Welcome! This Privacy Policy explains how OwlCus Studio (” OwlCus ” or “we”) collect, use, and share your personal information while you play OwlCus ‘s games (“Games”) and/or use OwlCus ‘s websites that link to this Privacy Policy (“Websites”) and what rights you have if we are processing your personal data.
It is important that you read this notice before accessing or using the Services so that you are aware of how and why we may use data relating to you. In addition to this notice, we encourage you to carefully review our Terms of Service, which govern your use of our Services.
1. What kind of personal information does OwlCus collect?
We aim to minimize how much personal information we collect from users when they play the Games or use the Websites. We collect the personal information that you voluntarily provide to us (e.g. email addresses you give us to subscribe to our Newsletters (as defined below)), but most of our data collection is limited to the following types of data, which do not identify you personally but may uniquely identify the device you are using to play to the Games or use the Websites (“Device”). In some countries, this type of data may be considered as personal information:
· Advertising ID”, which means the resettable and unique identifier associated with your mobile phone or tablet that is used by advertisers for ad tracking.
· “Location Information”, which means general information about the location from which you’re playing the Games or using the Websites (e.g. IP address, country, and city).
· “Device Information”, which means technical information about your Device. When we refer to Device Information, this means your Device ID, your internet service provider (ISP), your browser and browser plug-in types, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your Device, the language you’ve set for your Device, the version of the Game installed on your Device, and the name of your carrier.
Does OwlCus Collect My Financial Information When I Make In-App Purchases?
When you make in-app purchases in the Games, we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. Apple’s Game Store or Android’s Google Play) or your platform’s payment processor.
2. Why do we process your data and on what basis?
To perform our contract with you, we may process your data as necessary to:
– Create and maintain an account for you in our Games or other Services where applicable,
– Enable you to play our Games or use our other Services,
– Provide the correct version of our Games or other Services to you (for example, selecting an appropriate language version for you),
– Where available, enable you to communicate with other users in our Games or other Services (for example, by providing chat, forums, or other similar features),
– Send you service-related communications (for example, technical notices, security alerts, or administrative messages), or
– Verify your purchases or other transactions in our Games or other Services.
Based on our legitimate interest to make our Services the best they can be, we may process your data to:
– Operate and maintain our Services (for example, by making sure our Services are secure and function as intended),
– Troubleshoot or debug any bugs, errors, or other issues in our Services,
– Measure and analyze the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations),
– Create data that is not identifiable to you (for example, aggregate data), which we may then use and share freely,
– Conduct surveys or other research to learn more about our users, or
– Improve our current Services or develop new Services.
Based on our legitimate interest to make sure you have the best possible user experience in our Games, we may process your data to:
– Personalize your gameplay experience in our Games based on your activity,
– Provide you with offers and rewards in our Games based on your activity,
– Where available, enable your gameplay across multiple devices (for example, by allowing you to connect a third-party account with our Games for that purpose),
– Where available, provide social features (for example, clans, matchmaking, or leaderboards) or events in our Games or other Services,
– Handle your support requests or otherwise manage our relationship with you, or
– Send you service-related communications (for example, technical notices, security alerts, or administrative messages).
Based on our legitimate interest to make sure our Services are a fair and safe environment for all users, we may process your data to:
– Moderate and monitor the use of our Games or other Services (including any messages sent through the Services), either automatically or manually, or
– Ensure that our Terms of Service and, in particular, our Code of Conduct are followed.
Based on our legitimate interest to promote our Services and to make sure we reach interested audiences, we may process your data to:
– Keep track of installations of our Games (including the source of each install),
– Measure, analyze, and improve the effectiveness of our advertising (including our advertising outside of our Services),
– Send you communications about offers, rewards, events, or other news related to our Services or other operations,
– Request our advertising partners to show or not show our ads to you based on your activity (including by limiting the number of times you see our ads), or
– Request our advertising partners to advertise our Games or other Services to audiences who they believe have interests similar to yours.
Based on our legitimate interest to provide you with relevant ads in our Games and to fund our Services so that we can keep providing them to you, we may process your data to:
– Show ads to you in our Games, either from us or our advertising partners,
– Keep track of your activity in our Games to learn about your interests and improve the advertising in our Games
– Personalize, or allow our advertising partners to personalize, the ads you see in our Games to make them more relevant to you
Based on our legitimate interest to safeguard our operations, we may process your data to:
– Detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior,
– Audit our operations or processes (for example, to verify that they function as intended and according to regulatory or contractual requirements), or
– Establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations.
With your consent, we may process your data:
– To send you newsletters or other similar communications if you have subscribed to them (for example, through a subscription form on our Websites) or
– For other purposes explained to you when we ask for your consent (for example, using your GPS location to provide location-based experiences).
Finally, we may process your data as necessary to:
– Comply with legal obligations which we believe apply to us (including accounting and tax requirements and requirements to provide information to competent authorities upon due request) or
– Protect your vital interests or the vital interests of another person.
– In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
We do not use your data to make automated decisions which significantly affect you. By an “automated decision”, we mean a decision made by an information system without any human intervention.
3. Advertising
Advertising funds our Services and enables us to make our Games available free of charge. In our Games, we show our own ads and also ads from third parties. We also advertise outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes.
Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of a device. It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices.
Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them to your desired state on each of your devices individually. It may take some time for your updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads, but the ads you see may be less relevant to you.
For more information on mobile privacy settings, you may refer to third-party resources such as:
https://www.networkadvertising.org/mobile-choice
When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed.
When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. Ad networks may also use your data to:
– Mit the number of times you see our ads,
– Inform users who have previously played our Games about new content, updates, or other news related to those Games, or
– Refrain from showing our ads to users who already play the Game being advertised.
In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services.
For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. It is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.
4. Cookies and similar technologies on our Websites
Like most websites today, our Websites may use cookies or similar technologies (for example, local shared objects or web beacons).
A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.
Using your browser or device settings, you can control the use of cookies, for example by disabling some or all cookies or configuring your browser or device to notify you when cookies are being set. However, please consider that disabling cookies may affect your ability to use the Services.
5. What data do we process?
We may process the following data relating to you:
– Your name, email address, or other contact information if you have provided them to us (for example, when registering an account or subscribing to our communications),
– Online identifiers such as your in-game alias, IP address, identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID,
– Technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
– Your coarse location (for example, country, state, or city), inferred from your IP address,
– Information about your use of the Services (for example, information about your progress in our Games, your visits to our Websites, or your interactions with ads in our Games),
– Information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
– Crash logs or other information related to bugs, errors, or other issues in our Services,
– Inferences we make based on your activity in our Services,
– Messages or other communications you send to us or through the Services (for example, your chat messages in our Games or emails you send to our support team),
– If you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends information to provide social features),
– If you make purchases in our Games, information we receive from third-party payment service providers to validate those purchases,
– If you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications,
– If you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
– Any other information you choose to submit to us through our Services or otherwise, and
– With your consent, other information explained to you when asking for your consent (for example, your GPS location for location-based experiences).
We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
6. Where do we collect your data from?
We may collect data relating to you from the following sources:
– Directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
– Directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
– If you interact with ads in our Games or our ads outside of our Services (for example, on third-party websites or applications), from our advertising partners involved in the delivery and measurement of those ads,
– If you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
– If you make purchases in our Services, from the third-party payment service provider involved in those transactions, or
– With your consent, from other sources explained to you when asking for your consent.
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings.
7. Who do we share your data with?
We may share your data with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:
– Other companies in the OwlCus Studio, for example where they help us develop or operate our Games or other Services,
– Persons or companies outside of OwlCus Studio that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services),
– Other partners we work with while providing the Services (who may process your data independently of us), including advertising partners and others listed here,
– Prospective or actual buyers (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
– Competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation,
– Any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
– With any other person or entity with your consent.
In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards.
In connection with the processing activities described in this notice, your data may be transferred to and/or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies or the service providers we use to provide the Services may be located outside of the EU and the EEA. These countries may have data protection laws that differ from the laws of your country. In these cases, we will provide appropriate safeguards to protect your personal data. These safeguards may include compliance with the European Commission’s standard contractual clauses for transfers of personal data or reliance on the EU-US Privacy Shield framework. Upon request, we can provide you a copy of the European Commission’s standard contractual clauses and further details on the applicable safeguards.
8. How long do we keep your data?
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements.
9. Is my personal information secure?
The security of your personal information is important to us. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our Service Provider stake appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. For OwlCus , this includes, but is not limited to, ensuring that all of your information is disclosed only on a “need to know” basis and ensuring that all information collected by OwlCus is done so via secured connections and protected and encrypted (using secure socket layer technology, “SSL”) by industrial grade security software to guard against unauthorized access.
10. Age limit
Under our Terms of Service, you represent that you are at least 13 years of age. However, we do not know the specific age of individual users of our Services. If you are under 13 years of age, please do not provide your personal data (including your name, address, telephone number, or email address) to us or use the Services to make your personal data available to others.
11. Social media features and tools.
The Websites and Games may include integrated social media features and tools, such as the Facebook “Like” button, the YouTube “Share This” button, and the Twitter “Follow” button. These features may collect information on your IP address, which Website you are visiting, and may set a cookie to enable the feature to function properly. Social media features and tools are hosted by a third-party, and your interactions with these integrated social media features and tools are governed by the privacy policy of the company providing it.
12. Changes
We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.
OwlCus 
Leave a comment