BEST GAMES PRIVACY POLICY

This policy describes how Best Games (described as “Best Games”, “we”, “us” or “our”) and its third party marketing and advertising partners collect, use, process and share information about you. This Privacy Policy applies to all of our games, whether played on our website , on mobile devices, PCs or on other platforms such as Facebook. It also applies to our Marketing and Advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our "Services". By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to Best Games and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services. Playing our games By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of information about you by us. Most of this data comes directly from you or your device, such as device information, country and region, and game play information. We use this data to provide our games and Services to you, including for the purposes of optimisation, preventing fraud, customising in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes. Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made) and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests. In more detail, depending on which of our Services you interact with we may collect and process the following types of information: - details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services or details regarding profile visits) - the content of messages sent using our chat and messaging systems; - your interactions with us on our social media channels; - information we collect via cookies and other similar technologies, as explained further below; If you choose not to create a profile by connecting your social media account, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including: - the type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, player ID, and the country or region that you are playing in; and - how you play our games and interact with our websites or other Services (such as which of our games you are playing, your progress through the games, session time and duration, number of attempts at each level and purchases made). We may also share your information with third party publishers who develop and provide games and other Services to you on our behalf. We also analyse and use the information that we collect on an anonymised or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimise the games to ensure the best player experience for our players as a whole. A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy. Providing and optimising our Services We use your information to enable us to provide our websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players. Customer Services We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services. Analytics and Research We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content. Cheating, crime and fraud prevention We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police. Visiting our websites When you visit our other websites operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis. The information we collect and process about you when you visit our Websites includes: - information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us; - details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites); - your interactions with us on our social media channels; and - information we collect via cookies (which are small text files placed on your device), and. Cookies allow us to collect data, such as your device's model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies. Marketing Unless you opt out as explained below, we and our third party partners use information collected about you to send you marketing communications about other games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices. What information do we use for marketing? We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as: - ad identifiers and other non-personal information collected from your device. For more information, see Ad identifiers, cookies and similar technologies; - the games you play and information about how you interact with our games and Services; - other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us. Marketing partners When we market our games in media published by other companies, we use various third party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes. Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies. This Privacy Policy does not apply to the collection of your information by our marketing partners. Advertising Our games may include advertising for third party products and services. By accepting this Privacy Policy and downloading or continuing to play our games or use our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games. We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services. What information is used for advertising? We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as: - ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies; - the games you play and information about how you interact with our games and Services; - other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us. Advertising partners When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device. Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems. You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. Opting-out of interest-based advertising You can choose to prevent your device's ad identifier being used for interest-based advertising by updating the settings on your device. Please note that if you opt out of interest based advertising, you won't be able to play our games. Ad identifiers, cookies and similar technologies To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences. Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to: - recognise you and your device; - provide interest-based advertising to you; - allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction); - allow us to understand how you interact with our websites (for example, where we use cookies such as the Google Analytics cookie on our Websites); - allow our payment processors to process your payment instructions; and - enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language. How do ad identifiers, cookies and similar technologies work? Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications. Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser. How to adjust your preferences for interest-based advertising You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings. Your rights You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below. Those rights include: - Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. - Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network. - Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller. - Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us. Children You must be over a certain age to play our games and use our Services. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age, please Contact Us. General Our Privacy Policy contains further details about: - who we share your information with and the reasons for sharing it; - measures we take to keep your information secure; - the legal bases under which we process your data; - how long we retain your information and where we store it; - when and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”); and - changes or updates to our Privacy Policy. Sharing In addition to the other disclosures described in this Privacy Policy, we will also share your information: - where we have your consent to do so (including as set out in this Privacy Policy); - as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you); - where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors); - where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it; We may also share your information with our service providers if necessary to enable them to provide services to us. Security We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online. Legal Bases In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following: - Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, chat functionality and third party social network connectivity; - Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimisation of our games and other Services; and - Consent. This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games; (ii) the storage of data on your device by us and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising above). You consent to this collection when you accept this Privacy Policy and you can withdraw your consent to this processing by following the steps at How to adjust your preferences for interest based advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services. Retention We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations. Changes to this Privacy Policy We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us. Contact us If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several way of contacting us: - via email to privacy@tentopfree.com; or For information collected under this Privacy Policy, the data controller is Best Games. Our Data Protection Officer can be contacted here: dataprotection@tentopfree.com.