PRIVACY POLICY

(Last Updated: October, 2020 with effective date 30 October 2020)



We, at Fizzy Brizzy Games LLC ("Fizzy Brizzy Games" "we" or "us"), are committed to respecting your privacy and the integrity and security of your personal data.



Fizzy Brizzy Games is data controller with legal address at prospekt Pobediteley 106, office 012, Minsk, 220062 Belarus.



This Privacy Policy applies to www.fizzybrizzy.com, all other sites or online services that is owned or operated by Fizzy Brizzy Games, all mobile games published by Fizzy Brizzy Games, Fizzy Brizzy Games games that can be played through third party platforms (collectively "Services") We reserve the right to change our practices and this Privacy Policy at any time. Each time a user accesses our Services the current version of the Privacy Policy applies, and you agree that the personal data we collect will be subject to the Privacy Policy, as updated. We encourage you to check this page regularly so that you know our current practices.



Please read this Privacy Policy carefully, because it is important for you to understand what we do with your information and how you can control it.



1. WHAT DATA WE COLLECT

While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you ("Personal Data", or "data" or "information"). We may also collect Personal Data automatically, or from third-party partners or services.



Thus, We collect data in three ways:



1. Data you provide to us:

- Basic Identifiers and Contact Information (such as your name, email, and phone number);

- Your messages to the Services (such as chat logs and player support tickets)

- Other data you choose to give us;



2. Data we collect automatically

- Data about your game progress;

- Device Information (such as type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI), language, time zone and IP address;

- General location data;

- Usage Information (such as the date and time you used a service, features you have used, you're in-app purchases history, subscriptions, your interaction with advertisements, and data generated when you use our Services);



3. Data we collect from our partners

- Data we receive if you link a third-party tool with the Services (such as Facebook, or Google);

- Demographic data (such as to determine the coarse 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 a better Services.



2. WHY DO WE COLLECT YOUR DATA



- To provide and maintain our Services as well as perform essential business operation. Our legal basis for processing is performance of a contract obligations with you which you entered into with us when you download our Services and accept our Terms of Use.

- To show personalized advertisements. Our legal basis is legitimate interests to run our business. For information on how to opt-out from personalized advertisements, see section "Your rights and options" below.

- To keep the Services safe and fair. Our legal basis for processing is legitimate interests for running our business, provision of administration and services.

- To respond to legal proceedings and other obligations or requirements under applicable law.



3. WHY WE SHARE YOUR PERSONAL DATA

Any transfer of your personal data to any of our partners is made, provided that such third parties comply with applicable personal data protection laws, including, but not limited to, General Data Protection Regulation 2016/679. Any transfer of your personal data to a third party is based on an agreement with such third party, and we make sure such a third party complies with the applicable data protection regulations, unless we are entitled by applicable data protection laws to transfer personal data without a written agreement (for example, if you have given you consent to such third party to obtain your personal data from us).



We may share the above categories of Personal Data for certain business purposes, including:



- Analytics

In order to analyze various aspects of Services, we need to collect and process certain information with regard to your interaction with the Services. Such information includes your location data, information about your device and advertising data. It may also comprise information about errors of the Game functioning. For this purpose we use technologies and solutions provided by third parties – our analytical partners. We integrate such technologies into the Services and our partners process the data on our behalf to provide us with analytics. For more information regarding our analytical partners please see APPENDIX A – Analytics and Advertising partners.



- Advertising

We may share information with advertising partners who distribute advertising in our Services. For more information regarding our Advertising partners please see APPENDIX A – Analytics and Advertising partners.



- When required by law

We may also share information if we also under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.



- With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

4. RETENTION OF PERSONAL DATA

We retain all the data we collect for as long as you use our Services and 30 months after you stop using the Services. If you do not use the Services for 30 continuous months, we erase your personal data from our data base, as well as request the same erasure from any third parties whom your data may have been transferred to. We may erase your personal data earlier if we do not need to process such data anymore.

5. YOUR RIGHTS AND OPTIONS

- Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your device:

• For Android devices: Open Settings -> Select Google -> Select Ads and enable "Opt out of Ads Personalization"

• For Apple devices: Open Settings -> Select Privacy -> Select Advertising and enable "Limit Ad Tracking"

- Access the personal data we hold about you

You have the right to access your personal data, which we hold. Under your request, we may provide you with a copy of your personal data in an electronic format.



- Right to erasure (deletion)

You have the right to ask us to completely delete your personal data. In order to have your personal data erased (deleted), please, send us a message describing your request.



- Your other rights

You also have the right to rectification (correction), right to object, right to withdraw consent, right to data portability, right to restriction of processing.



6. CALIFORNIA STATE RESIDENTS RIGHTS

If you are a resident of state California, USA, the California Consumer Privacy Act (CCPA) gives you the right to request disclosure of information that we collect about you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information).

Also, being a resident of state California, USA, you have the following rights:

- to request deletion any personal information about you;

- to request disclosure of the categories and specific pieces of personal information that we have collected about you;

- to request disclosure to you the following: the categories of personal information we have collected about you; the categories of sources from which the personal information have been collected; the business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; the specific pieces of personal information we have collected about you; the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.



We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny your our Services; (ii) charge you different prices or rates for our Services; (iii) provide you a different level or quality of Services; (iv) suggest that you may receive a different price or rate for Services or a different level or quality of Services.



If you have any concerns regarding your privacy, you can exercise the abovementioned rights by contacting us at legal@fizzybrizzy.com. Please note that we reserve the right to ask for reasonable information to verify your identity before we process your request.

7. AGE LIMITS

We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 16 and over. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.

8. CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact us at legal@fizzybrizzy.com. Please note that for the exercise of some of your data subject rights, we might be requested by law to verify your identity.


















































APPENDIX A – ANALYTICS AND ADVERTISING PARTNERS


(Last Updated: May, 2021 with effective date 21 May 2021)





Our analytics partners



We use your information to perform our own analytics and to enable analytics provided by third parties. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider's privacy notice.



• AppsFlyer
AppsFlyer is analytics service provided by AppsFlyer Ltd (Israel).

Privacy Policy: https://www.appsflyer.com/services-privacy-policy/?__hstc=216715721.dd28538fcc2a42abff66bc364958ea26.1537945624023.1552210524725.1553515495184.93



• AppMetrica
AppMetrica is an app analytics and marketing platform provided by Yandex Oy Limited Company (Finland).

Privacy Policy: https://yandex.ru/legal/metrica_agreement/

• Facebook Analytic Facebook Analytics is an analytics service provided by Facebook, Inc. (USA).

Privacy Policy: https://www.facebook.com/about/privacy/

• Unity Analytics
Unity Analytics is an analytics service provided by Unity Ads Inc. (USA)

Privacy Policy: https://unity3d.com/legal/privacy-policy


Our advertising partners

In order to provide our Services, including personalized advertisements to our users, those listed below use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA).



• Unity Ads
Unity Ads is an advertising service provided by Unity Ads Inc. (USA)

Privacy Policy: https://unity3d.com/legal/privacy-policy/