Fundoll Global Limited (“Fundoll,” “we,” “our,” or “us”) is the operator and controller of various
mobile applications and other online services and websites (collectively, the “Services”). We are
dedicated to protecting the privacy rights of our online users (“you,” “users,” and “user”), and
have adopted this Privacy Policy to explain how we collect, store, use, disclose, and manage your
personal information and data. This Privacy Policy applies to the Services in which it is posted
only. Unless otherwise stated at the time of collection, this Privacy Policy does not apply to
information collected outside of the Services in which it is posted.
Fundoll is a valid licensee and participating member of the Entertainment Software Rating Board’s
Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily
undertaken this privacy initiative and have had the Services that display an ESRB Privacy Certified
Seal reviewed and certified by ESRB Privacy Certified to meet established online information,
collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to
audits of the Services and other enforcement and accountability mechanisms administered
independently by ESRB Privacy Certified.
If you do not agree with this Privacy Policy or our Terms of Service, please do not access or use
our Services.
Note to Parents
The Services are intended for enjoyment by a broad audience. They are not directed to users under 13
years old (“Children” or “Child”). We do not knowingly collect or store personal information from
Children. However, we do collect information, including personal information, from all users of the
Services, as explained further in Section 1 below. If you believe we may have unintentionally
collected personal information from your Child, please contact us using the information in the
Contact Us section below.
In addition, we urge you to instruct your Children to never give out their real names, addresses,
phone numbers, or other personal information when online, unless you have given them permission to
do so. We also recommend you familiarize yourself with the parental controls available on the
devices you provide to your Child (e.g., mobile phones and tablets) and keep a watchful eye on your
Child’s online activity. If you have any concerns, please contact us immediately using the
information in the Contact Us section below.
Parents/guardians are jointly and severally liable for all acts (including purchases and payments in
the Services) and omissions of their Children when using the Services.
Table of Contents
1. Information We Collect About You
2. How We Use Information We Collect
3. When We Disclosure Your Information
4. Third-Party Links
5. Publicly Posted Information
6. Security
7. Your Privacy Rights
8. Data Retention Policy
9. International Data Transfer of Your Information
10. Changes to this Privacy Policy
11. Contact Us
1. Information We Collect About You
Fundoll collects information you provide directly to us via the Services, certain technical
information automatically when you use our Services, and when other sources (i.e., third parties)
provide it to us. As explained below, some of the information we collect may identify you personally
(whether alone or in combination). This is considered personal information.
A. Information You Provide To Us
There are several opportunities for you to provide or disclose personal information directly to us
via the Services. The decision whether to provide the information to us belongs to you. If you
prefer not to disclose the information, you will still be able to utilize the Services, but may not
be able to utilize all aspects of them. The information you choose to provide to us will either be
processed with your affirmative consent, pursuant to a contractual necessity or in furtherance of
our legitimate business interests.
Profile Information: We collect information about you when you create or modify your profile, set
preferences, and sign-up for or make purchases through the Services. For example, depending on the
Service, you may have the option of adding a display name, profile photo, age, gender, geographic
information and other details to your profile information to be displayed in the Service.
Content you provide through our products: We collect and store content that you send, receive and
share when you use the Services. This content includes any information about you that you may choose
to include. Examples of content we collect and store include but are not limited to: the messages
you post, exchange or reply in message boards, forums or chat areas; information you provide in
connection with a survey or contest; and any feedback you provide to us. Content also includes the
files and links you upload to the Services, including art you create and share with us and other
users in our Services, and pictures and audio recording you upload.
Content you provide through our websites: We also collect content you submit to our websites, which
include social media or social networking websites operated by us (e.g., our Facebook pages). For
example, you provide content to us when you provide feedback or when you participate in any
interactive features, surveys, contests, promotions, activities, or events.
Information you provide through our support channels: The Services also include our customer
services and technical support, where you may choose to submit information regarding a problem you
are experiencing with a Service. Whether you speak to one of our representatives directly or
otherwise engage with our support team (or our third-party service providers), you will be asked to
provide contact information, a summary of the problem you are experiencing, and any other
documentation, screenshots or information that would be helpful in resolving the issue. You may
upload photos and voice messages to customer service. Whatever information you provide will be used
solely to address your request for support.
Payment Information: We collect certain payment and billing information when you purchase certain
paid Services. You might also provide payment information, such as payment card details, which we
collect via secure payment processing services.
B. Information Collected Automatically
We collect certain information automatically from and about the device(s) you utilize to access the
Services and your use of the Services. Specifically, we and/or our third-party service providers
collect your Internet Protocol (IP) address, type of device, operating system, browser type,
language settings, device IDs, mobile advertising IDs (e.g., for Android users, the GPS ADID also
known as the “Google Play Services ID for Android”), MAC address, GSSF ID, usage data (including the
features of the Services you use, and when and how often you use the Services), URLs of
referring/exit pages, and crash data. We use your IP address and/or country preference to
approximate your location (i.e., country and, at times, city) to provide you with a better
experience.
Some of the Services use cookies and similar tracking technologies, such as pixel tags, to
automatically collect information from and about your device(s) and your use of the Services. A
“cookie” is a small file that is saved on your computer or mobile device, which uniquely identifies
your browser and provides information to the cookie sender. Pixel tags are small blocks of code on a
webpage that allow websites to do things like read and place cookies. We also use third-party
software development kits (also known as SDKs) in our mobile apps, which collect information about
your device(s) and use of the Services. These trackers help us to deliver the Services to you, to
improve your user experience and to analyze traffic on and use of the Services. In addition, they
are used for marketing and advertising, including to help us to measure the effectiveness of our
marketing campaigns and potentially for interest-based advertising by third parties.
Third parties that provide support for internal operations, as well as marketing partners and
analytics providers include the following:
· Adjust.com
· AIhelp
· Bugly
· Cs30.net
· Facebook
· Firebase Measurement
· Google APIs
· Google Play Game Services
· Xdrig.com
· Google Voice( for chat support)
C. Information We Receive From Other Sources
We receive information about you from other Service users, from third-party services, from our
related companies, and from our business and channel partners.
Other services you link to your account: We receive information about you when you integrate or link
a third-party service with our Services. For example, if you log into the Services using your Google
credentials, we receive your name and email address as permitted by your Google profile settings in
order to authenticate you. If you log into the Services using your Facebook credentials, we receive
your Facebook username, profile picture, and email address[1] . The information we receive when you
link or integrate our Services with a third-party service depends on the settings, permissions and
privacy policy controlled by that third-party service. You should always check the privacy settings
and notices in these third-party services to understand what data may be disclosed to us or shared
with our Services.
Other Partners: We receive information about you and your activities on and off the Services from
third-party partners, such as advertising and market research partners who provide us with
information about your interest in and engagement with our Services and online advertisements.
Depending on the Services that you are using, some of the information listed above may not be
collected. However, when this information is collected, we consider it to be in furtherance of our
legitimate business interests.
2. How We Use Information We Collect
We process your personal information for the following purposes under a range of legal bases:
Purpose
Legal Basis
To improve, operate, manage, and provide you with the Services
Contract; Legitimate interests
To perform services requested by you, including to fulfill your orders, respond to your support
requests, and send messages to your friends
Legitimate interests
To send you technical notices, updates, security alerts, information regarding changes to our
policies, and support and administrative messages
Legitimate interests
To protect our legal rights, interests and the interest of others, including to prevent and address
fraud, breach of policies or terms, or threats of harm
Legitimate interests, Legal obligation, or Vital interests
To monitor and analyze trends, usage and activities
Legitimate interests
For internal marketing, profiling and demographic purposes, so we can constantly improve the
Services; adapt our Services to better suit your needs; and better understand and serve you
Legitimate interests
To send you messages or personalized information about our games, your scores, new features,
contests, special offers, and more, including for marketing and promotional purposes
Legitimate interests or consent
To provide you with advertisements about the Services and to measure the effectiveness of the
advertisements
Legitimate interests or consent
To fulfill other purposes that may be disclosed to you and for which you provide affirmative
consent.
Consent
3. When We Disclose Your Information
Fundoll discloses information about you to the below third parties. We do so to further our
legitimate business interests.
· Affiliates. Fundoll may share your information, including personal information, with its related
entities, including its parent, subsidiary and sister companies. For example, we may share your
information with our affiliates for customer support, marketing, technical operations, or to offer
affiliated services to you. If we share your personal information with our affiliates, it is on the
condition they have agreed to be bound by the terms of this Privacy Policy as it relates to their
handling of your personal information.
· Application Providers. Fundoll shares your information, including personal information, with our
third-party service providers, which may include agents, vendors, developers, and consultants, among
others. Service providers assist us with operating the Services and provide us with other services,
including marketing and promotional services. Some of these third-party service providers are
necessary to provide you with the Services, perform services requested by you, and prevent and
address fraud, in which case we also share information with them to fulfill our contractual
obligations.
· Advertising Partners. We may share your information, including advertising IDs, with third parties
who help us market the Services, including to provide you with advertisements.
· Other Partners. Depending on the Service, we may share your information, including personal
information, with our partners in connection with offering you co-branded services, selling or
distributing our products or the products of our partners, or engaging in joint marketing
activities.
· Mergers or Acquisition. In the event of, or during negotiations of, an actual or proposed merger,
acquisition, reorganization, bankruptcy, sale of a line of business, or other similar event, your
information may be shared with or transferred to Fundoll’s successors or assigns or other third
parties involved in the event.
· Security and Compelled Disclosure. We may share your information, including your personal data, to
comply with the law or other legal process, and where required, in response to requests by public
authorities, including to meet national security or law enforcement requests. We may also share your
information in connection with an investigation of fraud, harassment, intellectual property
infringements, or other activity that is illegal, a violation of our policies, or may expose you or
us to legal liability. We may also share your information to protect the rights, property, life,
health, security, and safety of us, the Services or a third party. We may share this information
pursuant to a legal and/or contractual obligation, or a vital interest.
Except as set forth above and in this Privacy Policy, Fundoll does not disclose, sell or rent your
personal information to any third parties. However, we may share aggregated information that does
not identify you or de-identified information about you with third parties or affiliates for any
purpose, except as prohibited by law.
4. Third-Party Links
The Services may contain links to third-party websites or other online services. Fundoll is not
responsible for the content or the privacy policies or practices of any other websites or online
services, or for the actions of the companies responsible for those websites and online services.
Please review the privacy policies of those websites or online services before providing them with
any personal information.
5. Publicly Posted Information
Whenever you publicly post personal information online (for example on message boards, public
profiles, and in chat areas), that information is stored by us and becomes publicly available,
subject to the collection and use of third parties (e.g., other users). Fundoll is not responsible
for the subsequent use of that information by third parties. Please take caution whenever you
disclose personal information in a public manner. If you encounter any Fundoll user who is
improperly collecting or using information about you or other users, please contact us using the
information in the Contact Us section below.
For certain forums, you may post or reply to a post using your full first and last name with the
option to also display your primary in-game character. If your personal information is posted on one
of our forums, you may contact us to request removal using the information in the Contact Us section
below. If we are unable to remove your personal information, we will notify you and explain the
reason.
6. Security
Fundoll takes reasonable steps to help protect the security and integrity of any personal
information you provide to us. Nevertheless, transmission via the internet is not completely secure
and we cannot guarantee the security of your personal information through the Services. If we learn
that your personal information has been compromised by a data breach, we will notify you consistent
with applicable laws.
Please also keep in mind that you are responsible for maintaining the secrecy of your passwords and
account information. Please be careful and responsible whenever you are online.
7. Your Privacy Rights
You may have the right to know how your personal information will be collected, processed, stored,
and used; access, update, and request the deletion of information you have previously provided to
us; request a portable copy of your personal information; withdraw previously provided consent; and
object to our processing of your personal information, including for direct marketing and profiling
purposes. In addition, you have the right to opt-out of our use of your personal information for
purposes of targeted or interest-based advertising at any time. For more information on
interest-based advertising and opt-out options, see https://youradchoices.com/learn. You may
exercise or find out more about these rights by using the information in the Contact Us section
below. Your request and choices may be limited in certain cases: for example, if fulfilling your
request would reveal information about another person, or if you ask us to delete information that
we are permitted by law or have an overriding legitimate ground to keep.
You also have the right to complain to a data protection authority about our collection and use of
your personal information.
Therefore, please carefully consider the content of the information uploaded, published and
exchanged through our services. In some cases, you can control the range of users who have access to
your shared information through the privacy settings of some of our services. If you are required to
remove your information from our services, please contact by email: contact@funtoygame.com.
DO NOT TRACK
Your browser may allow you to set a "do not track" (DNT) signal indicating that you do not wish your
online activity to be tracked. Currently, our system does not support DNT signal headers that we may
receive. However, the choices that we provide you concerning collection and use of your personal
information will continue to operate as described in this Privacy Policy.
8. Data Retention Policy
How long we keep information we collect about you depends on the type of information, as described
in further detail below. After such time, we will either delete or anonymize your information or, if
this is not possible (for example, because the information has been stored in backup archives), then
we will securely store your information and isolate it from any further use until deletion is
possible.
We retain your information for as long as your account is active and a reasonable period thereafter
in case you decide to re-activate the Services. We also retain some of your information as necessary
to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support
business operations, and to continue to develop and improve our Services. Where we retain
information for Service improvement and development, we take steps to eliminate information that
directly identifies you, and we only use the information to uncover collective insights about the
use of our Services, not to specifically analyze personal characteristics about you. We retain the
information you share on the chatting areas for 24 hours. If you private chat with other users, we
will retain only 800 messages.
Any personal information you provide in connection with a customer service request or inquiry will
be deleted by our third-party service provider one year from the date of your request or
inquiry.
9. International Transfer of Your Information
Personal data may be transferred to, and stored in, a country operating outside the European
Economic Area (EEA). Under Regulation (EU) 2016/679, the transfer of personal data to a country
outside the EEA may take place where the European Commission has decided that the country ensures an
adequate level of protection. In the absence of an adequacy decision, we may transfer personal data
provided appropriate safeguards are in place.
Personal data collected from individuals, including those in the EEA, is stored on servers located
in the United States and the Netherlands. We have verified that our Cloud Service Provider and data
processors (where applicable) are certified under the EU-U.S. Privacy Shield Framework. For
additional information, please click here.
10. Changes to this Privacy Policy
We may revise this Privacy Policy from time to time. Please check the Privacy Policy each time you
use one of the Services to ensure you are aware of any changes in our privacy practices. The Privacy
Policy will indicate the date it was last updated. If we make a material change in the way we handle
your personal information, we will provide you with additional notice by sending you an email at the
last email address we have for you, if any, or by prominently posting notice of the change on the
Services. If you do not agree with any changes we make to the Privacy Policy, please stop using the
Services.
11. Contact Us
If you have any comments, questions or complaints regarding this Privacy Policy or our privacy
practices, please contact us using any of the following methods:
Fundoll
402，1-1-36
Higashi,shibuya-ku,Tokyo
150-0011
contact@funtoygame.com