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PRIVACY POLICY

EFFE Studios Private Ltd., hereinafter referred as “EFFE Studios”, “We”, “Us”. We thank you for using our products & services. Your privacy is most significant to us, and we deem it as our duty to care for it seriously; therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security.

 

We hope the policy outlined below will help you understand what data we may collect, how we use and safeguard that data and with whom we may share it. We are committed to respect the privacy of all visitors/users of our website, games, entertainment content, mobile applications and other online products and services (collectively, the “Services").

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PRIVACY & PERSONAL INFORMATION

 

If you have questions about privacy of your personal data, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us at privacy@effestudios.com along with the details of our product/ services that you are using.

 

If you wish to access, update, or delete your PII, please reach out to us at privacy@effestudios.com. You might be asked to verify your identity before we can act on your request in such cases. In some cases, we may have to keep that information for legitimate business or legal purposes.

 

If you have questions pertaining to In-app purchases, requesting a refund or reporting a problem and issues regarding to the same in android platform you are advised to contact us through email within 48 hrs. with the cause of action. Email: privacy@effestudios.com

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COLLECTION OF PERSONAL / NON-PERSONAL INFORMATION

We may collect following information through our products or services or otherwise

  • Data that you provide us

  • Contact information (such as name, email address etc. when you login)

  • Your messages using our service (such as chat logs etc.)

  • Information you have disclosed through support mails to us.

  • Data we or service providers and intermediaries for our Services collect automatically

  • Data about your account and game progress

  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address etc.)

  • Data about your device, such as device name and operating system, browser type and language

  • Data we collect with cookies and similar technologies (see more below)

  • Data about your use of the Service, such as gameplay data and your interactions with other players inside the Services

  • In some cases, we may also create a Unique ID and Encrypted ID for you when you use our Services.

  • Data we collect from our partners

  • Data we receive if you link a third-party tool with the Services (such as Facebook, Google etc.)

  • Data from platforms that you use to access our Services (such as to verify payment)

  • Data for advertising and analytics purposes, so we can provide you a better Services

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WHY WE COLLECT PERSONAL / NON-PERSONAL INFORMATION

  • To make the Service work

  • To perform the contract, we process data necessary to

  • Create accounts and allow you to play our games and use our Service

  • Verify and confirm payments

  • Provide and deliver the products and services you request

  • To make the Service more suitable for our players

  • To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

  • Develop and improve the Service and enhance player experience

  • Update and develop player profiles

  • Manage our relationship with you

  • Provide social features as part of the Service

  • Respond to your comments and questions and provide player support

  • Enable you to communicate with other players

  • To show personalized advertisements

  • To show you personalized advertisements in the Service as well as in other websites and services we have a legitimate interest to process necessary data to

  • Track the content you access in connection with the Service and your online behavior

  • Deliver, target and improve our advertising and the Service

  • For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.

  • To keep the Service safe and fair

  • Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the EFFE Studios Terms of Service.

  • In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

    • Analyze and monitor use of the Service and its social features

    • Moderate chats either automatically or manually

    • Take action against fraudulent or misbehaving players

    • To analyze, profile, and segment

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In all of the above cases and purposes, we may analyze, profile and segment all collected data.

  • With your consent

  • With your consent, we may process your data for explicit additional purposes.

  • With your consent, we may share your data with our partners or third party

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DISCLOSURE OF PERSONAL/NON-PERSONAL INFORMATION

Apart from EFFE Studios, your data can be accessed by others in the following situations:

 

Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

 

Partners working with EFFE Studios

EFFE Studios has partners to perform certain services. These partners process your data only at and according to EFFE Studios instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

 

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

 

Advertising and Social Media partners

The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

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GDPR CLASSIFICATIONS

Many types of data we process qualify for multiple legal bases for processing under the General Data Protection Regulation (GDPR). Below is the primary legal basis for each type of data that we process:

 

  • We have a legitimate interest in conducting analytics, measurement of usage and conversions, and game telemetric to improve our services. We and our processors have multiple measures in place to minimize the privacy impact.

  • We have a legitimate interest in storing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues.

  • We have a legitimate interest in enabling third party ads and data collection on our sites and apps to help provide a more customized ad experience for our users and site visitors. Our reputable partners provide opt outs and numerous other privacy measures to minimize the privacy impact of online ads.

  • We have a legitimate interest in periodic email and direct marketing, to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt outs for anyone not interested.

  • It is contractually necessary to process your username, email, password, cookie data, IP address, game network IDs, game information and similar information to fulfil our obligations in the terms of service to provide you with high quality games and a social game network from ourselves and our partners.

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INTERNATIONAL DATA TRANSFERS

Some of our Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.

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YOUR RIGHTS AND OPTIONS

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by writing to us on privacy@effestudios.com 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).

 

Access the personal data we hold about you

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, and the law permits us to charge a fee for exercising this right of access. 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 90 days of receipt of your request, evidence of ID and any applicable fee.

 

Right to correct personal information

We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at privacy@effestudios.com and we will correct it as soon as we can.

 

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 on privacy@effestudios.com

 

Please note that to ensure that we do not collect any further information, you should also 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.

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Account deactivation

If you have created an account with us, you can ask us to deactivate that account by contacting us using the information above. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, will be lost and we may not be able to restore them in the future.

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COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

 

HOW DO WE PROTECT YOUR DATA

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

 

Data retention

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.

 

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

LINKS TO OTHER WEBSITES

We may also provide you with general links to non-EFFE Studios websites. Your use of these links is subject to the third parties' privacy policies, and you should become familiar with the third-party sites' privacy policies before using the links. EFFE Studios is not responsible for the privacy practices or the content of those other websites.

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AGE LIMITS

We do not knowingly collect or solicit personal data from children, or show direct/ target interest-based advertising to children, or knowingly allow such persons to use our Services if their age do not legitimately allow them to use it as per laws of their country. EFFE Studios will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of "child" or "children" should take into account applicable laws as well as national and regional cultural customs.

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AUTO-RENEWABLE SUBSCRIPTIONS

EFFE Studios outlines an auto-renewable subscription as one that allows a user to purchase dynamic content for a set period of time. Once that set period of time ends, the subscription renews again for the same amount of time. This continues until the user cancels the subscription. These subscriptions services allow users to choose their plan and the frequency of renewal. After the user makes a choice of a subscription, EFFE Studios requests the user to approve it. When the subscription starts, it is recorded under the user’s ID. Respectively subscription displays the date of renewal and the term. After listed, cancellation is easy. All a user needs to do is open up the particular subscription under manage subscription and hit “cancel subscription”.

 

In case of any queries relating to the requesting a refund or reporting a problem relating to auto renewable subscriptions in Android platform, he is being strictly advised to contact EFFE Studios within 48 hours of the issue/query, delaying to which the user may be refunded with only in-game virtual items not the money/amount.

 

For further more details, explanation and clarity on the same the user is advised to refer https://support.google.com/googleplay/answer/2479637

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LEGAL USES

We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing TAX invoices where we are required to do so by law or where requested by you.

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GRIEVANCE REDRESSAL MECHANISM

Any complaints or request or concerns with regards to use, processing or disclosure of information provided by you or breach of these terms may be taken up with the designated grievance redressal officer as mentioned below via post or by sending an email to privacy@effestudios.com

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Grievance Redressal Officer:

Any complaints, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to.

 

Name: Mr. Khakhar

Email: privacy@effestudios.com

EFFE Studios Private Limited,

1226, Shivalik Satyamev, Nr. Vakil Saheb Bridge,

Ambli-Bopal Cross Road, Bopal,

Ahmedabad- 380058, Gujarat, India.

 

We request you to please provide the following information in your complaint:

  1. Identification of the information provided by you.

  2. Clear statement as to whether the information is personal information or sensitive personal information.

  3. Your address, telephone number or e-mail address.

  4. A statement that you have a good-faith belief that use of the information has been processed incorrectly or disclosed without authorization.

  5. A statement, that the information in the notice is accurate, and that you are authorized to act on behalf of the owner of the right that is allegedly infringed.

 

We may reach out to you to confirm or discuss certain details about your complaint and issues raised, EFFE Studios shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

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UPDATES TO THIS PRIVACY STATEMENT

We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our website (http://www.effestudios.com). Your continued use of our products means you accept the changes. Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms.

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