Effective Date: August 1, 2018

Supercent Games Private Limited develops and publishes social games for web and mobile devices. “Supercent,” “Supercent Games,”  “we,” “our,” or “us” in this Privacy Policy refers to Supercent Games Private Limited.

Your privacy is important to us, and we take our responsibility of caring for it seriously.  We respect your privacy rights and are committed to protecting the personal information that is collected about you.  This Privacy Policy describes:

  • The ways we collect personal data about you and why we do so
  • How we use your personal data, and
  • The choices you have about your personal data.

If you do not want Supercent Games to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to play our games or use our services.

This Privacy Policy applies whenever you use our “Service,” which means our games, products, services, content, Supercentgames.com, and/or other domains or websites operated by Supercent.All of our Services, whether used on mobile devices, PCs or other platforms, are governed by this Privacy Policy.

We may periodically update this Privacy Policy and Our Privacy Policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically.

 

CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the email address provided on our website and/ or Mobile Application so we can reply to you more quickly.

f 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 multiple ways of contacting us:

  • Through our website at http://www.supercentgames.com/Contact-Us/
  • Sending an email to support@supercentgames (dot) com;
  • The data controller of the data collected in respect to this Privacy Policy is Supercent Games Private Limited. Our Data Protection Officer can be contacted here: supercent@supercentgames (dot) com

 

DEFINITIONS

Unless otherwise provided in this Privacy Policy, the terms capitalized in the Privacy Policy shall have the meaning as provided hereunder:

  • “Device” shall mean computer, mobile or other device used to access the Services.
  • “Device Identifier” shall mean IP address or other unique identifier for the Device.
  • “Protected Information” shall mean such categories of information that could reasonably be used to identify you personally, including your name, e-mail address, and mobile number.
  • “Promotion” shall mean any contest and other promotions offered by us.

THE DATA WE COLLECT

  • Data that You Share With Us Directly
  • Player name and password (can include your first and last name)
  • Profile information (such as Your profile picture or its URL)
  • Contact information (such as email address and name)
  • Your chat messages or other messages to the Service (such as chat logs and support tickets)
  • Other data or information you choose to provide us (such as data that helps us make sure it’s you accessing your account or helps us improve our services. This also includes data shared with the support team to identify a lost account)
  • Data we collect automatically directly from you when you use our Service.
  • Data about your game account and game progress
  • Your IP address
  • Data about your device, such as device name, device’s operating system, language and other such information which can help us in enhancing your play experience.
  • Your mobile device identifiers (such as your device ID, IMEI, MAC address, advertising ID, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID) )
  • Data we collect with cookies and similar technologies (see more below)
  • General geo-location information or data
  • Precise geo-location information or data (GPS, with your consent)
  • Data about your use of the Service, such as gameplay data, your game progress, game activity and your interactions with other players inside the Service
  • game state and the date and time of activity on our Services.
  • We also create a Supercent-specific ID for you when you use the Service.
  • Data we obtain from our partners.
  • Data we receive if you decide to connect to a third-party social network (such as Facebook, or Google or Game Center)
  • Data for advertising and analytics purposes, so we can provide you with better Services
  • Demographic data (such as to determine the coarse location of your IP address)
  • Data to fight fraud (such as click fraud in advertising or refund abuse in our games)
  • Data from billing partners or data from platforms that the games run on (such as to verify payment or make an in-game purchase)
  • Transaction identifiers for purchases (such as In-App-purchases (IAP))

 

WHY DO WE COLLECT YOUR DATA

We acquire, use, hold and Process Personal Information about players or Individuals for a variety of business purposes, including:

  • To Provide Products or Services Requested.
  • To operate our business and to enhance your gaming experience,
  • To create your game accounts and allow you to play our games
  • To provide you with game-related Services that are suitable to your age and are also compliant with the applicable laws of your country of residence.
  • To operate, and optimize our Service
  • To identify and fix bugs and service related errors
  • To communicate game or Service-related information such as in-game updates, enhancements, new games, new features, special and promotional offers, upgrade opportunities, contests, and events of interest.
  • To keep you informed of your game activity, including comments or messages from friends, notifications about in-game status as well as notifications of gifts and other freebies.
  • To protect against crime, cheating, or fraud, or for other security reasons
  • To Verify and confirm payment requests
  • To provide gaming experiences that you may like and functionalities or service you have subscribed to
  • To personalize the player experience and make the Service more suitable or worthy of our players.
  • To make this Service worth for players, we have a legitimate interest to collect and process necessary data to
  • To Improve, optimize and customize our player’s game experience
  • To Provide player support and respond to your queries
  • To Manage our relationship with players in a better way.
  • To Create, update and develop player profiles
  • To Provide social features and optimize such features as part of the Service
  • To Provide our players features which they can use to communicate with other players
  • To Send players service related information, such as  security alerts and support messages
  • To Provide players with various offers in the game as well as on other websites and services, and by email

To display personalized advertisements.

We use advertising to enable us to offer some of our games, game related features, and other Services for free. These advertisements may include, without limitation, banner ads,  or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as completing a survey, or finishing a particular game level. These offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Supercent.

We do not actively share personal information that directly identifies you with these third-party advertisers for their marketing purposes unless you give us your consent.

To enable ad networks, advertisers, and offer wall providers to show you personalized advertisements, they may collect, or we may collect and share with them, the following types of information when you use our Service:

  • some technical information (like non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID,  IP address);
  • certain performance related data (like the number of clicks on a particular advertisement);
  • a unique identifier, such as Supercent-specific ID or your social network ID; and/or
  • other contextual data about your game progress, game activity and game play(like your game level and session duration).

The information collected may be used to:

  • analyze traffic and other player activity to optimize  and improve your experience.
  • offer you interest-based advertising or behavioral advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you; and/or
  • measure effectiveness of ads;
  • Ad networks or third-party advertisers may collect these information through the use of cookies and other similar tracking technologies, and they may use multiple tracking technologies at the same time or they may use a single tracking technology.

Please note, after clicking on a third-party offer or advertisement, you may no longer be on an app controlled by Supercent or the social network through which you are playing our games. The practices of third-party companies or ad networks delivering advertisements in our game and on our Services are subject to those companies’ own privacy policies.

To provide safe and fair Service.

In order to keep the game or and game’s social features safe and fair and to fight fraud, we have a legitimate interest to process necessary data to

  • prevent fraud or potentially illegal activities, and to enforce our Terms of Service (http://www.supercentgames.com/Terms-Of-Services/)
  • Moderate in-game chats either manually or automatically
  • Take action against fraudulent or misbehaving players
  • Analyze and monitor use of the Service and the social features it offers
  • to protect the safety and well-being of our players
  • to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties
  • To analyze, profile, and segment.

In all of the above mentioned cases and purposes, we may analyze, profile and segment all collected data. When we use third parties to assist us in processing your personal information or credit card information, we take reasonable steps to require that they comply with this Privacy Policy and otherwise protect your personal information (including any credit card information).

With your consent.

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

How We Share Information

We may share your information, including personal information, with third parties or allow third parties to collect this information from our Services in the following circumstances:

OTHER PLAYERS AND USERS USING OUR SERVICE.

Social features are important part 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 And Third Party Service Providers  WORKING FOR SUPERCENT.

Supercent may employ third party companies and individuals to facilitate its Services, to provide the Services on its behalf, to perform tasks (e.g., without limitation, database management, maintenance services, web analytics and improvement of the Services) or to assist Supercent in analyzing how its Services are used. These third party companies and individuals process your data only at and according to Supercent´s instructions to provide the Service, such as advertising, player support, hosting, analytics and fraud prevention. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Supercent's behalf.

 

Required by Law and Similar Disclosures

We may access, preserve, and disclose your Personal Information, and other account information and content, if we believe doing so is required or appropriate to:

  • comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
  • protect the rights, property or safety of us, our players or others;
  • to collect amounts owed to Supercent;
  • to enforce Supercent policies or contracts;
  • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or
  • if we, in good faith, believe that disclosure is otherwise necessary or advisable.

 

Third-Party Marketing, Social Media and Advertising Partners

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

We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, Amazon, etc.). Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).

INTERNATIONAL DATA TRANSFERS

As part of our international operations, we may transfer personal information to our “Affiliated Entities,” which are any other corporate entities under common ownership with Supercent Private Limited, or to our business partners and service providers from time to time for our legitimate business purposes. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details, or (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully, and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

Participating European countries’ residents should direct any questions, concerns or complaints regarding Supercent’s handling of personal information by sending an email to  support@supercentgames (dot) com;

We will attempt to answer your questions and satisfy your concerns in a timely and complete manner.  If, after discussing the matter with us, your question or complaint is not resolved, you have the right to complain to a data protection authority. For more information, please contact your local data protection authority.

Your Rights and How to Access, Update, and Manage Your Personal Information

If you would like Supercent to review, delete, change or not use your information in our system, or have additional questions, please contact Supercent via e-mail to support@supercentgames (dot) com and we will attempt to accommodate your request if we are not legally obligated to retain such information. We will make good faith efforts to make requested changes in our then-active databases as soon as practicable (but may retain prior information for records to the extent not prohibited by applicable law). Kindly include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes.

European Countries’ Users’ Rights

We will refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in this Privacy Policy. If you are located in the European Countries then you have the following data protection rights:

You can access or request deletion of your personal information by sending an email to support@supercentgames (dot) com;

You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You can opt-out of marketing communications we send you by following the instructions in “Opt-out of marketing emails and other direct marketing or promotional communications” below.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. To exercise your rights to access or deletion, please submit a request by sending an email to support@supercentgames (dot) com.  We respond to all data protection requests we receive in accordance with applicable data protection laws.

Opt-out of marketing emails and other direct marketing or promotional communications.

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. If you want to stop receiving promotional e-mails from Supercent, click on the “unsubscribe” link at the bottom of any promotional email from Supercent. Your unsubscribe request or e-mail preferences change will be processed promptly, and in no event longer than 30 business days. During that processing period, you may receive additional promotional emails from us.

If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our games also offer the ability to turn off push notifications in the in-game “settings” page.

You can opt out of receiving SMS text messages by texting back STOP to the number we send the text from for that particular SMS text messaging program or by sending an email to support@supercentgames (dot) com. When we receive an opt-out message from you for SMS text messages, we may send a text message confirming receipt.

Please note that if you opt out of receiving promotional communications from us, we may still communicate with you from time to time if we need to provide you with information about the Services you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service.

Opt-out of targeted advertising.

If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS). Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for behavioral advertising.

All of the opt-out tools described in this subsection are provided by third parties, not by Supercent. Supercent does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive third-party advertisements in Supercent’s Services after using these opt-out tools, but the advertising you see may be less relevant to your interests.

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.

Access the personal data we hold about you.

If you request, we will provide you a copy of your personal data in an electronic format.

To review and update personal information associated with your Supercent player profile in certain games, visit the “settings” or “profile” page in that game. If you want to review or delete personal information associated with your game account data, please submit a request by sending an email to support@supercentgames (dot) com

Your other rights.

You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

We will respond to all requests within a reasonable timeframe.  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us by sending an email to support@supercentgames (dot) com. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

You can exercise your rights at any time and ask Supercent for access to, or rectification or erasure of, your information. According to your local regulations, if you are a European user, you can also request limitations to the processing of your personal information, object to the processing of your information, or exercise your right to data portability.

Please note that game functionality, Services and features can be affected by your actions. Some of your information and its processing is mandatory for Supercent to provide the Services.

Your actions can oblige Supercent to stop providing the Services. When the conditions below apply, your game might get reset:

If you ask for the modification of this mandatory information, we may not be able to continue to link the game or game Services to you.

If you request limitations to processing that are mandatory for Supercent, or you object to such processing (in which case, we may not be able to provide you with the game or game Services).

If you withdraw your consent or ask for the deletion of your information.

If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.

If you are a parent of a child who is under 13 years of age (or under another age specified by applicable regulations) and believe your child has provided us with information, please contact us by sending an email to support@supercentgames (dot) com and we will delete the information from our system.

To preserve the confidentiality of your information, we must be sure to correctly identify you. For this reason, please provide us with a copy of an official document that can prove your identity. This copy will be safely destroyed within two months of your request being received and closed.

Our team will look into your request and will answer you within one month, unless your request requires further investigation. You’ll be specifically informed if that is the case.

We remind European users that they have a right to lodge a complaint with a European Data Protection Supervisor.

Note: European users can also manage personal information associated with their Supercent player profile in certain games, by visiting the “settings” or “profile” page in that game. If due to some unforeseen circumstances, you are not able to see these options then European users can also contact us by sending an email to support@supercentgames (dot) com.

Ad identifiers, 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.

California Online Privacy Protection Act Notice

At this time, there is no general agreement on how companies like Supercent should interpret Do Not Track signals. Supercent does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

HOW DO WE PROTECT YOUR DATA

Security Safeguards.

We have implemented security measures to safeguard and help prevent unauthorised access, maintain data security, and correctly use the personal information collected through the Services.

We take, and force applicable third parties to take, reasonable precautions to protect your personal information against loss, misuse, unauthorised disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorised use of, or access to, your information that is under our control. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us by sending an email to support@supercentgames (dot) com.

Data retention.

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. In most cases, 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. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed.

We will take reasonable measures to delete your personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information. Once your account is deleted or terminated, after a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely to prevent players from tricking the Service and prevent them from taking any undue advantage which affects the commercial success of our Service.  Pseudonymization or Anonymization on the data will be done to prevent fraud or potentially illegal activities, and to enforce our Terms of Service (http://www.supercentgames.com/Terms-Of-Services/)

 

CHILDREN’S PRIVACY

Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.

We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission.

We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age.

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services.  If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data.  If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us by sending an email to support@supercentgames (dot) com.