policy, you can contact us).
- The Right to Opt-Out of “Sharing” and “Selling” Your Data under GDPR regulations (For example, if you do not want your data shared or sold to third parties, please contact us through the contact information in this privacy policy. However, please be aware that such “sharing” and “selling” require your explicit consent, and we do not engage in selling data during the course of providing our services).
- The Right to File a Complaint with Supervisory Authorities under Article 77(1)(f) of the GDPR (For example, you can directly contact a data protection regulatory body).
9. General Terms
Your privacy and security are important to us, and we always pay special attention to ensuring that we process your information legally based on one of the legal bases set forth by the EEA data protection laws applicable to EEA users. We have appointed a Data Protection Officer to help ensure compliance with EEA data protection laws. We store your information for as long as needed to provide our services to you. We may store information for longer periods, but only in a way that cannot be traced back to you. We operate globally and share your information with our partners (please refer to our current list of partners) for the purposes described in the "How We Share Your Information" section above, which may include transferring your personal data outside the European Economic Area (EEA). Please check our privacy policy regularly for any changes.
10. Legal Basis
- Contract Necessity: This covers information processed to provide you with the requested (and agreed upon) services, such as providing and improving our services, offering customer support, providing special features in our games (e.g., in-app chat, multiplayer, leaderboards, and other third-party social network features), and delivering in-app purchase content you have made.
- Legitimate Interests: This covers information processed to pursue our legitimate interests for reasonable purposes, such as ensuring the best experience when using our app, keeping your information secure, and offering our games to you for free or at a low cost. We pay particular attention to your data protection rights, ensuring that they are not overridden by our legitimate interests. We rely on legitimate interests for data processing for purposes such as analysis, tracking and fraud prevention, push notifications, cross-promotion, and contextual advertising.
- Consent: If we ask for your consent to use your data for specific purposes, we will make this clear at the time of collection and explain how you can withdraw your consent. We will always seek your consent before sharing any information with our advertising partners for personalized ads or conducting any surveys.
- Legal Obligations: This covers information processed to comply with legal obligations, such as retaining records for tax purposes.
11. Security
We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of the information we collect, and to prevent unauthorized access and misuse of the information in violation of this privacy policy. While we make commercially reasonable efforts to ensure that your information remains secure while in our custody, please note that no security measures are perfect or invulnerable.
12. Retention
We will store your information for as long as necessary to provide you with our services. We may store information for longer periods, but only in a way that cannot be traced back to you. Once we no longer need the information for the purposes described in this privacy policy, we will delete it immediately, and in any event, no later than five (5) years after your last interaction with all of our games.
In compliance with legal requirements, we will retain your information for the period specified by law. If you request the deletion of your data, we will delete it as outlined in the "Your Rights" section above.
13. Contact Us
If you have any questions or concerns about this privacy policy, please contact us:
- For privacy issues, you can contact us via our privacy email to exercise your rights: 31gamestudio@gmail.com
- Data Protection Officer: If you would like further consultation on related issues, please contact our Data Protection Officer: 31 Games Limited.
14. Supplemental Terms - Specific Jurisdictions
California
If you are a resident of California, the following additional terms apply when you use our services:
(a) Your Rights and Choices
(b) Authorized Agents
Under applicable laws, you may have the right to submit requests through an authorized agent. To designate an authorized agent to exercise your rights on your behalf, please provide evidence that you have granted the agent a power of attorney or written authorization to submit rights requests on your behalf.
(c) Protection of Minors
If you are a parent or guardian, depending on the state you reside in, you may have the right to exercise certain rights on behalf of your child’s account. For example, you can contact us via the email address we provide to request the deletion of your child's account, download account data, or exercise other rights related to your child’s information.
Brazil
If you are a resident of Brazil, the following additional terms apply when you use our services:
(a) Exercising Data Protection Rights
The Brazilian General Data Protection Law (LGPD) grants individuals certain rights regarding their personal data. Therefore, we strive to ensure transparency and access control so that users can benefit from these rights. We will respond to and/or fulfill requests to exercise the following rights in accordance with applicable law and the LGPD:
• Confirm whether your data is being processed;
• Access your data;
• Correct incomplete, inaccurate, or outdated data;
• Anonymize, block, or delete data;
• Portability of personal data to third parties;
• Object to the processing of your personal data;
• Information about the public and private entities with which we share your data;
• Information about the possibility of refusing to provide personal data and the corresponding consequences of withdrawal (if applicable);
• Withdraw your consent;
• Request analysis of decisions based solely on automated processing of your personal data, which may affect your interests, including decisions related to defining your personal, professional, consumer, or credit status or other personal characteristics.
(b) Limitations on Your Rights
In some cases, we may have legitimate reasons not to comply with certain requests. For example, if there is a risk of disclosing our trade secrets or intellectual property, or if the disclosure could have an adverse impact on our business, we may choose not to disclose certain information. Additionally, if maintaining your data is necessary to comply with legal or regulatory obligations, or if such maintenance is required to protect our rights and interests in case of a dispute, we may refuse to comply with a deletion request. If this happens and we cannot comply with your request, we will inform you of the reason we cannot fulfill your request.
If you have any questions about your privacy, your rights, or how to exercise these rights, please contact us using the information in the "Contact Us" section. We are happy to address any concerns regarding the processing of your personal data.
Virginia
Under applicable law (VCDPA), you may have certain rights (subject to legal conditions and scope):