20 February 2020
The information we collect depends on what products you use and how you use them. The controller of the personal information collected is:
Imangi Studios LLC
4601 Six Forks Road
Suite 121, Raleigh, NC 27609.
We collect information you provide us, including:
When you participate in social features through a Social Media Site, the information 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 your privacy settings on the Social Media Sites you use reflect your preferences.
When you participate in online leaderboard components of our products, your in-game profile information, gameplay, and statistics may be visible to all.
We collect other information automatically when you use our products, including:
We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage and application data caches.
To comply with local laws, we may need to collect your IP address to help us determine your country of residence. In that case, your IP address may be sent to a server that we control, for evaluation purposes, but will not be stored or further processed. We also use your device settings to determine the country where you are located as a way to respect privacy laws specific to your location. We do not collect your precise location, at a level more granular than your city, without your explicit consent.
If you play or purchase our games or in-app purchases on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide, through systems such as Google Play Services or Apple Game Center.
We may receive information from third parties, like Facebook or other Social Media Sites, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us. We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.
We collect some information from you when you provide it to us directly, such as via an online form or when you communicate with our customer support team. We and third parties also use certain technologies, described below, to deliver positive customer experiences.
Our products change over time and those changes are reflected in new versions that are available to download from the Apple App Store, Google Play Store, Amazon App Store, and other official stores. Imangi recommends that you always use the latest version of our products to guarantee you have the most secure, privacy-oriented, and engaging experience possible.
Imangi cannot guarantee the integrity of versions of products that are installed from unofficial channels and does not support, provide customer support, or provide privacy guarantees for those unofficial versions. If you are using a version of one of our products that was installed from an unofficial channel or is no longer supported, we encourage you to remove it from your device as soon as possible and install an officially distributed version.
We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.
For example, Imangi may collect and store data from your device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP address and device ID), information about your feature usage, gameplay and usage statistics and system interactions. If you play a game offline, this data will be stored on your device and may be transmitted to Imangi when your device connects to the Internet. If you participate in online components of our games, such as leaderboards, Imangi may also collect, use, store, transmit, and publicly display statistical data regarding game scores and achievements.
Third party analytics services integrated into our products may combine the information they collect in connection with Imangi’s services with information they have independently collected over time and across different websites and applications. Many of these companies collect and use information under their own privacy policies. A list of the third party analytics companies that operate in our products can be found in the Appendix below.
These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to device advertising identifiers, this information includes:
Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different products, websites, and services. Many of these companies collect and use information under their own privacy policies. A list of ad serving companies that operate their own networks in our games as well as how to opt out can be found below.
To learn more about some of these ad networks’ practices, see the Your Choices and Controls section below and read their privacy policies, linked in the Appendix below.
European Economic Area only. Prior to being shown ads in Imangi products, you will be asked whether you consent to the tracking that enables personalized ads. You have the right to change your consent status at any point in time. If you have questions about how to change your consent status or to inquire regarding your rights to erasure or data portability, please contact our privacy team at firstname.lastname@example.org.
California only. Prior to being shown ads in Imangi products, you will be asked to verify whether you are over the age of 16. If you are not, you will be asked whether you consent to the tracking that enables personalized ads. You have the right to change your consent status at any point in time. If you have questions about how to change your consent status or to inquire regarding your rights to erasure or data portability, please contact our privacy team at email@example.com.
We use your personal and non-personal information, both individually and in aggregate, in the following ways:
To operate our business and to enhance and personalize your game experience, including to:
To provide you support, including to:
To personalize our communications with you, including to:
Imangi uses analytics services to understand how users engage with our products. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one Imangi product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of the Imangi products you have installed. The identifier value is provided to Imangi through the operating system on your device. In the course of processing your data, we may do any of the following:
European Economic Area (EEA) Only:
Per requirements under the EU’s General Data Protection Regulation (GDPR), we log your consent state for compliance purposes. This information is stored on servers hosted in the EU and is used solely for GDPR compliance. Your device identifier is stored along with your consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in our consent logging database if you do not consent to personalized advertising.
We do not share personal information that directly identifies you (such as your name, email, or postal address) with independent third parties without your consent, unless it is required by law or we determine that disclosure is critical to protect our rights, property, or operations or to protect our players or third parties. We may share anonymous (including pseudonymous identifiers) or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys or analyzing gameplay event data. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.
However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook “Like” button.
European Economic Area (EEA) Only:
We have put in place reasonable controls designed to help safeguard the personal information we collect via our products. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an unauthorized way.
Protecting children’s privacy is extremely important to us. We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times.
Imangi’s products are not intended for children under the age of 13 and we do not knowingly collect any personal information from children under the age of 13. If you are a resident of the European Economic Area (EEA) under 16 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access Imangi’s products. Additional age-based privacy information specific to California residents is set forth below in the Privacy Notice for California residents. If you believe Imangi has inadvertently collected information about your child, please contact us (information below) so we can promptly remove the information.
Imangi has a policy of retaining information we collect for a period of up to 180 days. During the period when we hold Information, we may transform and aggregate it such that it no longer is personally identifiable. We may retain the de-identified aggregate data products for more than the retention period to support business critical needs.
Uninstalling Imangi applications from your devices does not cause the data that we possess to be deleted. It remains subject to the same data retention and expiration policies.
If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Imangi may collect in-game technical or usage data or gameplay analytics for players. Note that Google Play Services, Apple Game Center, and other platform-level services may also collect gameplay analytics if you are located within the EEA. Please see your device-level settings for more information about how to disable those services. Imangi considers any data specific to your use of our apps that is collected or processed by Imangi or through Google Play Services or Apple Game Center to be in our legitimate business interests.
Imangi works with advertising partners that may collect information from you as part of their process of serving advertisements in our products. This is described above in the section “Ad Serving Technologies.” In accordance with the General Data Protection Regulation (GDPR), Imangi’s advertising partners in the European Economic Area function as independent data controllers and processors. Prior to showing you personalized advertisements, you will be asked whether you consent to sharing your information with the advertising company. If you are a resident of an EEA country and indicate that you are below the age of 16, you will be served non-personalized ads and the advertising companies will not collect personal information from you.
Under the GDPR you have a right to have Imangi and our third party partners erase the personal information we have collected from you without undue delay.
Under the GDPR you have a right to request a copy of the personal data Imangi and our third party partners have collected from you.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. To change your consent status, please visit the following screen in the product you are playing:
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at firstname.lastname@example.org or Imangi Studios LLC, 4601 Six Forks Road Suite 121, Raleigh, NC 27609 USA.
Under the GDPR, you have the right to object to the processing of your data. If you wish to object to the processing of your data, please contact us at email@example.com or Imangi Studios LLC, 4601 Six Forks Road Suite 121, Raleigh, NC 27609 USA.
This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We may use reasonable proxies, such as time zone or other data where we do not know the state of residence of a person, to determine whether a user is a California Resident - we do not ask users of our games for their address or state of residence. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
Personal information does not include:
In particular, we have collected the following categories of personal information from consumers within the last 12 months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (only for delivery of contest rewards where required by tax laws), or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age, sex (including gender) only if provided to us by you in a survey or online form.
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Equipment Information
Information about your internet connection, the equipment you use to access use our products, and usage details.
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose the personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information other than persistent identifiers for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We disclose persistent identifiers with our advertising partners, who may use those persistent identifiers, share them with their other partners, combine information from other sources with those persistent identifiers, or otherwise use them consistent with their privacy policies.
We share your personal information with the following categories of third parties:
In the preceding 12 months, Imangi has disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
We do not provide these access and data portability rights for B2B personal information.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We do not provide these deletion rights for B2B personal information. Additionally, if you uninstall all of our products, your device identifier is lost and prior usage information and similar information tied only to that IDFV could not be linked to you and therefore could not be deleted.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights .
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response electronically.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at email@example.com
We log your consent state for compliance purposes.
Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales (unless you uninstall all of our products and reinstall any of our products, which will reset your IDFV). However, you may change your mind and opt back in to personal information sales at any time by adjusting your settings in the applicable product application.
We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write to us at: Imangi Studios, Attn: Privacy Officer, 4601 Six Forks Road, Suite 121, Raleigh, NC 27609, USA.
If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative https://www.networkadvertising.org/ and/or the DAA Self-Regulatory Program for Online Behavioral Advertising https://www.aboutads.info/principles. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please download the version of AppChoices for your device here http://youradchoices.com/appchoices or visit these websites:
Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
We maintain a list of Frequently Asked Questions at the following URL, on the Imangi website. http://imangistudios.com/contact.html
For other customer support needs, please contact email@example.com. Our customer support team uses Zendesk to answer support requests. When you email customer support, your email address will be entered into the Zendesk system for the sole purpose of processing your support request. After your support request is processed, it will be marked as “closed” and be automatically deleted from the Zendesk system and the customer support email account after thirty days. Please do not include any personal information in your email to customer support.
If you have questions regarding this Policy or about Imangi’s privacy practices, please contact us by email at firstname.lastname@example.org, or at:
Attn: Privacy Officer
4601 Six Forks Road
Raleigh, NC 27609
Non-English translations of this Policy may be provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
This table summarizes our ad serving and analytics providers and where you can go to get more information about their policies and practices and opt out of their networks in many cases.
* Indicates a company or service whose software may be integrated in older versions of Imangi products but are not present in versions released after May 2018.
|Company Name||Purpose||Link||Personal data shared||Contact Info|
|AdColony||Advertising||https://www.adcolony.com/privacy-policy/||Advertising identifier, IP Address, email@example.com|
|AdMob||Advertising||https://policies.google.com/technologies/ads||Advertising identifier, IP Address, firstname.lastname@example.org|
|-- AdMob Partners||Advertising||https://support.google.com/admob/answer/9012903||Note that, at this time, AdMob may serve ads from any of these providers in the EEA through its mediation email@example.com|
|Applovin||Advertising||https://www.applovin.com/privacy||Advertising identifier, IP Address, location||dataprotection@Applovin.com|
|Chartboost||Advertising||https://answers.chartboost.com/en-us/articles/200780269||Advertising identifier, IP Address, firstname.lastname@example.org|
|Facebook Audience Network||Advertising||https://www.facebook.com/policy.php||Advertising identifier, IP Address, location||https://www.facebook.com/help/contact/861937627253138|
|Fyber||Advertising||https://www.fyber.com/services-privacy-statement/||Advertising identifier, IP Address, email@example.com|
|Google Analytics for Firebase||Analytics||https://cloud.google.com/terms/data-processing-terms||Device identifier, advertising identifier, IP Address, location||https://support.google.com/cloud/contact/dpo|
|Google G Suite||Support||https://support.google.com/googlecloud/answer/6056650?hl=en||Email address and other information emailed to Imangi||https://support.google.com/cloud/contact/dpo|
|InMobi||Advertising||https://www.inmobi.com/privacy-policy/||Advertising identifier, IP Address, firstname.lastname@example.org|
|ironSource||Advertising||https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/||Advertising identifier, IP Address, email@example.com|
|Mintegral||Advertising||https://www.mintegral.com/en/privacy/||Advertising identifier, IP Address, firstname.lastname@example.org|
|Smaato||Advertising||https://www.smaato.com/privacy/||Advertising identifier, IP Address, email@example.com|
|TapJoy||Advertising||https://www.tapjoy.com/legal/#privacy-policy||Advertising identifier, IP Address, firstname.lastname@example.org|
|Unity||Advertising||https://unity3d.com/legal/privacy-policy||Advertising identifier, IP Address, email@example.com|
|Unity Cloud Diagnostics||Analytics||https://unity3d.com/legal/privacy-policy||Device identifier, IP Address, firstname.lastname@example.org|
|Zendesk||Support||https://www.zendesk.com/company/customers-partners/privacy-policy/||Email address and other information emailed to Imangiemail@example.com|
|Vungle||Advertising||https://vungle.com/privacy/||Advertising identifier, IP Address, firstname.lastname@example.org|