Sugra Games Privacy & Security Policy
Here at Sugra Games we care about your privacy and we respect your privacy rights.
By using a Sugra Games’ App you permit the collection and use of your personal information as described in this Privacy and Security Policy and you agree with this Privacy and Security Policy (last updated on 10 January 2013). If you do not agree with the terms of this Privacy and Security Policy, you should not use Sugra Games’ Apps.
ABOUT OUR PRIVACY AND SECURITY POLICY
1. Our products, including all our computer programs for your mobile telephone, tablet, computer or other supported device (“Device”) (each a “Sugra Games’ App”), are managed and controlled by Sugra Games Limited, of C/O Smith Pearman & Co, Hurst House, High Street
Ripley, Surrey, GU23 6AY, United Kingdom, Company Number: 08326620 (“Sugra Games”, “we”, “us” and “our”).
2. Our Privacy and Security Policy sets out the basis on which we process and use any personal data we collect from you or that is provided to us as a result of you downloading or using the Sugra Games’ App.
3. Please read the Privacy and Security Policy carefully to understand our views and practices regarding your personal data and how we will treat it.
2. INFORMATION ABOUT YOU RECEIVED THROUGH VARIOUS APP DISTRIBUTION CHANNELS
2.1 We make the Sugra Games’ Apps available for download via a number of channels, including websites, app stores, shops and markets (e.g. the Apple Inc. App Store and Google Inc.’s Google Play) which we decide upon from time to time (each an “App Channel”) operated by third parties (each an “App Channel Operator”).
2.2.1 information on your patterns of use of a Sugra Games’ App, such as how long you use it for, how often you use it and what you do or click when you are using it;
2.2.2 the number of pages of a Sugra Games’ App viewed each time you use it;
2.2.3 the language through which you are using a Sugra Games’ App;
2.2.4 information about your Device, including (where available) your operating system, unique device identifier code, information regarding the volume and status of data transmission, click-through statistics and the date and time you access portions of the Sugra Games’ App; and
2.2.5 what other Sugra Games’ Apps you have installed on your Device.
2.3 We have no control over an App Channel Operator’s collection or use of information and cannot change what information is made available to us by an App Channel Operator by virtue of your or our use of the App Channels.
2.4 Your personal data is gathered from the following sources:
2.4.1 when you provide it to us or the App Channel Operator;
2.5 We currently use Apple’s Vendor ID to identify your device, in accordance with Apple requirements. This ID is generated by iOS, identifies your device in the context of our Apps only and allows us to gather information about you described in this Privacy and Security Policy.
3 USES MADE OF THE INFORMATION
3.1 We use information that we have access to about you or that you give to us in the following ways:
3.1.1 to refine and improve Sugra Games’ Apps and to deliver to you and maintain high quality products;
3.1.2 to gain insight into how customers (including you) use the Sugra Games’ Apps so that we can make improvements to its usability;
3.1.3 to balance traffic to ensure our customers receive a consistent and reliable service;
3.1.4 to conduct research on and analysis of on our business practices and our interactions with you, with a view to improving our service and products;
3.1.5 to comply with our legal obligations;
3.1.6 to deliver and maintain a high quality service;
3.1.7 to allow you to access the Sugra Games’ App and to participate in interactive features of our service when you choose to do so; and
3.1.8 to notify you, if we choose to do so, about changes to our services including the Sugra Games’ App.
3.2 Except as set out in this Privacy and Security Policy, we do not sell, rent, share, trade or give away any of your personal information.
4 DISCLOSURE OF YOUR INFORMATION TO OTHER PEOPLE
4.1 We do not disclose personal information about you to any third party unless we have your permission (including as given in this Privacy and Security Policy), it is a condition of our agreement with an App Channel Operator or we believe the law permits or requires it.
4.2 You understand and agree that we may disclose your personal information to the following third parties:
4.2.1 any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
4.2.2 our professional advisors (e.g. lawyers, tax advisors);
4.2.3 a prospective seller or buyer of any business or assets of Sugra Games or Sugra Games itself;
4.2.4 a third party in order to enforce or comply with any agreement, including an agreement with an App Channel Operator; and
4.2.5 to protect the rights, property or safety of Sugra Games, our group of companies or others; this includes exchanging information with third parties for the purposes of fraud protection insurance and credit risk reduction.
4.3 We will tell you when personal data about you may be provided to third parties by us in ways other than those explained in this Privacy and Security Policy; you will have the option to prevent such information sharing at the time that we tell you.
4.4 We do not disclose personal information about you to third parties (including advertisers or marketing companies) unless you have consent to that disclosure, but we may provide them with aggregate anonymised information about users of a Sugra Games’ App. You agree to these practices.
4.5 It may be necessary to transfer your personal information to other group companies, to App Channel Operators or to our other service providers located in countries outside of the European Economic Area (EEA). This may happen where our servers, an App Channel Operator’s servers, or suppliers and service providers are based outside of the EEA, or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data on that basis.
5 TIPS AND WARNINGS
5.1 The use by you of any App Channel is at your sole risk.
5.2 From time to time game publishers are the target of third parties acting illegally and masquerading as legitimate game companies. The Sugra Games’ Apps will never be made available to download from sources other than from an App Channel Operator approved by us. If you are in doubt about the authenticity of any source of a Sugra Games’ App, please let us know.
5.3 Sugra Games’ Apps and the Sugra Games account pages in the App Channels may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as to third party websites to which we have no affiliation or connection. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for the activities on those websites or for the actions of an App Channel Operator.
5.4 Care should be taken when using the third party apps or websites which you can access using the Sugra Games’ App and the Sugra Games account pages in the App Channel Operators. If you find any suspicious activity connected to the use of an App Channel then we suggest you contact the App Channel Operator immediately. If you find anything suspicious or encounter suspicious activity in relation to your use of a Sugra Games’ App or our account then please contact us immediately at firstname.lastname@example.org.
6.1 We do not knowingly collect or hold personal data about children under the age of 18. If we become aware that a child under the age of 18 has provided us with personal information, we will take steps to delete it as soon as is possible. If a parent or guardian becomes aware that a child (a person under the age of 18) has provided us with personal data without their consent, please contact us on email@example.com.
7 SECURITY AND CONTROL OF YOUR PERSONAL DATA
7.1 Although we rely on an App Channel Operators to take care of your data, much of which we only access by viewing the data held by them, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and Security Policy.
7.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Sugra Games; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. You acknowledge that we are not responsible for the actions of an App Channel Operator, or for any intercepted information sent via the internet, and you release us from liability in connection with any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
8 ACCESS TO INFORMATION AND UPDATING, VERIFYING AND DELETING PERSONAL DATA
8.1 At any time, you can make a written request to have access to all the personal data information that we hold about you. We will provide this information to you and may request a small administrative charge.
8.2 You can modify, update or delete your inaccurate personal information at any time by contacting us at firstname.lastname@example.org.
9 CHANGES TO OUR PRIVACY AND SECURITY POLICY
9.1 Any changes we may make to our Privacy and Security Policy in the future will be posted on this page. You should visit this page periodically to review any changes to the Privacy and Security Policy.
10 USER FEEDBACK AND COMPLAINTS
10.1 We welcome questions, comments and requests regarding this Privacy and Security Policy. These should be addressed to privacy@Sugra-Games.com or by post to Sugra Games, C/O Smith Pearman & Co, Hurst House, High Street, Ripley, Surrey, GU23 6AY, United Kingdom.