Privacy Policy

INTRO

This policy describes how 5007490 Ontario Ltd. (also known as Swell City) collect, process, use, and share information about you.

This Privacy Policy applies to all of our games, whether on your computer, on your mobile device, on a website, on a console, PC, or platform. It also applies to our Marketing and Advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our Games, websites, marketing and advertising activities, and other services collectively as our “Services”.

By downloading, accessing and/or playing our Games, or other Services, you agree to the use of your information in accordance with this Privacy Policy. If you have any concerns about providing information to us or it being used as described in this Privacy Policy you should not use our Games or other Services.  

INFROMATION WE COLLECT WHEN YOU USE OUR GAMES AND OTHER SERVICES

When you play our Games or use our other Services, we collect information about you.  

We collect information from you when you voluntarily provide such information, such as when you play our Games or use our other Services.

  1. When playing our Games, the information we may collect about you relates to the type of device you are using, device ID, Advertising ID, the IP address of your device, geographic information (i.e. country and region), mobile operating system, the type of mobile Internet browser, and game play information (i.e. how you play our Games and purchases made in our Games).
  2. Information you provide when you contact us through Customer support or messaging channels (i.e. social media).
  3. Information you provide when creating an Account.
  4. Information that you allow us to access when connecting to your social media accounts through our Games or Services

 
INFORMATION PROVIDED TO US BY THIRD PARTIES

When you play or purchase our Games on your mobile device, console or PC we receive information about you from the apps stores (i.e. Apple App store, Google Play store, Amazon, Steam, or other mobile platform providers).

  1. This information includes your username and/or device ID and the fact you made purchase.
  2. We do not collect or store any sensitive or financial payment information (i.e. credit card number)
  3. We may also get information that you have authorized them to provide

We use the data that you provide for the purposes of game optimization, preventing fraud, customizing in-game offers, and verifying purchases. We may also use it for the other purposes as set out in this Privacy Policy. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.

Depending on which of our Services you interact with we may collect and process the following types of information:

  1. How you use and interact with our Games, advertising and other Services.
  2. What device you use to access our Games and Services.
  3. The information you provide when you create an Account or if you invite your friends to use our Games and Services.
  4. If you contact us through our customer support channels, the content of messages sent and received.
  5. Record of correspondence and interactions with us on social media channels.
  6. Record of correspondence using our chat or messaging systems.
  7. Information collected via Cookies other similar technologies.
  8. Information you provide to enter a contest or promotion. If you win we may need to collect your address and other information to validate eligibility and legal compliance.
  9. Information we collect about you from third party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained).

We may from time to time ask you for your consent to collect other information from you or your device. For instance, we may invite you to allow us to access your contacts to enable us to invite them to play our Games with you. If we do this or something similar, we will tell you what information we would like to collect, why we need it, and what we’ll use it for.

HOW WE USE YOUR INFORMATION

We use your personal and non-personal information, both individually and combined together, the following ways:

  1. To provide a safe and enjoyable user experience.
  2. To operate, improve, and develop our Games and Services for you and the device that you are using.
    1. This includes the use and analysis of aggregated data to ensure that our Games and websites work properly on all devices.
    2. We use analytics tools, which may include third party analytics tools, to collect information about how you play our Games or use our Services.
    3. We may analyze and use the information that we collect on an anonymized or aggregated basis for product development, to analyze the performance of our Games, to troubleshoot, and to improve and optimize the Games to ensure the best player experience for our players as a whole.
    4. We may also create reports, analysis, or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new Game features and content.
  3. To ensure that any purchases you make are verified on our servers and activated in the Games.
  4. We may also share your information with third party publishers who develop and provide Games and other Services to you on our behalf.
  5. Customer Support
    1. We will use the information and data that you provide directly to us through our customer support channels to communicate with you.
    2. Help identify and troubleshoot problems with your account or Games
    3. Correspond with you (i.e. respond to your specific requests or questions)
    4. Manage your account and relationship with us and to improve your experience when you using our Services.
  6. Events, offers, and promotions
    1. From time to time we may run promotions or competitions during which we may collect certain personal information from you, such as your name, address, postal code, email address or other information or content submitted in order for you to claim a prize.
    2. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition.
    3. We may also publish the names and entries of competition entrants. That information may also be combined with your Account and other account information and will be processed, stored, and shared in accordance with this Privacy Policy.
  7. Marketing and Advertising purposes
    1. When you play our Games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.
    2. Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our Games or to improve the accuracy of their targeting and measurement systems.
    3. This Privacy Policy does not apply to the collection of your information by our advertising partners. We recommend that you review our advertising partners’ privacy policies for more information here.
  8. Legal Compliance
    1. To enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service
  9. Social Media
    1. We have several Social media channels which we use to communicate to our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
  10. Chat
    1. When you participate in social features (such as chat), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure privacy settings reflect your preferences.
    2. To ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason.
  11. Visiting our Website
    1. When you visit our other websites, we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimizing the Websites, in connection with our advertising purposes, and for research or analysis.
    2. Information we collect via cookies (which are small text files placed on your device) or other similar tracking technologies, allow us to collect data such as your device’s model operating system, screen size, and other information about how you use our Services.

CCPA

As of January 1, 2020, the California Consumer Privacy Act (CCPA) was implemented and provides certain privacy rights to consumers in the state of California. The CCPA provides protections for individuals in California pertaining to how their personal information is collected, what personal information is collected and options for exercising your data privacy rights under that Act.

The stated aim of the CCPA is to ensure six rights for Californian consumers:

  1. To know what personal data you hold about them
  2. To access the personal data without charge
  3. To know whether you sell or share their personal data (and if so, who gets it)
  4. To demand that you don’t sell their personal data
  5. To demand that you delete their personal data
  6. To exercise these rights without it affecting the services

We will not sell your personal information to any party. If that changes in the future, we will provide you with an opt-out capability as well as inform you of your opt out rights as required by the CCPA.

If you require more information or need clarification, please reach out to contact@swelldoneapp.com.

SWELLDONE GAME LOG-IN PROFILE

When you create an Account, we will give you a randomly generated unique identifier. Your Account will not be personally identifiable unless you choose to add your personal information to it, such as your name, avatar, email address or other information.

If you choose to add information to your Account or to connect our Services to your account with a third party network (such as Facebook or other Social Media providers). If you do this, then your personal information will be visible to other players and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising.

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

Those rights include:

Right of access
  
You have a right to know what information we have about you and in certain instances to have that information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive.

  1. We reserve the right verify your identity and ask for reasonable evidence there of before we provide you with any information.
  2. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person.
  3. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why.
  4. We will try to respond to any request for a right of access within 1 month of receipt of your request and verification of your identity.

Right to correct personal information

We try to keep the information that we have about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know at contact@swelldoneapp.com and we will correct it as soon as we can.

Data deletion

In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us.

  1. In order to process your request you must delete/uninstall our Games from your mobile devices and clear our cookies from any device where you have played our Games in a web browser.
  2. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity.
  3. We may also retain your information in an anonymized form.
  4. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores, and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.

Account deactivation

If you have created an account with us, you can ask us to deactivate that account by contacting us.

  1. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device.
  2. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our Games from your mobile devices.
  3. Please note that if you completely deactivate your account all your progress in our Games and any unspent Virtual Currency and/or Virtual Commodities (i.e. Diamonds, Coins, and such) will be lost and we may not be able to restore them in the future.

Restriction of processing

In some cases, you may have the right to request a restriction of the processing of your personal data, for example, when you are disputing the accuracy of your data held by us.

Right to object

You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).

Children

We are committed to respecting children’s privacy. Swell City’s Games are intended for general audiences and we do not knowingly collect any personal information from children. We will not collect personal information from anyone we have actual knowledge is under the age of 13 or under the minimum age in the relevant territory.

If you as a parent or guardian grant consent for child to use Swell City’s Games or other Services, the information collected will be accordance with this Privacy Policy.

If you believe that we might have any personal information from or about your child, please Contact Us contact@swelldoneapp.com. In the event that we learn that we have collected personal information from a child, we will delete that information as quickly as possible.

GENERAL

Further details about Swell City's Privacy Policy:

Sharing

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

  1. Where we have your consent to do so (including as set out in this Privacy Policy);
  2. As reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
  3. Where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
  4. As we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Swell City, our users, or others; and
  5. If there is a sale of the assets of Swell City or corporate restructuring, or as a result of a change of control of Swell City or one of its affiliated companies, or in preparation of any of these events. Any third party to which Swell City transfers of sells Swell City’s assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

We may also share your information with our service providers if necessary to enable them to provide services to us.

Security

Swell City takes appropriate and reasonable security and technical measures to protect your personal information from unauthorized access, loss, alteration, and misuse. Personal information collected by Swell City is stored in secure operating environments that are not available to the public (i.e. locked rooms). However, no system is 100% secure (i.e. no Internet or email transmission is ever fully secure or error free). In particular, email or messaging sent to or from Customer Support may not be secure. Therefore you should take care in deciding what information you send to us. By using our services, you assume the risk. 

Legal Bases

The legal bases which we rely upon are the following:

Contractual Necessity

This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our Games, customer services, chat functionality, and third party social network connectivity;

Legal Obligation

This covers data used by us to comply with a legal obligation, such as the prevention of crime or fraud or to maintain records relating to tax;

Legitimate Interests

This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics and research, and optimization of our Games and other Services; and

Consent

Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.

In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time. Nonetheless, if you play our Games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our Games and stop using our Services.

Retention

We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.

Location of storage & International transfer

Personal information we collect from you may be stored and processed for the purposes set out in this Privacy Policy in Canada, USA or any other country in which Swell City, its affliated companies, or third party agents operate. By using our Games and other Services, or providing us any personal information through them, you consent that your personal information may be transferred to recipients in Canada, USA, and other countries that may not offer the same level of privacy protection as the laws in your country or residence of citizenship.

Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page

Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.

Contact us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several way of contacting us:

via our customer services page at https://www.swelldoneapp.com/contact;
via email to contact@swelldoneapp.com; 

For information collected under this Privacy Policy, the data controller is Swell City.