Last updated: 15
September 2022
This Privacy
Policy explains how your personal data is collected and processed by Waffles.Enjoy when you use the our mobile applications (the "App").
The App is a paid
or free to play game (with optional in-game-purchases), and in order to
maintain the high quality and a great game experience we process information
from and about you in particular to improve the entire experience in the App
and to support internal operations.
We update this
Privacy Policy from time to time. If we make changes, 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.
Collection of
information
Information we
collect automatically through the app
When you access
or use the App, we automatically collect general information about you,
including:
- Log Information: We log information about your use of the App, including the type of
device you use, the features you use, access times and your IP address.
- Device Information: We collect information about the device you use to access the App,
including information about the device manufacture, device model, device's
OS, time zone of device, language of device.
- Device identifiers: We collect online identifiers of the device you use to access the
App, including IDFA, Google Ads ID, Google Device ID, Game Center ID,
Google Play Account ID.
- Usage Information: We collect information relating to your use of the App, 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 the App, including which purchases you make
with both virtual and real currencies and the reception of virtual goods
in-game.
Information we
collect from other sources
If you log into
the App using a third party site or platform such as Facebook, Apple Game
Center 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.
You can learn
more about how such third-party sites or platforms process your personal data
in the relevant privacy policy:
If you log into
the App using a third party site or platform, you represent and warrant that
(i) your access and use of such features in connection with the App will comply
with the applicable terms and policies of such site or platform; and (ii) 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.
Use of information
– purpose and legal basis
We use
information about you for the following purposes in accordance with the legal
bases for each type of personal data as described below:
- Log-,
device-, usage-, and consumption information and device identifiers are
being processed:
- to
provide and deliver the products and services you request and send you
related information as requested by you / as agreed with you;
- to
provide and maintain the App and the game experience; and
- to
send you technical notices, updates, security alerts, and support and
administrative messages;
Our processing for the above purposes is
necessary for the performance of a contract to which you are party in order to
support the operation of the App, facilitate the delivery of requested products
and services and enable maintenance and update of the App, see Article 6(1)(b)
of the GDPR.
- to
provide news and information about the App that we think will be of
interest to you;
- to
personalize and improve the App and provide tailored content and features;
- to
monitor and analyze trends, usage and activities in connection with the
App;
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 (also known as "the balancing-of-interest rule").
- to
provide 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 the App (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).
- Information
from other sources are being processed:
- 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.
- to
link or combine information we get from others to help understand your
needs and provide you with better service; and
- to
provide news and information about the App we think will be of interest
to you;
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 (also
known as "the balancing-of-interest rule").
We only process
your information to the extent that is necessary to achieve the purposes for
which the information has been collected.
Storage of
information
Waffles.Enjoy will
store your personal data for as long as necessary in order to provide you with
the App or otherwise fulfil 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 Waffles.Enjoy has ceased.
Sharing of
information
We disclose
information about you to the following categories of recipients based on the
legal bases under 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 Waffles.Enjoy 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;
Furthermore, if
you have given your consent in accordance with Section 6(1)(a) of the GDPR, we
share your Device identifiers 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:
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 following data processors such as server hosting
providers, technical service providers for supporting internal operations, user
login services and analytics service providers:
Social sharing
features
The App offers
or can offer social sharing features and other integrated tools (such as the
Facebook “Like” button), which let you share actions you take in the App 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 the App. 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.
Children
Use of the App
is limited to users aged 13 years and above, except in European Economic Area,
where the App is limited to users aged 16 years and above. If you are accepting
this Privacy Policy and using the App, you warrant you are 13 (or 16, depends
what is applicable) or more years old.
If you have
additional questions about Waffles.Enjoy privacy practices related to children
under the applicable minimum age, please contact us at waffles.enjoy@gmail.com
Transfer to
third countries
In connection
with the processing, we will in certain circumstances transfer your personal
data to recipients outside the EEU.
We only transfer
personal data to entities in third countries that have provided appropriate
safeguards to ensure that their level of data protection is in agreement with
this Privacy Policy and applicable law.
Consequently,
the transfers will only occur based on the following safeguards:
- If
the entity is certified to comply with the principles for data protection
under the US-EU Privacy Shield Framework ("Privacy Shield") (you
can view the entities certified under Privacy Shield at https://www.privacyshield.gov/), or
- If
we have entered into standard data protection clauses adopted by the
European Commission with the entity, which is deemed to offer sufficient
safeguards with respect to the protection of the privacy and fundamental
rights and freedoms of individuals.
Security
Waffles.Enjoy takes reasonable measures to help protect information about you from loss,
theft, misuse and unauthorized access, disclosure, alteration and destruction.
Push
notifications
We send push
notifications or alerts to your mobile device to provide 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.
Does Waffles.Enjoy actually "sell" personal data?
Waffles.Enjoy does
not, and will not, provide your personal data in direct exchange for
money. Therefore, in the literal sense, Waffles.Enjoy does not sell your
data. However, we have disclosed some categories of personal data we collect,
explained under ”Sharing of information“, to the third parties for business
purpose as explained under “Use of information – purpose and legal basis”.
To the extent
this practice is interpreted to constitute a “sale” under the CCPA, please
contact us at waffles.enjoy@gmail.com to exercise your right to withdraw your
consent on sharing your personal data with third parties.
YOUR RIGHTS
Rights of EEU
residents
We process and
answer your requests without undue delay and in any event within one month of
our receipt of the request unless a longer period is required due to the
complexity of the request. In this case, our response time can be up to three
months in total as permitted by Article 12 of the GDPR.
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.
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.
Right to
rectification
You have the
right to have inaccurate personal data rectified, see Article 16 of the GDPR.
The right to
restriction
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.
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.
Rights of
California residents
We endeavor to
respond to a verifiable consumer request within 45 days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason and
extension period in writing. We will deliver our written response by mail.
Any disclosures
we provide will only cover the 12-month period preceding the verifiable
consumer request’s receipt. The response we provide will also explain the
reasons we cannot comply with a request, if applicable. For data portability
requests, we will select a format to provide your personal data that is readily
useable and should allow you to transmit the information from one entity to
another entity without hindrance.
Right to opt out
Under CCPA each
California resident can request any business stops selling personal information
to third parties.
Right to be
informed
You have a right
to be informed about what categories of personal data we are collecting,
including the purpose of the collection. You can freely find this information
in our Privacy Policy. We update our Privacy Policy at least once every 12
months.
Right to
disclosure
You can request
us to disclose what personal data we have collected on you in the past 12
months.
We can assure
you that our Privacy Policy is an relevant document where you can find
information about what personal data we have collected about you over the past
12 months and intend to collect, sources of your personal data and how we use
your personal data.
You also have a
right to get a free copy of your personal information disclosed in
a readily usable and readable format (right of access). You
can make this request for free, twice per year.
When providing
information under the right of access, we will provide you with the following
information:
- The
categories of personal data we are collecting about you,
- The
categories of sources of the personal data,
- The
purpose for collecting your personal data,
- The
categories of any third parties with whom we share your personal data,
- The
specific pieces of personal data collected about you.
Right to
deletion
You can request
us to delete the personal data we have collected on you in the past 12 months.
We fully
recognize you right to deletion, however, we would like to note that in some
cases we are obliged to keep your personal data for certain period of time. For
instance, if we need to provide services to you, detect or resolve issues
security or functionality-related issues, comply with the law, conduct research
in the public interest, safeguard the right to free speech or carry out any
actions for internal purposes that you might reasonably expect. If we do not
have obligations to perform any of the above actions, we can delete your
personal information at your request.
Data
Deletion Request
You may request Waffles.Enjoy to erase without undue delay your personal data when it is no longer necessary
for Waffles.Enjoy to retain such data.
In order for
your data to be erased you can contact Waffles.Enjoy by waffles.enjoy@gmail.com with
request.
Right to equal
services and prices
California
residents are protected against any discrimination that a business might
subject them to based on the exercising of their CCPA rights.
We will not
discriminate against you for exercising any of your CCPA rights. Unless
permitted by the CCPA, we will not:
- Deny
you the App,
- Charge
you different prices or rates for the App, including through granting
discounts or other benefits, or imposing penalties,
- Provide
you a different level or quality of the App,
- Suggest
that you may receive a different price or rate for services or a different
level or quality of the App.
How to exercise
my rights
If you wish to
use any of the rights described below, you may contact us at any time by emailing
us at waffles.enjoy@gmail.com.
Mandatory verification: We will need to verify your identity before
processing your request. However, because you cannot create an account with the
App, and you do not provide us with any information directly, we only collect
information automatically, we may use limited verification methods. To verify
your identity, we will generally require the matching data in our systems to
the information we can process when you are making a request. In certain
circumstances, we may decline the request, mainly where we are unable to verify
your identity, for example, if you disable cookies, changed the device you used
to access the App or you already requested us to delete your personal data.
Contact
Waffles.Enjoy has
the following contact information:
Waffles.Enjoy
E-mail: waffles.enjoy@gmail.com
You may also
contact your local data protection authority for unresolved complaints.