Privacy Policy

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( with effective date 15 November 2023 )

We, at UAB Fizzy Brizzy Games (“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 a data controller with legal address at Lvivo g. 25-702, LT-09320 Vilnius, Lithuania.

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 process 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 PROCESS

The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: 

(A) data you provide to us; 

(B) data we collect automatically; and 

(C) data we collect from our partners. 

We do not knowingly collect (D) special categories of information.

A. DATA YOU PROVIDE TO US

• Contact information (such as name and email address).
• Your messages to the Services (such as chat logs and player support tickets).
• Other data you choose to provide us when you contact us (through the Services, social media, e-mail or any other channels).

B. DATA WE COLLECT AUTOMATICALLY

• Data and analytics about your use of our Services (e.g. your game progress, the date and time you used a Service, session length, features you have used, your in-app purchase history, your interaction with advertisements).
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI).
• Non-identifying data about your device, such as device name and operating system, browser type, language and other technical data like screen size or processor, or combination of this data available for a developer for checking the device compatibility with a particular Service
• Geolocation data  - your accurate geolocation data based on GPS.
• Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services.

Note that we do not use such data to learn a person’s true identity or contact details, but mostly to understand how our users typically use and interact with our Services, so that we could maintain and improve them.

C. DATA WE COLLECT FROM OUR PARTNERS

• Third-party tools. Data we may receive if you choose to link a third-party tool with the Services (such as Google or Apple). Exactly what information we receive from such third-party tool will depend on your privacy settings, but it would typically include your basic profile information such as your user id, username, gender, picture, e-mail, your friends playing the same game. We do not get access to or store your logins or passwords for any of these third-party tools.
• Third-party platforms. In-app purchases are typically processed by the platforms (e.g. Apple App Store, Google Play, Amazon AppStore or Facebook). We do not collect or store your financial data, such as your credit card number or bank account. You are requested to provide payment details directly to the relevant platform. We may, however, receive limited non-financial data relating to the purchase (e.g. platforms may notify us if a purchase was successful). Any post-purchase processes are controlled by the platforms. We encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Services.
• Advertising partners. From time to time, we may receive non-personal information from our advertising partners concerning the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of our Service originated from or data necessary to fight fraud (such as refund abuse in games or click fraud in advertising).
• Third-party service providers. Our analytics providers may provide us with information regarding your use of our Services (such as in-game events, your interaction with the Services and in-game advertisements, software errors, etc.) so that we could improve our Services.

D. NO SPECIAL CATEGORIES OF INFORMATION

We do not request or intend to collect any “special categories of information” such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please, be cautious when sharing this information about yourself (or others) in our Services.

2. WHY DO WE PROCESS YOUR DATA

• To provide and maintain our Services as well as perform essential business operations.
• To collect analytics connected with our Services.
• To collect statistic which we use for further development of our Services.
• To show personalized advertisements which have been tailored to meet your interests with the help of our partners.
• To keep the Services safe and fair.
• Please note, that we may also process your personal data, in case we are entitled to do so by the applicable data protection laws without obtaining your consent.

3. OUR LEGAL BASIS TO PROCESS YOU DATA

• on the basis of performance of contract’s obligations: we may process your personal data in order to fulfill our obligations under the agreement with you, e.g. provide you with the access to the Services;
• on the basis of your consent to processing: we may process your personal data based on your consent in order to improve our Services, to show advertising, which suit with your interest, etc.
• on the basis of the legitimate interest: the “legitimate interest” means lawful purposes that could be reasonably expected (like informing you about the Services and making sure our marketing is relevant for you, protecting the security of our websites and systems); Please note, that we consider and balance any potential impact on your rights when we rely on the legitimate interest;
• on the basis of applicable law: we may process your personal data in order to fulfill the applicable law’s requirements (e.g. our obligation to keep certain records under tax laws).

A simplified version of why and how we process your personal data, along with the legal basis, can be found at this table "WHAT DATA WE PROCESS?".

4. HOW WE SHARE YOUR DATA

Apart from Fizzy Brizzy Games, your data can be accessed by others in the following situations:

OTHER PLAYERS AND USERS

Social features are a core component of our Services. Other players and users may, for example, see your  real geolocation, profile data, in-game activities and read the messages you have posted.

OTHER COMPANIES AND PUBLIC AUTHORITIES

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 ours, our players or others.

OUR SERVICE PROVIDERS AND PARTNERS

For advertising and analytics and purposes, we use services and solutions provided by third parties. Such parties process these data on our behalf and the respective technical solutions represent a part of our Services. 

Any transfer of your personal data to any third party 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, California Consumer Privacy Act. 

We share your personal data with these third parties only where we have a legal basis as set out above or where such third parties process data on our behalf based on a data processing agreement.

For further information, please, see our List of Partners and their privacy policies.

5. INTERNATIONAL DATA TRANSFERS

Our Services are global by nature and your data can therefore be transferred and processed in other countries other than the country in which you are resident. 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 transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection for personal data of EU residents or standard contractual clauses approved by EU Commission.

6. PROTECTION OF YOUR PERSONAL DATA

SECURITY SAFEGUARDS

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. Although we use commercially reasonable efforts to assure that your data remains secure when maintained by us, please, be aware that no security measures are perfect or impenetrable.

RETENTION OF PERSONAL DATA

We process all the data we collect for as long as you use the 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 database, 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.

7. YOUR RIGHTS AND OPTIONS

• Right of access 

You have the right to access your personal data, which we process. 

• Right of rectification (correction)

You have the right to  request us to make any changes and corrections to your personal data or restrict the processing if it is inaccurate or incomplete.

• Right to erasure (deletion)

You have the right to request us to completely delete your personal data where we do not have a compelling reason to continue to process such personal data in certain circumstances.

• Right to data portability

You have the right to ask us to transfer your personal data to  another controller.

• Right to withdraw consent

You have the right to withdraw your consent for personal data processing. Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent.

• Right to object

You have the right to object to processing of your personal data for the purpose of direct marketing.  You can opt-out of personalized advertising in the “Settings” tab in our mobile applications. Also, you can opt-out of personalized advertising on mobile applications by checking the privacy settings of your Android or iOS device. 

Apple devices: 

• iOS 14/15: open “Settings” - select “Privacy” - select “Tracking” - disable “Allow Apps to Request to Track”
• iOS 13 and older: open “Settings” - select “Privacy” - select “Advertising” - disable “Allow Apps to Request to Track”

Android devices: 

• open “Settings” - select “Google” - select “Advertising” - enable “Limit Ad Tracking”. 

• Right to restriction of processing

Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679. 

• Right to complain

You have the right to lodge a complaint with a data protection supervisory body.

To submit a request regarding your rights and options, please, use the contact details in section 10 below.

8. CALIFORNIA STATE RESIDENTS RIGHTS

This Section applies only to persons who reside in the State of California, USA.

If you are a resident of state California, USA, the California Consumer Privacy Act of 2018 (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:

• Right to know

You have the right to know and see what information we have collected about you over the past 12 months, including:

• The categories of information we have collected about you;
• The categories of sources from which the information is collected;
• The business or commercial purpose for collecting your information;
• The categories of third parties with whom we have shared your information;
• The specific pieces of information we have collected about you.

You may submit once a year, free of charge, a verifiable request to disclose what personal information we collected, used or disclosed about you in the preceding twelve (12) months.

• Right to Delete. 

You have the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

• Right to Opt-out

You have the right to “opt-out”. You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances we may share your information with our partners, who help us deliver advertisements in our games tailored to your interests. To learn what information we collect and how we share it with third parties for advertising purposes, please, see our List of Partners. If you would prefer that your personal information is not shared with third parties in this way, please, see Right to object clause above .

• Right to be free from discrimination

We may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• deny your our Services;
• charge you different prices or rates for our Services;
• provide you a different level or quality of Services;
• suggest that you may receive a different price or rate for Services or a different level or quality of Services.

• Authorized agents

In certain circumstances, you may exercise your rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. We reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, we may deny the request.

• Selling of data

We do not “sell” data of our users as most people would typically understand this term. The definition of “selling” shall be interpreted in accordance with the meaning attributed to this term under US Privacy laws. We do, however, share certain data with third-party advertising partners for the purposes of serving advertisements in our Services, fraud detection and prevention and advertising campaign management. Generally, the data collected is limited the user’s advertising ID, device identifiers and other technical information. Such data collection practices may fall under the definition of “selling” under US Privacy laws.

If you have any concerns regarding your privacy, you can exercise the above mentioned 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.

We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.

9. AGE LIMITS

Our Services are not intended for children. Our Services are intended for use only by those aged 18 and over. We do not knowingly collect personal information from children under 18 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.

10. 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 your request must:

• provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
• contain sufficient details describing your request to allow us to properly understand, review and respond to it.

We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.

HOW WE SHARE YOUR PERSONAL DATA

For advertising and analytics and purposes, we use services and solutions provided by third parties. Such parties process these data on our behalf and the respective technical solutions represent a part of our Services. 

We may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests, In order to combat fraud and illegal activity.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of ours, our players or others.

Any transfer of your personal data to any third party 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, California Consumer Privacy Act. 

We share your personal data with these third parties only where we have a legal basis as set out above or where such third parties process data on our behalf based on a data processing agreement.

For further information, please, see our List of Partners and their privacy policies.

PROTECTION OF YOUR PERSONAL DATA

SECURITY SAFEGUARDS

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. Although we use commercially reasonable efforts to assure that your data remains secure when maintained by us, please, be aware that no security measures are perfect or impenetrable.

RETENTION OF PERSONAL DATA

We process all the data we collect for as long as you use the 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 database, 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.

YOUR RIGHTS AND OPTIONS

• Right of access 

You have the right to access your personal data, which we process. 

• Right of rectification (correction)

You have the right to  request us to make any changes and corrections to your personal data or restrict the processing if it is inaccurate or incomplete

• Right to erasure (deletion)

You have the right to request us to completely delete your personal data where we do not have a compelling reason to continue to process such personal data in certain circumstances;

• Right to data portability

You have the right to ask us to transfer your personal data to  another controller. 

• Right to withdraw consent

You have the right to withdraw your consent for personal data processing. Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent.

• Right to object

You have the right to object to processing of your personal data for the purpose of direct marketing.  You can opt-out of personalized advertising in the “Settings” tab in our mobile applications. Also, you can opt-out of personalized advertising on mobile applications by checking the privacy settings of your Android or iOS device. 

Apple devices: 

• iOS 14/15: open “Settings” - select “Privacy” - select “Tracking” - disable “Allow Apps to Request to Track”
• iOS 13 and older: open “Settings” - select “Privacy” - select “Advertising” - disable “Allow Apps to Request to Track”

Android devices: open “Settings” - select “Google” - select “Advertising” - enable “Limit Ad Tracking”. 

• Right to restriction of processing

Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679. 

• Right to complain

You have the right to lodge a complaint with a data protection supervisory body.

СALIFORNIA STATE RESIDENTS RIGHTS

This Section applies only to persons who reside in the State of California, USA.

If you are a resident of state California, USA, the California Consumer Privacy Act of 2018 (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:

• Right to know. 

You have the right to know and see what information we have collected about you over the past 12 months, including:

• The categories of information we have collected about you;
• The categories of sources from which the information is collected;
• The business or commercial purpose for collecting your information;
• The categories of third parties with whom we have shared your information;
• The specific pieces of information we have collected about you.

You may submit once a year, free of charge, a verifiable request to disclose what personal information we collected, used or disclosed about you in the preceding twelve (12) months.

• Right to Delete. 

You have the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
• Right to Opt-out
  You have the right to “opt-out”. You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances we may share your information with our partners, who help us deliver advertisements in our games tailored to your interests. To learn what information we collect and how we share it with third parties for advertising purposes, please, see our List of Partners. If you would prefer that your personal information is not shared with third parties in this way, please, see Right to object clause above .
• Right to be free from discrimination

We may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• deny your our Services;
• charge you different prices or rates for our Services;
• provide you a different level or quality of Services;
• 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 above mentioned 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.

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.

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 your request must:

• provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
• contain sufficient details describing your request to allow us to properly understand, review and respond to it;

We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.