Effective Date: December 29, 2021
We hope that you will continue using our Application, but if you do not agree to our updated terms, you can delete your account at any time.
1. Information That We Collect
Collection of device and technical information
We might collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app and to personalize the content of the app.
We automatically obtain certain information about your computing device, including IP address; Country code; Time zone; session start/stop time; IDFVs, Language; Network status (WiFi, etc.), browser plug-in types and versions; platform, SDK version, timestamp; Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software API key identifier for application, Push notifications token. Although some of this information (such as IDFA, IDFV, IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US) may treat information that uniquely identifies your device as personal information.
Collection of classical personal information
We may also collect personally identifiable information about you (such as your name and surname, email address), as well as non-personally identifiable information (such as age range and gender) that you provide us by using our Applications or contact us directly via email.
We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.
If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail and your e-mail will be deleted from our database.
When you use our Services, you may register an account with us to track your progress and to sync your activity across devices. To register an account, you may be asked to provide certain personal information to us, including your name, email address, and password. You are solely responsible for ensuring your account information is correct and up-to-date.
Information from Social Media Platforms
You may also choose to create an account with us using your Facebook or Google account credentials. When you log in using your Facebook or Google account, you authorize Facebook or Google to provide us with your personal information such as your name, profile picture, email address, language preference, and other information as listed in the authorization.
Information You Provide to Us
We collect personal information you provide to us when you use our Services. For example, you may provide additional account information, such as your language preferences. You may also provide information when participating in surveys, sweepstakes, contests, or events, such as your contact information. You are solely responsible for ensuring the information you provide to us is correct and up-to-date.
When you use our features, we may collect information such as your painting history on the app, paint artifacts, completed works, and purchase history.
While accessing or using the Services, we may automatically collect information about how you interact with the services. Such information may include your Internet Protocol (“IP”) address, device identifier, advertising identifier, MAC address, operating system, browser type, language preferences, referring and exiting pages, crash data, location data, purchasing activity, and other data regarding your activities on the Services. For more information, see the section on Cookies and Similar Technologies (“Tracking Technologies”).
We collect the personal information you provide to us when you contact us for customer service, to provide feedback, or to request information.
2. Purposes of Collecting, Processing and/or Disclosing
• Detecting/Protecting against security events
• Internal analytics and reporting
• Customer service
• Operate our business and games
• Game mechanics or functionality
• Facilitate players’ social interactions
• Product development/improvement
• Maintaining and enhancing service
• Auditing consumer interaction & transactions
• Direct marketing
• Player acquisition
3. How We Use Your Information
We shall use your personal information for the following purposes:
To Provide Our Services
We use your personal information to provide you with our mobile application and any other Services you request. This may include processing transactions, providing you with the requested features, syncing your painting history across your devices logged into your account, customer service, etc.
To Personalize Your Experience
We may process your information to personalize the Services for you. For example, we use your language preferences and country location to display the correct language and time zone in the Services. We also use certain information about your device (such as operating system version and screen resolution information) to optimize the display of pictures on your screen.
We will use your information (such as contact information) to send you communications about your account, requested transactions, and changes in our policies. Please note that you may not opt out of such communications, which are necessary to keep you informed about important updates about your account and the Services.
To Conduct Analytics and Other Internal Purposes
We may use your personal information to conduct analytics. This can be used for quality control, internal auditing, and to measure how our mobile application and ad campaigns are performing.
To Ensure Security of our Services
While we are offering services, it is used for the purposes of identity verification, customer service, security protection, fraud monitoring, archiving and backups, ensuring the security of the products and services that we provide to you.
To Conduct Research and Development
We may process your personal information to improve our existing Services and help us design new ones. When we do so, we may implement security measures and safeguards to protect the privacy of your personal information. For example, we may institute technical safeguards or administrative safeguards, such as restricting access to personal information to only those who need access to conduct the research and development functions.
To Promote Our Services
We use your personal information for our marketing activities. For example, we may conduct targeted marketing and send you information about our and our partners’ products, events, and market studies that may be of interest to you.
To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, and to manage risk as required under applicable law.
4. Sharing of Your Information
We may share your personal information in the following circumstances.
We are multinational organization, with cross-border legal entities and management structures. We may share your personal information within our corporate organization to facilitate the Services; however, we will require that your personal information still be handled in the manner describe herein.
Third-Party Service Providers
We may use third parties to perform certain functions on our behalf to provide you with the Services such as:
to process payments and complete transactions you request, such as payments for our subscription service, which is processed by Apple (App Store) or Google (Google Play Store);
to process and store data, including your personal information;
to provide security for our Services; and
to conduct market research.
We have agreements with third-party service providers in place to ensure they use adequate safeguards when processing your personal information.
Merger, Acquisition, or Other Business Transaction
Legal Obligations and Safety
We may disclose your personal information if it is reasonably necessary to:
Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
Comply with valid requests or investigations by public authorities;
Comply with applicable laws or regulations;
Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise;
Protect our legitimate interests, including legal interests;
Protect the security or integrity of the Services; or
Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.
We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.
With Your Consent
We may transfer your personal information for other reasons after obtaining your consent.
5. How to Exercise Your Rights
You may access, amend and delete information provided by you when using our Applications, or contact us at email@example.com. The scope and the way in which you access, amend or delete your personal information depend on the service you use.
You may opt-out of receiving promotional communications, such as marketing emails we send you, at any time. If you wish to do so, please e-mail us at firstname.lastname@example.org. You can turn off push notifications by visiting the “options” or “settings” page within the relevant games.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For personalized in-game offers opt-out, you can use the options provided in the game settings.
If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, please contact us using the information in the “Contact Us” section below. We will respond to your request as promptly as possible.
In some cases, we may not be able to delete your personal information and will retain and use our information as long as necessary to comply with our legal obligations, resolve disputes, and/or
enforce our agreements.
What are cookies and tracking technologies?
What types of tracking technologies do we use?
We use the types of tracking technologies described below on our Services:
Types of Tracking Technologies and Its Description
Some of the tracking technologies we use are necessary to provide our Services to you. For example, they help you: navigate from page to page; stay logged into your account; and support and enable security features. Without such tracking technologies, some of our Services cannot be provided to you.
Functional tracking technologies collect information about how you use our Services, provide you with certain functions on our Services, and remember your preferences.
Analytics, Performance and Research
These tracking technologies help us understand how well our Services are doing. They collect information about your use and interaction with our Services so that we can continue to improve and expand our Services.
Marketing tracking technologies allow us to collect information about your interactions with our marketing activities, such as parts of our website and our emails. They help us measure performance of our Services and advertising campaigns.
How to manage tracking technologies
We use third-party tracking technologies that allow us to automatically collect information through our Services that can recognize your device both when it visits our Services and when it visits other websites or mobile apps. We encourage you to check the websites of any third-party tracking technologies providers for more information about how they use the information they collect.
Below we describe how you can manage tracking technologies on our Services:
Through Your Browser/Mobile Settings
You can enable, disable or delete tracking technologies via your browser settings. To do this, follow the instructions provided by your browser, usually located within the “Help”, “Tools” or “Edit” settings of your browser or mobile device. Please be aware that if you set disable tracking technologies on your browser, you may not be able to access secure areas of the Services and parts of the Services may also not work properly (e.g., preferences, referral links).
Many browser manufacturers provide helpful information about cookie management, including, but not limited to:
Safari (Desktop) or Safari (Mobile)
If you use a different browser than those listed above, please refer to your specific browser’s documentation or check out http://www.allaboutcookies.org/browsers/index.html to learn more about different browsers. You can also find out more information about how to change your browser cookie settings at www.allaboutcookies.org.
You may be able to control or limit mobile tracking technologies in your mobile device settings. Please follow the instructions provided by your mobile device, usually located in “Settings” of your mobile device. Many mobile device manufacturers provide helpful information about how to do this:
Through Third Parties
You may also check the third party’s website below for information about how they use tracking technologies to collect and use your information, and how you may be able to opt out of tracking.
Google Firebase Analytics: To conduct usage and advertising analytics
Facebook Analytics: To conduct usage and advertising analytics
Appsflyer: To conduct usage and advertising analytics
Google (Ad Words)
We are included with third party advertising for their products and services. We and our partners use your information to improve advertising and targeting to measure the relevant third-party ads to show in our games. Information we may have about you such as: ad identifiers and other non-personal information collected from your device, how you interact with our game and Services the game play information, your age, country or region, and gender, and other information collected from third parties with legal right to share it with us are used to make sure that you only see ads from us that might be of interest to you.
Non-personal identifiers and other information collected from your device when you play our games or use our Services are shared with advertising partners in order to technically deliver the ads to your device. Such information may be combined with collected information of our advertising partners own to serve you with more relevant ads and to enhance the accuracy of their targeting. For more information we recommend for you to scan through our partners’ privacy policies on their websites.
We use ad identifiers that are non-permanent, non-personal identifiers such as the Android and/or Apple’s ID for advertising associated with your device, and similar technologies such as tracking pixels within ads to provide interest-based advertising. These technologies enable us and our third-party advertising partners to recognize you and your device, allow our Services to interact with a third-party social network or platform and help our payment processors to work it out your payment instructions.
How to reset your preferences for advertising
You may reset your ad identifier being used for interest-based advertising by changing the settings of your device usually found under “privacy” or “ads”. You can also opt-out from your information being collected if you live in the USA, Europe or Canada by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). The full use of our Services may not available if you choose to adjust your preferences.
8. Social Sharing Features
We may offer social sharing features and other integrated tools enabling share actions you take in the apps with other media. You must be over the minimum age limit prescribed by the legislation in the individual jurisdictions to use such social sharing features which may, depending on the settings you set with the entity, share information with your friends or the public.
Our Services has social features from the following providers, for more information about the processing driven by the third parties regarding social sharing features, please visit the privacy policies of the entities found here:
• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/privacy/en-ww/
• Google Play Games: https://www.google.com/policies/privacy/
We take the security of personal information seriously. We adopt standard practices in the internet industry to protect your personal information from unauthorized access, disclosure, use, alteration, and corruption or loss. We shall take all reasonable and feasible measures to protect your personal information. We shall do everything possible to take appropriate technical measures to ensure the accuracy and timely update of the personal information collected about you.
Please understand that due to the nature of the internet industry, it is impossible to ensure that systems are 100% secure. You should understand that the systems may encounter issues due to the factors beyond our control, such as malicious actors. Although the security of your personal information is our highest priority, there will always be a risk that your Personal Information gets compromised. We also depend on you to keep your account information and other personal information secure by keeping your password confidential and taking precautions to keep others from accessing your account.
In general, we keep your information for as long as necessary to achieve the purposes stated in this Policy or to comply with the applicable law.
We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.
We will retain information associated with your account as long as your account remains active or as necessary to provide you with the requested services.
Information collected from tracking technologies:
We generally retain such information for as long as necessary for usage analytics, the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.
Any contact information you provide to us for marketing purposes, such as your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. If you unsubscribe, we will add your contact information to our do-not-contact list to respect your unsubscribe request.
11. Children (COPPA)
Our Services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. If you are under the age of sixteen (16), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of sixteen (16), please contact us immediately.
To use and play our Services you must be over a certain age depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect personal information from or direct or target interest-based advertising to anyone under the ages set out below. We also do not knowingly allow such persons to use our Services, if in any way such personal data have been processed under the age set out below, please contact us so we can delete that information as quickly as possible.
Please see below listed with age you must be to play and use our games and Services depending on which country you are in while using our games and Services. Please do not play our games or use our Services if you are under the relevant age.
12. Do Not Track
Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit “Do Not Track” (“DNT”) signals. Since uniform standards for DNT signals have not been adopted, we currently do not process or respond to DNT signals on our Services.
13. Special Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland (GDPR)
This section only applies to individuals located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland (collectively, the “Designated Countries”) at the time their personal information was collected.
We may ask you to identify which country you are in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.
14. California Privacy Rights (CCPA)
If you live in California, you can ask us for a list of third parties we share your Personal Information with for marketing purposes.
California law permits California residents to ask us for a notice that identifies the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us with your name, account information, and proof of California residence with the subject line “My California Privacy Rights” by email.
General Data Protection Law (GDPL)
The General Data Protection Law (GDPL), also referred to as LGPD in Portuguese (Lei Geral de Proteção de Dados Pessoais) is a Federal Law in Brazil that comprehensively regulates data protection.
We enable compliance with the GDPL mechanisms and data protection measures when we process personal data. If you have any questions regarding GDPL compliance please contact us by email.
We will notify you (for example, by email or through our Application) at least 30 days before we make changes to these terms and give you an opportunity to review them before they go into effect, unless changes are required by law. Once any updated terms are in effect, you will be bound by them if you continue to use our Application.
We hope that you will continue using our Application, but if you do not agree to our updated terms, you can delete your account at any time.
17. Contact Us