Privacy Policy

---

(with effective date 01 August 2022)

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.

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.

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).

                                                                                 WHAT DATA WE PROCESS

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.