This Privacy Policy applies to Smart Project GmbH games, products, websites and related services, collectively called the Service. We respect the privacy of users and recognize the importance of protecting information collected from users. This Privacy Policy may be periodically updated by publishing a new version. Please make sure you rely on the most current version of Privacy Policy.
This Privacy Policy informs how we collect, use, and process the information that users provide. This Privacy Policy applies to all Services users. By using the Service, users agree that Smart Project GmbH collects, uses, and processes personal information provided by users as defined below.
Please note that we do not sell User data or any other personal information.
If you are a California resident, please see Additional Information For California Residents below in this document. If you are a resident of Japan, please see Additional information for residents of Japan below in this document.
Please read the following to learn more about how we use your personal data.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Smart Project GmbH (referred to as “Smart Project GmbH”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.
If you have any questions or concerns about this Privacy Policy, including those related to exercise any of your rights, please contact us through the game’s Support so we can reply to you more quickly.
The data controller: Smart Project GmbH
Email: support@smartproject.com
Address: Albitweg 11, 3095 Spiegel b. Bern, Switzerland
When you use the Service, we may collect the information about the efficiency of the Service as a whole and its single parts, whether through the Service or through social networks. When you make a decision to connect Application to your social network profile, Smart Project GmbH may collect and record the publicly available information you provide to Smart Project GmbH including your User ID and your friends’ User IDs.
SOURCES OF PERSONAL DATA
We may obtain your personal data from the following sources:
a) from you directly (through the game, website or online forms); and/or
b) from other entities, service providers that are assisting us in providing you with a service (including data analytics providers, operating systems, and internet services providers), or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google).
We collect data you provide us: contact information (such as name and email address), username, gender, date of birth, player name and password, profile information (such as profile photo), your messages to the Service (such as chat logs and player support tickets), other data you choose to give us (such as data to identify a lost account).
Your Username, User ID, profile photos are collected if you made them public and can be seen by anyone, including people outside the social network. The first time the Service connects to a social network, we will be given the information about your preferred language and location. If you connect the Service to the social network, we may collect information you shared with the network, store it and keep it updated. The Service may update its records about your basic information including your age, language and location.
Data we collect automatically: data about your account and game progress, your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI), data about your device, such as device name and operating system, browser type and language, data we collect with cookies and similar technologies, general location data, data about your use of the Service (such as gameplay data and your interactions with other players inside the Service), purchase history, including details of orders (purchase ID, amount spent, currency, date, time, vouchers or offers used), your email address and your messages to the Services (such as chat logs and player support tickets sent by email or through Helpshift service (or another service we can use in the future) any feedback you submitted about your experience with us; and/or other data you choose to give us. We may also create a game-specific ID for you when you use the Service.
Data we collect from our partners: data we receive if you bind to a third party tool with the Service (such as Facebook, Game Center or Google, social networks) including social network profile, your User ID and your friends’ User IDs, demographic data (such as to determine the approximate location of your IP address), data to fight fraud (such as refund abuse in games or click fraud in advertising), data from platforms that the games run on (such as to verify payment), data for advertising and analytics purposes, so we can provide you with better Service.
We collect technical data related to an End User’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier, unique identifiers that generally only identify a computer, device, browser or Application: IP address (which may also provide general location information), User agent, identifier for advertisers, Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers.
We collect information relating to the Customer’s ad campaigns and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.). Publicly available information is not considered personal information.
We get the information about you from your friends in social networks as soon as they start using the Service and connect it to their profiles.
The Service has access to the information required for providing and enhancing the Service to enable Users to enjoy the Service and for the Service to work properly. We obtain and update the information about you each time you interact with the Application for example, when you start the Service, collect a bonus or make a micro-transaction via the Service.
Information regarding billing, a user's account, a user's Internet connection and the SPG software installed on a user's computer is uploaded to the server in connection with the user's use of Service. Service software automatically generates and submits to SPG bug reports upon a crash or other fault in the Service. This automatically generated bug report information may include information about other software or hardware on a user's system. We do not associate and store the automatically generated bug report information with users' personally identifiable information. Any bug reporting information manually submitted by users (e.g., through bug reporter form) is associated and stored with personally identifiable information sent voluntarily by the user through a bug report.
Service may provide chat rooms, forums, or instant messaging tools to users. Any information that is disclosed in chat, forums etc. should be considered public information, and users who message one another may not know each other personally. SPG has no obligation to keep private personally identifiable information that a user makes available to other users or the public using these functions. Users should exercise caution when deciding to disclose personal information in public forums. Users should also be aware that game play information disclosed during multiplayer game play (e.g., player name and current player statistics) is public information and may be displayed to other users.
We collect data when provided voluntarily, when the Customer integrates SDK’s, API’s, pixels, redirect links, JavaScript tags, cookies or similar data collection technologies into their Applications, websites and/or ads, from the various advertising networks and third parties that are used by the Customer in connection with the measurement and analysis of Customer’s marketing campaigns and that have partnered with SPG.
We may collect data to make the Service work, create accounts and allow you to use our Service, operate the Service, verify and confirm payments, provide and deliver products and services you request, send you Service-related communications, to make the Service more suitable for our players.
We may use and share your personal information to provide you with our products or services (for example, play any of our online games and make online purchases); to communicate with you; to offer you additional products or services, including targeted promotions; to personalize your experience with us, including by reviewing and analyzing your information; and to manage our business including our credit and other risks. Our lawful basis for doing so is contract.
We may use your personal data to send you marketing communications via email.
Our lawful basis for doing so is consent.
We may use your personal data to:
Our lawful basis for doing so is Legitimate Interest.
Our legitimate interests in doing so are:
To provide greater Service to our players, we have a legitimate interest to collect and process necessary data to: update and develop player profiles, develop and improve the Service and player experience, manage our relationship with you, provide social features as part of the Service, customize your Service experience, respond to your comments and questions and provide player support, provide you offers in the Service as well as in other websites and services, and by email, send you related information, such as updates, security alerts, and support messages, enable you to communicate with other players, display personalized advertisement, track the content you access in connection with the Service and your online behavior, deliver, target, and improve our advertising and the Service. For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.
If you object us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in section Contacts. If we use your email to communicate marketing information, we will seek your prior consent if required to do so by law.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. If we learn that we have collected personal data about a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us.
We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.
We use the obtained information about you only to fulfill the efficiency of options and Services you need, to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise. No personal information is provided to a third party.
We do not share any personally identifiable information with other parties except as described in this policy. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. We may share anonymous data, aggregated or not, with third parties.
We do not share or disclose your data with any third party, except: upon Customer’s request, we have notified you, in particular through this Privacy Policy, to our subsidiaries as necessary to help us support and maintain the Services provided to Customers; to our service providers who help to support our Services – such as data hosting providers and payment processors; when legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements; to respond to, or prevent, fraud or to protect the safety of SPG, its Customers, End Users or the public; as part of any merger or acquisition of SPG, in which case your data may be transferred to the surviving or acquiring entity.
Your User ID allows personalization of your interaction with the Service, bringing together your profile in the Service with your profile in a social network. We also use the information about you for internal application management: for eliminating errors, data analysis, validation, research and improvement of the application functionality.
Personally identifiable information is used internally by SPG to deliver, develop and improve products, content and services, to answer users' requests, to establish matches between devices used by you; to detect fraud and to ensure more accurate attribution measurement and ad fraud protection for Customers using the Services. In addition, we may allow third parties performing services under contract with SPG, such as order or payment processors or merchandise warehouse and fulfillment services, located in and outside the European Union, to access and use personally identifiable information, but only to the extent necessary to provide Service.
We may use data provided by users to send them information about SPG, including news about product updates, contests, events, and other promotional materials, but only if the users agree to receive such communications.
We provide the best gaming experience for all ages that is compliant with the law and with industry standards. This guide is designed to provide parents and other legal guardians with information on safety in our games.
Please be assured that Company abides by the following rules and principles:
If you have any questions regarding underage players, kindly contact us as described in section “Contact Us” below.
In order to play our game, you must download the game application from your respective store (various mobile and PC platforms) or access the game via your internet browser.
What are the age limits for our game and the target audience?
Our game is designed for everyone and do not contain any content that might be regarded as mature. However, as stated in our Terms of Use, players must be at least 16 years old to access and/or use our games. If a player is a minor over the age of 16, we recommend seeking consent from a parent or legal guardian before accessing and/or using our website or games.
Our game displayed in online stores like Google Play or Apple's App Store also contain information about age recommendations. Kindly note that these age ratings also depend on the stores’ policies and on local legislature, which is why they may differ from our Terms of Use.
Aspects of data processing, especially in regard to underage individuals
While it covers all the necessary information and provisions, we have decided to clarify certain aspects of data processing, especially in regard to underage individuals.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 16, nor do we knowingly allow such persons to use our Services. If any player is under 16, we ask them not to send any data about themselves to us, including their name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. If we find out that we have collected personal data about a child under 16, we delete that data immediately. If you believe that we might have any data from or about a child under the age of 16, please contact us via the in-game customer support interface or at support@smartproject.com.
Our Privacy Policy contains a full list of the personal data that we may collect from you directly (through the game, website, or online forms); and/or from other entities, service providers that assist us in providing you with a service (including data analytics providers, operating systems, and internet services providers), or from your social network accounts that you used to sign in to our online services (Facebook, Google, etc.). Kindly note that we only process personal data in order to provide you with our services, fulfill our duties under contractual obligations, and realize our legitimate interests.
REAL NAME AND USERNAME
As part of your registration for our Services, or via log-in or social networks, we may collect certain data, such as your name or nickname and email address.
However, it is not necessary to use your real name as your username within the game, and we strongly recommend not doing so.
Instead, we encourage our players to choose a nickname not directly related to their real-life identities to increase security and privacy. You can also change your username in the in-game settings.
Can I delete personal data?
Under the General Data Protection Regulation, you have the right to have all of your personal data or your children's data used in our application and our partners' services deleted (purchase payments, in-app ad views, etc.). Please keep in mind that should you decide to delete the data, your user account will be deleted and will not be restorable. However, it will be possible to start the game over from the beginning.
Under the California Consumer Privacy Act, California residents have the right to opt out of the sale of personal information. Please keep in mind that opting out doesn't mean that you will stop seeing ads. You may opt in at any time by contacting our support team.
You can also delete data received from third parties/platforms. In this case, you or your children will lose the ability to use the functions provided by the third parties/platforms, but your account will not be deleted.
For more detailed instructions, you can access our contact customer support.
Is the game free to play?
While our game is free to download, they do contain in-app purchases. You can play entirely for free, but making purchases can help you speed up your progress and increase your in-game resources.
You can limit or disable in-game purchases in your device's settings. The exact process depends on the type of device the game is installed on, be it an iOS device (iPhone, iPad, etc.) or an Android device.
Check the following articles to learn more about how you can protect yourself from unwanted in-game purchases:
My child accidentally made an in-app purchase. Can I get a refund?
All purchases are processed by the store where you downloaded the game, so please contact the store's customer support to request a refund.
If the purchase was made on an iOS device:
Go to the App Store Support page, select the link for "Get help with your purchases and refunds," and find the option that best suits your situation.
If the purchase was made on an Android device:
Go to the Google Play Help page, Amazon Appstore support page or Huawei App Gallery support page and follow the instructions for your device.
I am seeing an inappropriate ad. What can I do about it?
In our games, players have the opportunity to receive in-game resources in exchange for watching video ads from our partners.
All the ads are checked for compliance with the age rating applicable to our games.
However, if you come across video content that you think doesn't correspond to the age rating of the game, you can let us know by contacting us through the game settings and providing a screenshot of the ad. It's best if the screenshot also shows the name of the application that the ad is promoting.
Our Customer Support specialists will process your request and take all necessary measures to resolve the problem.
How can I contact you?
The fastest and most convenient way to contact us is to do it through the game settings. That way, we'll have all the technical information we need to resolve any issues quickly. Depending on the nature of the problem, please make sure that your message includes the following: the time the incident occurred, copies of transaction receipts or the purchase history, screenshots showing the problem, etc.
If you are not familiar with our games, please refer to support@smartproject.com, where you will find answers to some common questions.
Safety tips
Our main priority is creating a safe space for all players in order for them to have a great time playing our games. If you have any concerns regarding one of our games and your child, do not be afraid to contact us. Here are a few tips you may find helpful:
We hope that these simple rules will make your family's gaming experience even more enjoyable!
When you use or access our Services in any capacity, you represent that you are at least the minimum age to consent for data processing under the laws of your jurisdiction, and not barred from accessing the Services under applicable law. Notwithstanding the foregoing, we may provide some Services that are available to younger players as permitted under applicable law. Regardless, if you are under the age of 16, you hereby agree that you have gotten permission from a parent or guardian to use our Services, and your parent or guardian must agree to the conditions in all applicable policies and accept them on your behalf. Parents and legal guardians are responsible for the acts of their children when they use our Services. If you access our Services through a third-party platform or site, you may be required to comply with their policies in addition to this Policy.
Note that we do not have any knowledge of sales or sharing of personal information of minors. While our Services may allow you to create an account, we do not otherwise use or disclose any sensitive personal information.
Smart Project GmbH will not knowingly collect personally identifiable information from any person under the age of 16. We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 16 or knowingly allow such persons to use our Service. If you are under 16, please do not send any data about yourself to us, including your name, address, telephone number, or email address. We encourage parents to instruct their children to never provide personal information.
If we learn that we have collected personal data about a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us. No one under the age of 16 may provide any personal data.
If you are a parent or guardian of a minor and believe that minor has uploaded personal information in connection with our Services without your consent, or if you wish to review information collected from your minor child, or have that information modified or deleted, you may contact us as described in “Contact Us” below.
If we become aware that a minor has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and revert them to the underage experience, if applicable.
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
Smart Project GmbH may need to transfer Customer Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws. With regards to the collection, use and retention of personal data transferred from the European Economic Area or Switzerland to the United States, we comply with the EU-U.S. and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce.
We share your personal data with our affiliates and partners in the EU/EEA and outside the EU/EEA. Where a data transfer outside the EU/EEA is not covered by an EU Commission adequacy decision, we rely on lawful safeguards referred to in Article 46 GDPR. This mainly includes EU Commission-approved Standard Contractual Clauses which we enhanced by supplementary security measures such as ancillary individual risk-assessments, additional contractual safeguards and technical safeguards including additional encryption or pseudonymization, to enable international transfers with our affiliates and partners outside the EU/EEA.
Please feel free to contact us for additional information on third country data transfers as well as our safeguards and supplementary security measures.
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts, and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.
Some of the vendors that we engage to are located outside the European Economic Area. Where the EU Commission did not recognize them as locations providing adequate protection for personal data, we rely on lawful safeguards as described above.
You may request a copy of these agreements by contacting us using the email address in the Contact section below.
Apart from SPG, your data can be accessed by: other players and users may, for example, see your profile data, in-game activities and read the messages you have posted; our partners to perform services for us. These partners process your data only at and according to our instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention; in order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
Our Partner Organizations and Service Providers.
We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
a) technical support providers who assist with our website and IT infrastructure,
b) software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
c) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
d) providers that help us generate and collate reviews in relation to our goods and services;
e) our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you. A list of our partners is available through this link; and/or
f) service providers that assist us in providing our services;
g) law enforcement or government bodies.
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. You can opt-out of interest-based advertising on mobile applications by sending the request to our e-mail mentioned herein. For personalized in-game offers opt-out, you can use the options provided in the game settings. You also have the right to correct your data, have your data deleted, object and restrict how we use or share your data.
You have the following rights: to withdraw any previously provided consent; to access certain information about you that we process; to have us correct or update any Personal Information; to have certain Information erased; to have us temporarily block our processing of certain Information; to have Information exported into common machine-readable format; to object to our processing of Information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and to lodge a complaint with the appropriate data protection authority.
As a data subject, you have the following rights which provided Article 13 GDPR: right to obtain information in relation to your personal data; right to access your personal data; right to data portability; right to withdraw the consent; right to correct mistakes in your personal data; right to stop the unwarranted processing; right to be forgotten (erase your personal data); right to be aware of the existence of the automated individual decision-making and to object in this regard; right to lodge a complaint to a supervisory authority.
You can access you personally identifiable data we collect once you authenticated your identity at any time directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you. We may refuse or limit your request to access personal data if we believe that the information may adversely affect the rights or freedoms of others, such as if the data includes trade secrets or intellectual property rights.
We will respond to all requests within a reasonable timeframe set out under applicable laws. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us immediately as described in this Privacy Policy. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions: (1) Your request should be in writing; (2) Provide sufficient information to enable Smart Project GmbH to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.
We rely on user game account access to verify the user identity and avoid unauthorized logins. Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request.
We have the right to refuse to process requests that are not meaningful/entangled, requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.
You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected, or deleted from our systems. You can also limit, restrict or object to the processing of your data.
We do not carry out any decision-making based solely on automated processing, including profiling.
If you gave us your consent to use your data, e.g., so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.
You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in relevant sections above.
If you would like to exercise any of your above rights, you may contact us as set forth in the Contact section below.
Like most online services, we and our partners may use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements, and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.
What is a cookie?
A cookie is a small file that is stored on a user's computer for record-keeping purposes. Cookies themselves do not identify you, as they are only designed to identify the device and browser when you visit the website again. In this case, only the cookies already available on your device will be used.
We use cookies and similar technologies to collect information about the use of our websites in order to make them function effectively and also to improve your experience when you browse our websites or play web versions of our games.
Types of cookies that we use
Cookies on our websites belong to one of the following categories:
Third-party cookies
Cookies may be either first-party cookies or third-party cookies. First-party cookies are cookies set directly by us to your device. Third-party cookies are cookies set by a third-party provider on our behalf.
When you visit our websites, third-party organizations may place cookies on your browser. These cookies may inform third-party organizations about your visit to our websites, which may be used by those organizations to deliver targeted messages and advertising to you. We do not control third-party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them.
Such cookies are subject to third-party organizations’ own cookie policies. Please read their privacy policies to ensure you are comfortable with how they use cookies.
How long will cookies remain on my device?
Please check your Cookies Settings for details.
Links to other websites
Our websites may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy or security practices of such other websites.
How to manage cookies using your browser
You can control and manage cookies in various ways. Insofar as cookies we use are not essential for the provision of our websites, we will ask you to consent to our use of cookies when you first visit our websites. You do not have to accept all of the cookies used by our websites. Consent can be provided or revoked by clicking on Cookies Settings at the bottom of this page. Please keep in mind that if you reject cookies, you may still use our websites, but your ability to use some areas of our websites will be limited and you may need to re-enter your personal data when you register.
You may also be able to change your browser settings to manage and control cookies. Your browser or device may be configured to allow you to refuse or delete cookies or to be notified when a cookie is stored on your device. To change your web browser or device settings for cookies, you can follow the instructions in the help section of your web browser.
You can also find detailed information on how to do so at https://www.aboutcookies.org/how-to-manage-and-delete-cookies.
To learn more about behavioral advertising and how to control your interest-based advertising preference, you can review the following resources:
Changes to this Cookie Notice
We may modify or amend this Cookie Notice from time to time at our discretion. When we make changes, we will update the "Last modified" date at the top of this page.
We advise you to periodically review this Cookie Notice to be informed about how we use cookies.
Smart Project GmbH is concerned with safeguarding your information. We take appropriate steps to protect your personal information from unauthorized use, sharing, loss or theft, and we audit our security measures and assess that they remain effective and appropriate. Our employees that have access to your information are made aware of the importance of keeping it secure and confidential. We use contracts and other measures with our subcontractors to maintain the confidentiality and security of your information and prevent it from being used for any other purpose other than that for which it was intended.
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
Smart Project GmbH will retain your data for as long as your account is active or as needed to provide you the Service. Generally, this period equals the period you use the Service or have an application installed on your mobile device or PC. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We shall delete your data upon a request to delete the data.
Personally identifiable information provided to Smart Project GmbH by customers in the EU is controlled by Smart Project GmbH, with place of business set out below. Personally identifiable information provided to Smart Project GmbH will be collected, processed, and stored by Smart Project GmbH in Switzerland and Germany.
Smart Project GmbH an international company with headquarters in Switzerland. We are the rightsholder to all our games, websites and related services.
As an international company we may entrust processing of personal information of our players and users to our subsidiaries in order to achieve the purposes stated in our Privacy Policy.
Additionally, we have commercial partners providing us marketing, advertising, support, and hosting services to which we similarly entrust processing of personal information of our players.
As a Swiss company we follow the highest standards of handling and transferring, including international transfer, of personal information under the EU General Data Protection Regulation. Likewise, we have obliged our subsidiaries and partners to meet these requirements in their processing personal information activities. To ensure security and confidentiality of personal information during processing our subsidiaries and partners have implemented legal, technical and organizational measures as described in our Privacy Policy.
The Personal Information Protection Commission ("PPC") of Japan has conducted analysis on the system for the protection of personal information in different countries (available at a link in Japanese).
By accepting our Terms of Use and Privacy Policy, you provide us consent to transfer personal information to our subsidiaries and partners in these countries as specified herein.
Privacy Policy
In this section, we provide additional information about how we handle personal data about California residents as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal that is exempt under the CCPA.
A. Categories of Personal Data Under the CCPA
In this section we describe, generally, how we have collected and disclosed personal data about you from the Last Updated date above. As noted above the data that we collect about you varies on your relationship with us. We may collect personal data from the following sources:
The table below identifies the categories of personal data (as defined by the CCPA) we have collected about you, as well as how we have sold or disclosed for a business purpose such information. For more information about the business and commercial purposes for which we collect, and sell personal data, please see relevant sections above.
Under the CCPA, a “sale” includes disclosing or making available to a third-party personal data, in exchange for monetary compensation or some other value or benefit. While we do not disclose personal data in exchange for monetary compensation, we may make certain categories of personal data available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
We may share your information with other players (your in-game nickname and avatar only), our business partners, service providers, affiliates and subsidiaries, advertising and promotional agencies and networks, consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you.
Personal Data Collected
Categories of Entities to Whom We May Disclose or Sell this Information
Categories
Description
Identifiers
Includes direct identifiers, such as email address, IP address, device ID and other online identifiers.
- Affiliates and Subsidiaries
- Other Players (username and profile only)
- Service Providers
- Business Partners
- Advertising Agencies (Advertising identifier and IP address only)
Customer Records
Includes personal information, such as advertising ID in order to understand which others of our products and services individuals have purchased and/or played.
Affiliates and Subsidiaries
Commercial Information
Includes records of products or services purchased.
Affiliates and Subsidiaries
Usage Data
Includes ad views, browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads.
- Affiliates and Subsidiaries
- Service Providers
- Business Partners
- Advertising Networks
Geolocation Data
Includes location information about a particular individual or device.
- Affiliates and Subsidiaries
- Service Providers
- Business Partners
- Advertising Agencies
- Advisors and Agents
- Government Entities and Law Enforcement
Tech device data
Includes device language setting, OS version, device model, user agent (browser version), connection type, carrier etc.
Affiliates and Subsidiaries
Player activity data
Date and time when the user has opened the app, finished the tutorial, in-game progress, etc.
- Affiliates and Subsidiaries
- Service Providers
California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to your personal data:
Do-not-sell (opt-out): to opt-out of our sale of your personal data. While we may “sell” personal data as defined by the CCPA, we do not sell personal data about California consumers who we know are younger than 16 years old.
Right of deletion: to request deletion of their personal data that we have collected about you and to have such personal data deleted (without charge), subject to certain exceptions.
Right to know: with respect to the personal data, we have collected about you in the prior 12 months, to require that we disclose the following to you (up to twice per year and subject to certain exemptions):
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising your rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests through one of the following methods:
When you submit any request, we will take steps to verify your request by asking you some questions about in-game experience (such as current level, the name of the in-game pet, etc.) and matching the information provided by you with the information we have in our records. You must answer the questions to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us via as set forth in the Contact section. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
We may update this Privacy Policy from time to time. Any material changes will be available to the Customer either through the Services, email or as otherwise agreed by the parties in the Agreement. We will also indicate that an update has occurred on the top of this page, so you are encouraged to review this Privacy Policy from time to time. All previous versions of this document are stored in the archive.
For any questions relating to this Services Privacy Policy or to contact our data protection officer please send us a mail to: support@smartproject.com. You may also send us or our data protection officer regular mail: Albitweg 11, 3095 Spiegel b. Bern, Switzerland
Effective date: 06 April 2023