Effective Date: 5/25/2018
Owner & Data Controller: Ringtones Sesleri
Owner contact email: email@example.com.
(“Ringtones Sesleri“ or “we”), is a developer and publisher of mobile games and applications that are made available via app stores including but not limited to the Apple App Store, Google Play Store, Amazon App Store, Microsoft app store, Oculus store and other platforms such as Facebook (our “Games”). Ringtones Sesleri is responsible for providing Games and related services (such as support services, our website, competitions, newsletters, advertising etc.) (collectively, the “Services”) and for data processing. If you would like to find out more about Ringtones Sesleri and our Services, please visit the Imprint section of the Games or our Website.
We hope to unite people in fun and enjoyment through our Games, so we create games that you can play and share with other people. This means that our Services can be accessed and shared with friends or in social networks. We believe that data protection is as important as uniting people through our Games and, therefore, we aim to protect your privacy as best as we can. If you use third party services – for example while playing one of our Games on Facebook – please note that those service providers will also collect personal data, that is not part of our service.
Who can I contact?
Ringtones Sesleri is responsible for their Services and for the protection of your data as a player. You can reach us at: firstname.lastname@example.org.
If you have specific questions about your personal data, deletion of your personal data or similar things, you can contact our Data Privacy Officer via e-mail at email@example.com.
What are my rights?
You can contact us at any time if you have any questions about your rights regarding data protection or if you wish to exercise any of the following rights:
Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you can contact us if you wish to cancel a previously given consent to a newsletter) (If applicable)
Right to access your data in accordance with Art. 15 GDPR (e.g. you can contact us if you would like to know what data we have stored about you). Please be very specific about personal information that you are asked us to provide, and the reasons why you are asked to provide it. Also at some point we will ask you to confirm that you are actually are that person by applicable means.
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your e-mail address has changed and we should replace your old e-mail address) (If applicable)
Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you) (If applicable)
Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can contact us if you do not want us to use your e-mail address for newsletters, but only to send absolutely necessary e-mails)
Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data, if you want to upload it to another service) (If applicable)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly)
Deletion of data and storage periods
Unless otherwise stated, we will delete or anonymise your data as soon as it is no longer needed (e.g. your e-mail address after you have unsubscribed from our newsletter). Your data will also be deleted or anonymised automatically, if and when the mandatory storage period expires (e.g. those required by law for payment transactions). Such data may be needed for longer periods of time for legal reasons. You can request information about all personal data we have stored about you.
Data collected in our Games
When you use our Services, we collect and store certain data about you to provide our Games and Services, to improve your overall user experience and to provide you with customised offers (e.g. certain in-game offers that you might like based on your playing behaviour):
Temporary unique device identifiers (e.g. IDFA and Android ID) and random device identification numbers (client IDs) and user identification numbers (user IDs)
Progress in the game and playing behaviour (for example your default settings)
In-app purchases (e.g. how many Diamonds you purchased)
Game version (Usually this is something like v1.0.1)
Language Settings (e.g. system language English)
IP address (or example any valid IP4 or IP6 address)
Approximate location based on IP range (e.g. “France”)
Date and time of your game session
Operating system (e.g. iOS, Android)
Hardware (e.g. Intel processor)
You may be aware that your IP address and other unique identifiers can theoretically be traced back to you or to the device you are playing on. We delete or anonymise identifiers in our database and most of the technical data after your game session. Any other data will only be used for statistical purposes to optimize the game, to serve interest-based ads (more information can be found below under “(Personalized) Advertising”) and to offer a more personalised gaming experience to you as our players (e.g. automatically setting the difficulty depending on your playing behavior). The purpose of temporarily storing this data is to establish a connection with our game servers which is necessary for providing our Games and Services as well as to provide a more personalized gaming experience to you. The legal basis are the contract with you in accordance with Art. 6 para. 1 lit. b GDPR and also the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR. In addition, we apply the aforementioned safeguards to protect your data.
Mobile app and app permissions
When downloading our Games as mobile apps or purchasing in-app items inside the Games through an app platform (e.g. Apple App Store or Google Play Store), you submit certain information to that platform, in particular your account data, e.g. your name, device identifiers, e-mail address and payment information. We have no influence on this data collection and are not responsible for it.
Some features of our Games require the app to access certain functions and services on your device. Depending on which mobile operating system you are using, this may require you to accept certain app permissions. We will now explain to you what those permissions are as follows:
Push notifications: If you select OK in the “Allow push notifications” pop up, you allow the app to notify you of certain events inside the game, even if the app is not currently open. You will then receive alerts as sounds, messages and/or symbol indicators (an image or a number on the app icon).
External Storage (Change or delete the contents of your external storage, read the contents of your external storage): These functions allow the app to temporarily store content on your device. The app only uses its own memory storage for this purpose. Other data on the external storage will not be erased, modified or read.
Internet Connection (Get Internet data, view full network access, network and Wi-Fi connections): These functions allow the app to obtain data from the Internet and to determine whether a connection to the Internet exists via a Wi-Fi network or via a mobile data connection. This is to prevent that larger amounts of data may use too much of limited data volumes.
As a safeguard to protect your privacy, all app permissions are optional, except for the technical permissions needed for the app to run. You can always decline (by clicking “no” or “do not accept” in your device settings). You can also revoke app permissions afterwards by changing the corresponding settings on your device. The purpose of asking for those app permissions is to keep you and the game updated on game updates, game related news and notifications. The legal basis is your consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR.
Connecting with Facebook
Public profile information (e.g. Facebook name, your profile picture and other public information etc.)
Friends list (friends you are connected with on Facebook)
E-Mail address (the e-mail address you use to log in to Facebook)
Facebook game specific ID related to your profile and the game you are playing (not your Facebook ID)
We use this information to improve your gaming experience (e.g. you can see which of your friends are playing the same game as you are and the other way around) and also for market research and advertising, but only following anonymisation.
As a safeguard to protect your privacy and the privacy of your friends, Facebook lets you choose which of your Facebook information you want to share with us (except for the required profile information) and we ensure that personal information is deleted or anonymised, so that it cannot be traced back to you in our systems. Since some of the Facebook services are located in the USA and thus in a country outside the EU and the EEA (a third country), further safeguards are required to ensure that your data is protected in accordance with a European level of data protection. Facebook has been certified under the EU-US Privacy Shield for the ad-related services and has thus demonstrated a sufficient level of data protection (https://www.facebook.com/about/privacyshield). The purpose of collecting and storing this information is to connect you with your friends on Facebook, to provide you with a cross-platform gaming experience, to synchronize your saved game status and to offer personalized advertising. The legal basis is your consent – when choosing to connect your Facebook account – in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR.
We use advertising technologies in our Games and exchange ad identifiers with external advertising networks to allow personalized advertising within our Games. We and our trusted partners collect and process the Apple Advertising ID (IDFA) on iOS devices and the Google Advertising ID on Android devices to allow interest-based advertising and measure the success of aforementioned advertising. Advertising IDs are unique but at the same time non-personalized and non-permanent identification numbers provided by your operating system and device. We will now explain how to activate or deactivate the advertising technologies within the mobile apps as follows:
Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.
Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalization” to prevent the creation of profiles and the display of interest-based advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.
As a safeguard to protect your privacy, we only store personal information temporarily. Additionally, the user can deactivate interest-based advertising in the device settings as described above. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve our Games and provide the player with more relevant ads. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base. The legal basis is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR.
Third party services
We and our partners use ad serving technology to provide ads relevant to your interest within our apps. In this connection, both we and our partners may collect and use information about you like your Service session activity and IP address. Our advertising partners operate under their own privacy policies, so, for more information check out the links below:
https://www.facebook.com/policy.php – Facebook Audience Network
https://www.applovin.com/privacy – AppLovin