GoodStore Ecom, its subsidiaries and affiliates (“Company” or “we” ) respects the privacy of the users (“User” or “you”) of the mobile applications we distribute (“Apps”) and are committed to protect Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps.
IMPORTANT -We operate Apps for all ages:
We do not knowingly collect any personal information from children other than as expressly specified in Sections 2.2 and 2.3 below.
We hereby prohibit children from actively and directly providing us with any personal information other than as specified in Section 2.3 below. If you are a legal guardian of a child and believe your child has provided us with any personal information, please contact us at email@example.com and we will delete such information from our servers.
We may collect and maintain the information described in Section 2, directly or through certain products or services, solely for providing support for our internal operations as permitted under applicable laws and rules (described in greater detail below).
We include an age-gate in certain Apps to prevent access to specific features to Users who indicate they are under the age of 16 for their protection (e.g. restricting behavioral advertising or information sharing by children).
1. Offline Use
We allow an offline use (without Internet connection and without GPS enablement) of some features of our Children Apps. Offline use of Children Apps will preclude collection by us and/or Third Parties of any information pertaining to the User and its use of the Children Apps.
2. Online Use
There are three types of data and information which may be collected from Users of our Children Apps:
2.1 Non-personal Information: We and our Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such children Non-personal Information, we and the Third Parties are not aware of the identity of the User from whom children Non-personal Information has been collected. Children Non-personal Information collected by us or our Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Children Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s gameplay (e.g. level reached, frequency and time spent in the Children App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Children Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), our other installed Apps, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 16), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.
2.2 Children’ Persistent Device Identifier and No Other children personal identifiable information: We and our Third Parties may passively collect a persistent device identifier from children, such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address (“Children Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Children Apps. In the case of IP addresses, we keep these for 1 week for error logs, then delete them. We do not collect and do not permit Third Parties to collect from children any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about children. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.
We do not link any additional personally identifiable information to the Children Persistent Device Identifier, even from other services.
We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning children.
2.3 Information gathered through Children Apps “Ask a Question” or “Support” type of a feature: If a child e-mails a question to us, using the “Ask a Question” or “Support” type of a feature which may be available within Children Apps, we may respond to such question by using the child’s e-mail address. Promptly after responding (or, at our discretion, not responding) to such question, we will delete the child’s e-mail address.
Purpose of the collection: The information described above is collected and processed solely for the purpose of supporting our internal operations. This means the following:
(i) providing and improving Children Apps as well as ensuring proper functioning of the Apps and services;
(ii) maintaining or analyzing the functioning of Children Apps and services;
(iii) authenticating Users (e.g. verify the User’s identity when he/she interacts with advertisements or acquires in-app purchases);
(iv) personalizing content and enhancing User experience;
(v) performing network communications;
(vi) protecting the security or integrity of Users, Children Apps and services;
(vii) serving contextual advertisements;
(viii) capping the frequency of advertising;
(ix) ensuring legal or regulatory compliance;
(x) fulfilling a User’s request under Section 2.3.
The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.
How is the Information about our Users of Children Apps being collected? The Non-personal Information and Children Persistent Device Identifier are collected by us or our Third Parties through the Users’ use of Children Apps, including through Third Parties’ SDKs embedded in our Children Apps. Non-personal Information and the Children Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Children Apps, such as “cookies-like technology” and local storage (see Section 18 below for further details on Cookies and Local Storage).
3. Sharing Children information with third parties
We may share the Children Persistent Device Identifier only in limited cases, including the following:
a. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
c. to detect, prevent, or otherwise address fraud, security or technical issues;
d. to protect the rights, property, or personal safety of the Company, its Users, suppliers, licencors, and/or licensees, or the general public;
e. when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
f. pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or the User of Children Apps may have requested from the Company.
To clarify, we may transfer and disclose Children Non-personal Information to third parties at its discretion.
In addition, we may advertise our other Apps within Children Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random Apps.
5. Additional Terms and Conditions
6. Which information may be processed from Users of our GoodStore Ecom Apps?
There are two types of information which may be processed about Users of our GoodStore Ecom Apps:
6.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). We and our Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to us and/or our Third Parties through use by Users of the GoodStore Ecom Apps. For details of the categories of data constituting Non-personal Information please refer to Section 2.1 above.
6.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.
● the User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;
- the User’s persistent device identifier such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address. We keep IP addresses for 1 week for error logs and then delete them. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable Platform Provider’s rules, policies and guidelines.
In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 17.
To clarify, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Users.
7. How is the Information about Our Users collected?
7.1 Non-personal Information may be collected through your use of the GoodStore Ecom Apps. In other words, when you are using a GoodStore Ecom App, we and our Third Parties are aware of it and may gather information relating to such usage, through the GoodStore Ecom Apps, APIs or SDK embedded in our GoodStore Ecom Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the GoodStore Ecom Apps, such as “cookies” and local storage (see Section 16 below for further details with respect to Cookies and Local Storage).
7.2 Personal Information which you provide us directly and/or through Third Parties via your installation and/or use of the GoodStore Ecom Apps or your behavior to ads inside such Apps. This information is collected via the GoodStore Ecom Apps or such Third Parties’ APIs or SDKs embedded in our GoodStore Ecom Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the GoodStore Ecom Apps, such as “cookies” and local storage (see Section 16 below for further details about Cookies and Local Storage).
7.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides us through the GoodStore Ecom Apps “Ask a Question” type of feature. In addition, we collect Personal Information which you voluntarily provide when you use the Facebook login feature (detailed above).
8. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
● Use it for statistical, analytical and research or business intelligence purposes (e.g., to track trends within our GoodStore Ecom Apps, for reports and for public relations purposes); and for customization, development and improvement of our GoodStore Ecom Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on behavior and preferences shown by Users usage within the GoodStore Ecom Apps).
● Measure traffic and usage on the GoodStore Ecom Apps.
● Promote our Apps.
Personal Information is collected in order to:
● Personalize and enhance the Users’ experience while using the GoodStore Ecom Apps.
● Improve the GoodStore Ecom Apps.
● Provide the Users with personalized content and information, including customized ads, interest-based ads, targeted ads, etc.
● Enable certain ad serving features, such as frequency capping etc.
● Enable certain functionalities available within the Apps, for example in-app purchases.
● Ensure proper functioning of the Apps and services, respond to questions or requests which were provided using the “Ask a Question” feature.
● Enable the User to use the Game Center Features, the Social Features and the features which are available while using the “Log in with Facebook” feature.
● Provide Users with updated information regarding our products and services, including about competitions which we may hold, where Users have asked us to do so.
● To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User’s participation.
● Authentication purposes including to verify clicks and/or installs, verify User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.
● Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the User (i.e. behavioral ads).
● Any other purpose explained at the time of collection.
9. Sharing Information with other third parties
In addition to the sharing of Personal Information with Third Parties described in sections 6-8, we may share Personal Information in the following cases:
a. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
c. to detect, prevent, or otherwise address fraud, security or technical issues;
d. to respond to claims that any content published on the GoodStore Ecom Apps violates any right of a third-party;
e. to protect the rights, property or personal safety of the Company, its Users, suppliers, licensors, licensees or the general public;
f. when the Company undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case your Personal Information may also be disclosed, transferred and/or assigned;
g. pursuant to your explicit approval prior to the disclosure;
h. as part of a competition, receiving rewards or otherwise interact with our social media channels..
For clarity, we may transfer and disclose Non-personal Information to third parties at its discretion.
Please note that some of the GoodStore Ecom Apps include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. We do not access or use this User Generated Content in any way. It is stored locally on your device. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.
We accept ads in various formats (such as banners, interstitials, rewarded videos, etc.) from Third Party ad networks which may be displayed in our GoodStore Ecom Apps. These Third Party ad networks may collect and use: (i) information about your visits to GoodStore Ecom Apps in connection with such marketing, sales and advertising activities; and (ii) geographic tracking and carrier network preferences; (iii) information, such as age, gender and other information logged from your device to ensure that appropriate advertising is presented within the App, to calculate or control the number of views of an ad, to deliver ads relating to User’s interests and to measure the effectiveness of ad campaigns. The delivery of ads to you may be based on IP address, device identifiers and other Personal Information gathered during your use of the GoodStore Ecom Apps. You may also be presented with non-personalised or non-targeted ads, i.e. ads which are not directed towards specific Users but are rather broadly posted onto random Apps. If you have chosen to receive non-personalized ads only within our Apps, please be aware that you may still see some targeted ads served by third parties if you have separately (e.g. on that third party’s website or app) provided consent to personalized advertising directly to those third parties.
We may promote GoodStore Ecom Apps in Third Parties applications and platforms. In addition, we may, at our discretion, advertise our other Apps within the GoodStore Ecom Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random Apps.
11. Using Game Center Features and Social Features
Our GoodStore Ecom Apps may enable using certain Game Center Features and may include Social Features (defined in our TOU). The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”).
By using the Social Features and/or the Game Center Features you understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby acknowledge that when you share content via Social Networks or Platforms your content may become public and any person may re-post-it.
12. Additional Terms and Conditions
13. Third Party Providers
14. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. We do not exercise control of such third parties and is not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.
15. Links to third party sites
16. Cookies & Local Storage
17. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifier or limiting ad tracking setting. If you are using a Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent such options exist) may not cease all tracking activities by our Third Parties’ service providers.
If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such Third Parties and follow the instructions specified therein. with instructions on how to opt-out when available.
You have the right to withdraw your consent to sharing your Personal Information for the purposes of personalized ads at any time by going to the applicable GoodStore Ecom App settings, clicking the Privacy Settings option and toggling the disable personalized ads button. This will withdraw consent to such processing across all GoodStore Ecom Apps within the same developer account on the applicable online store.
18. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as making transfers subject to standard contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. You can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
19. Retention of Information
After you have stopped using the Apps and/or following the termination of your Account, we will retain User’s Personal Information, and, as applicable, Children Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfill the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, to enforce these Terms and our agreements and/or to enable Users to reinstate their Account, all as permitted under applicable privacy laws.
Aggregate and/or anonymous information may remain on our servers indefinitely.
Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. TO THE FULLEST EXTENT PERMITTED BY LAW THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.
22. Got any Questions?
23. What legal bases do we use for processing your personal information?
We process your Personal Information on one of the following legal bases:
- ● Performance of a contract: We use this ground where we process Personal Information to provide you with a service that you have requested e.g. to provide you with access to our Apps, to provide you with customer services and support, to enable in-app purchases you make and to deliver Game Center Features and Social Features.
- ● Legitimate Interests: We process Personal Information for our legitimate interests as a commercial organisation to improve your game experience, provide the Apps securely, for analytics, and fraud detection and prevention activities. Except as explained under the heading “Consent” below, we also process Personal Information for advertising purposes based on our legitimate interests in: i) promoting our own products and services in the context of cross-promotions; ii) providing the Apps for free or at a low cost; iii) ensuring the basic display, functioning and measuring of non-targeted adverts (displaying the ads, linking the ads to views and installs, limiting the number of times the same ads are shown, combating abuse and fraud); and iv) carrying out related analytics (after anonymization where possible – to help ensure that ads are working, optimized and displayed correctly). In all of these cases we will look after your information at all times in a way that is proportionate and respects Your privacy rights and You have a right to object to processing as explained in the “Your Rights” section below.
- ● Consent:We rely on your consent to process your Personal Information for other aspects of advertising, including the provision and management of interest-based or targeted advertising as well as analytics and reporting regarding advertising in general, and to share Personal Information with Third Parties for these purposes. We ask for this consent when you download and access our App. If you choose to provide consent to processing for these purposes, please be aware that this consent covers such processing in this App and any other Apps within the same developer account (i.e. GoodStore Ecom) on the applicable online store that you download and use. You can withdraw consent at any time by adjusting the privacy settings within the App as described in section 17 above. This will withdraw your consent across all Apps within the same developer account (GoodStore Ecom as applicable) on the applicable online store which you have downloaded and are using. Within the privacy settings of the App you will also find an option to request deletion of your Personal Information by clicking on the “forget me” button.
- ● Legal Obligation: In certain circumstances, we may be required to comply with a legal obligation or by a court, regulator or law enforcement agency to process Personal Information for specific purposes or to share it with such an authority. This would only be after due consideration of the request and legal means available to respond thereto.
24. Your rights
As well as the rights explained in Chapter C, users in the EEA have the following additional rights (please note that these are subject to certain exemptions and in some cases dependent on the processing being undertaken):
- ● Right to access Personal Information
You have a right to request that we provide you with a copy of your Personal Information that we hold and you have the right to be informed of: (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.
- ● Right to rectify or erase Personal Information
You have a right to request that we rectify inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it.
You can also request that we erase your Personal Information in limited circumstances, for example, where it is no longer necessary for the purposes for which it was collected, or where our processing was based on consent, and you withdraw your consent.
If Third Parties have collected your Personal Information through the Apps, we will use reasonable efforts to inform the Third Parties of your request for deletion.
If you have shared your Personal Information via any Social Network or third party Platform we cannot amend or delete this information. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps.
- ● Right to restrict the processing of your Personal Information in certain instances
- ● Right to transfer your Personal Information
You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- – the processing is based on your consent or on the performance of a contract with you; and
- – the processing is carried out by automated means.
- ● Right to object to the processing of your Personal Information
You can object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
If you want to opt out of all future collection of your Personal Data by us and our Third Parties, you can do this by uninstalling the Apps from your devices.
- ● Right to obtain a copy of Personal Information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside of the EEA. We may redact data transfer agreements to protect commercial terms.
- ● Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.