Mobile Apps Privacy Policy – EN


Mobile Apps Privacy Policy
June 2017

1. About this Privacy Policy

1.1. This privacy policy (“Privacy Policy”) explains how information about you is collected, used and disclosed by SPIL GAMES BV (“SPIL”) when you play one of our mobile games (the “Game”)

1.2. The Privacy Policy applies in addition to our terms of use and other policies. In the case of a contradiction between the terms of use and this Privacy Policy, this Privacy Policy will prevail.

2. About us

2.1. SPIL GAMES BV is registered with the Chamber of Commerce under number 32106054 and is the controller as referred to in the Dutch Personal Data Protection Act (Wet Bescherming Persoonsgegevens). SPIL is having its registered office at Mussenstraat 15, 1223 RB, Hilversum, The Netherlands.

3. What kind of information do we collect?

3.1. When you play the Game, we collect the following information:

• Your device identifier and IP address;

• Demographic information (such as country);

• Information collected through various technologies;

• When you choose to register with us for a better game experience and/or to create a profile, we collect information such as username, email address, and any information you may choose to provide;

• Other information that we receive from you, e.g. your e-mails, chats or other communications and information exchanged with us on our social media channels for the Game;

• How you play the Game (frequency, device, platform, level etc.);

• Information you post on the Community of the Game.

With this list, we try to be as clear and complete as possible, but we find it important to keep this Privacy Policy legible, so there may be other information we collect.

4. How do we use your information?

4.1. When you playthe Game, we use the information that we have about you:

• To provide you the Game and associated websites and continuously improve their features;

• To store your gaming-history;

• To provide helpdesk and support services;

• To analyze the functioning of the Game and associated websites;

• To enable in app purchases;

• To present interest based advertisements and to send you promotional messages by email or other communications;

• To enable social network integration, especially with Facebook;

• To prevent fraud and crime;

• To meet legal and tax obligations.

4.2. Your email address will be used for the following purposes:

• service emails (regarding updates, new design, new features, (new) games etc.);

• administrative purposes, such as notification of a violation of our terms of use;

delivering messages you have allowed us to forward (e.g. from other users in your social network).

4.3. Your personal data will be stored by SPIL in the EU. Your personal data will be stored for a period necessary for your use of the Game for the purposes as described in this Privacy Policy.

5. Third parties

5.1. Ad network providers

SPIL may use ad network providers who assist us to serve advertisements to you about our products and services. These ad network providers may also show interest based advertisements for other parties’ products and services within the Game or on the associated websites and social media platforms based on the information that we have about you.

5.2. PSP

SPIL may also use third party payment service providers (“PSP”), who provide payment transaction services to SPIL to sell products or services throughthe Game. When you purchase products or services, the information you provide to the PSP is subject to their privacy policies, not ours. You explicitly consent that SPIL may provide personal information collected from you to a PSP for the purpose of offering the payment transaction service and that the PSP may use such data for (statistical) analysis of payment transactions. SPIL shall be allowed to notify a PSP regarding a user who engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person’s rights, or that resulted in such user’s suspension or termination of use of [Name Game].

5.3. Social networks

The Game can be played and synchronised on multiple devices by using your Facebook account to log in. Facebook may provide certain information about you to us and we may use this information in order to show you advertisements. Facebook is a third party, so your activities on this social media platform is subject to their user and privacy policies, not ours.

5.4. Partner networks

SPIL may use partner network providers who assist us to distribute the Game in order to enable as many gamers as possible to play the Game.

5.5. Developers

After the Game has been launched it will continuously be monitored and improved to maintain and effectuate the best gaming experience for our gamers. Developers may therefore see and have access to your information, but they will only use this information for game optimization purposes.

5.6. Other

We may supply information to other parties if we are required to do so by law or by a ruling from a court of law.

6. Your rights

6.1. If and to the extent applicable data protection regulation provides so, you have the right to access, rectify and erase the personal data we hold about you and to restrict or object to our processing of your personal data.

6.2. If you have a personal profile and you wish to exercise these rights, you can mostly do so by clicking on the appropriate link in your personal profile. Furthermore, you can send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, The Netherlands, detailing your request, along with a copy of your passport (to prevent misuse of requests for information), or send an email containing this information to: After the verification of your identity, the copy of your passport will be shredded.

6.3. You can at any time opt-out of marketing communication messages you receive from us by clicking the opt-out link in these messages.

6.4. Parents of users under the age of 16: If you wish to exercise the rights referred in 6.1 with regard to your child, please send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB Hilversum, The Netherlands, detailing your request along with a copy of your passport (to prevent misuse of requests for information), or send an email containing this information to: After verification, the copy of your passport will be shredded.

7. Security

7.1. SPIL has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security and to correctly use the information we collect in relation to the Game.

7.2. You post personal data and any other content at your own risk and in accordance with our terms of use. Although we allow you to set privacy options that limit access to such personal data and other content, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you choose to share your profile and information. Therefore, we cannot and do not guarantee that any content you post will not be viewed by unauthorized persons. We are not responsible for the circumvention of any privacy settings or security measures contained in the Game or on the associated websites. You understand and acknowledge that, even after removal, copies of personal data or content may remain visible in cached and archived pages, and that other users may have copied or stored your personal data or content.

8. Miscellaneous

8.1. We reserve the right to amend our Privacy Policy. Amendments will be effective from the moment of publication, so please check regularly to be sure you are familiar with the latest version.

8.2. The Internet is a global environment and using the Internet necessarily involves the collection and processing of personal data on an international basis. Therefore, by usingthe Game, you acknowledge and agree to our processing your personal data in this way.

8.3. Our websites or other platforms may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware of this when they leave our site, and to read the privacy statements of any other websites that collect personal data. This Privacy Policy applies solely to information collected by us.

8.4. This Privacy Policy shall be governed by the laws of The Netherlands and submitted to the exclusive jurisdiction of the courts in The Netherlands.