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Privacy Policy


Privacy policy is document that explains how your personal data is collected and processed by Small Basement Games when you use Small Basement Games' apps and games.


Small Basement Games is developer and publisher of apps and games, and in further text may be referred to herein as “we”, “us” or “our”, as the context requires.


It is important that you read this document carefully, before you start using our apps and games, to find out what personal information we collect and for what purpose, how we store data and what we do to ensure that your information is safe.

After reading, you will understand that personal data we collect is adequate, relevant and limited to what is necessary for the proper functioning of the certain app or game, so you will be able to decide whether you will give or not your consent to the processing of data relating to you.


We hope that the text of our privacy policy is clear and transparent, but if there are additional questions and concerns, you can contact us on our e-mail address found below in section Contact and complaints.


About this privacy policy


This privacy policy will make you understand what personal data we collect from you, how we process this data and why and how we store and protect them. You can read more about these topics in the next section so as in sections below.


Our privacy policy applies to all of our apps and games, whether played on our website, on mobile devices or PCs. 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 apps and games, websites, marketing and advertising activities and other services collectively as our "Services".

Changes to the privacy policy


If we decide to change our privacy policy we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent. We recommend you to take a little time and review the privacy policy whenever you access our apps and games to stay informed about how we process your personal data and how you can protect your privacy.


Data we collect and process


We collect information from you just for purpose of proper functioning of the app or game and sometimes we might collect some personal data. Here is the list of information we collect:


Information we collect automatically through our apps and games


When you access or use our apps and games, we automatically collect general information about you, including:

• Age - minor or not.
• Log information - we log information about your use of our app or game, including the type of device you use, the features you use.
• Device information - we collect information about the device you use to access our app and game, including information about the device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push-messages, mobile network information and time zone.
• Usage information - we collect information relating to your use of our app or game, including your game progress, scores, achievements and interactions with other players.
• Consumption information - we collect information about your consumption habits relating to your use of our apps and games, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

Information we collect from you on request

Some of our apps and games must access your personal data for the sake of proper functioning of app or game. If you are using a certain app or game, we might ask from you following data:

• Nickname – used in the app or game

• E-mail address – your e-mail address.


Information we collect from other sources


If you log into our app or game using a third party site or platform such as Facebook and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.
If you log into our app or game using a third party site or platform, you represent and warrant that:

- your access and use of such features in connection with app or game will comply with the applicable terms and policies of such site or platform, and

- that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.


Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).


The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).


Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.


How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.


For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.


How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.


We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.


No sale of your personal information

In the past 12 months we have not sold any of your personal information.


What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.


We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.


We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.


Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;

in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:

for sales, the personal information categories purchased by each category of recipient; and

for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.


The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.


How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;

describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.


How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.


Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).


The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;

compliance with a legal or regulatory obligation that lies with us;

the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

studies conducted by research entities, preferably carried out on anonymized personal information;

the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;

the exercising of our rights in judicial, administrative or arbitration procedures;

protection or physical safety of yourself or a third party;

the protection of health – in procedures carried out by health entities or professionals;

our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and

credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.


Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.


Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.


Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;

access to your personal information;

have incomplete, inaccurate or outdated personal information rectified;

obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;

obtain information on the possibility to provide or deny your consent and the consequences thereof;

obtain information about the third parties with whom we share your personal information;

obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;

obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

revoke your consent at any time;

lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;

oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;

request clear and adequate information regarding the criteria and procedures used for an automated decision; and

request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.


How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.


How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.


You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.


In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.


In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.



Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;

when the transfer is necessary to protect your life or physical security or those of a third party;

when the transfer is authorized by the ANPD;

when the transfer results from a commitment undertaken in an international cooperation agreement;

when the transfer is necessary for the execution of a public policy or legal attribution of public service;

when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Purpose of processing data


We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

Age is being processed:


a. to identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data.
Our processing for the above purpose is necessary for compliance purposes, see Article 6(1)(c) of the GDPR.

Log-, device-, usage-, and consumption information are being processed:


b. to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
c. to provide and maintain app or game and the app/game experience;
d. to personalize and improve app or game and provide tailored content and features;
e. to monitor and analyze trends, usage and activities in connection with app or game; and
f. to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in app or game.

Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR.
g. to provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of information) for the purpose of serving them with personalized advertisement in app or game (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).

Nickname is being processed:


h. to identify you among other users on leaderboards, ratings and scores.

Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.


E-mail address is being processed:


i. to identify your account in purpose of syncronzation of your data between different devices.

Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.


Information from other sources are being processed:


j. to provide and deliver the products and services you request and send you related information.
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
k. to link or combine information we get from others to help understand your needs and provide you with better service.
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR.

We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Push notifications


We send push notifications or alerts to your mobile device to provide app or game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.


Storage of information


We will store your personal data for as long as necessary in order to provide you with the app or game otherwise fulfill the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with app or game has ceased.


Sharing of information


We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
• Social networks, see more under "Social Sharing features";
• Third parties if we are required to disclose your personal data by applicable law,
rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of company or others;
• Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third party service, such as Facebook or Apple Game Center;
• Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID).


Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:


• Ad Mob -https://policies.google.com/privacy?hl=en
• Unity Ads - https://unity3d.com/legal/privacy-policy
• Facebook Ads - https://www.facebook.com/about/privacy/
• Adcolony - https://www.adcolony.com/privacy-policy/
• Chartboost - https://answers.chartboost.com/hc/en-us/articles/200780269
• AppLovin - https://www.applovin.com/privacy/
• IronSource - https://www.ironsrc.com/privacy-policy/

The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.

Social sharing features


Our apps and games offer social sharing features and other integrated tools, which let you share actions you take in our app or game with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in app or game. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.
Games and apps has social features from the following providers:
• Facebook
• Google

For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features, which can be found here:
• Facebook: https://www.facebook.com/about/privacy/
• Google: https://www.google.com/about/company/user-consent-policy.html


Children
Our apps and games are for a general audience. In order to comply with the legislation, you will be presented to an age screen, when launching our app or game. When presented with this age screen, it is important that you state the correct age.
Based on your age information and your device settings, we do not process personal data of children under the minimum age limit that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement. If such personal data have been processed without our knowledge, we will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from our records.
If you have additional questions about our privacy practices related to children under the applicable minimum age, please contact us via e-mail address found below.

Security


We take commercially reasonable precautions to protect your personal information and ensure the security of our systems.
It is important for you to protect against unauthorized access to your password and to your computer.


Your rights in relation to your personal data


If you are a user of our app or game you have certain rights in relation to your personal data according to EU General Data Protection Regulation (GDPR). If you wish to use any of the rights described below, you may contact us at any time via e-mail address found below.


Right to request access
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
• the purposes of the processing
• the categories of personal data concerned
• the recipients or categories of recipient to whom the personal data have been or
will be disclosed
• the envisaged period for which the personal data will be stored
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.


Right to rectification and erasure


You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• if you have withdrawn your consent and there are no other legal grounds for the processing,
• if you have objected to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
• the personal data have been unlawfully processed or
• the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.


The right to restriction of processing


You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest


The right to withdraw consent


If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use our game or app will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.


The right to data portability


You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.


The right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use app or game will cease automatically.


If you wish to make a complaint over the processing of your personal data, you have the right to lodge a complaint to the relevant supervisory authority.


Data controller


We are responsible for deciding how and why we collect and use your personal data. If you want to contact us, you can find our contact details in the section below.Contact and complaints 


Contact and complaints
Small Basement games contact information:
Address: Dr Milenka Hadzica 4/20, Nis, 18000 Serbia

E-mail: smallbasementgames@gmail.com


E-mail: funlandgames5@gmail.com