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SYBO ApS Privacy Policy
(Published at https://sybogames.com/privacy-policy/)
Summary
This Privacy Policy tells you what you need to know about the information we collect about you, as well as how and why we collect it. This information is known as personal data.
Mainly, we collect a little bit of personal data about you and your device in order to make our games and services available to you. If we didn’t collect some information, then all of your progress in our games would be lost every time you exit!
If you are 16 or over, we will ask for your consent to send your targeted advertising. You can choose to give us this consent or not. It is up to you. And whatever you choose, it will have no bearing on your ability to enjoy our games. If you are under-16 years of age, we will never send you targeted advertising.
If you have any questions about how we use your personal data or if you wish to exercise your rights, please get in touch: privacy@sybogames.com
Introduction:
At SYBO ApS (“SYBO” or "we" / “our”) data protection and confidentiality is a high priority.
This Privacy Policy explains how your personal data is collected, shared and used by SYBO and how you can exercise your data protection rights. This Privacy Policy applies to personal data (also referred to as personal information) that we collect when you use our mobile game applications, forums, websites and other online products and services (collectively, the “Services”) or when you otherwise interact with us.
SYBO is the controller of your personal data. This is a legal term and means that SYBO is responsible for determining the means and purposes of processing your personal data.
This Privacy Policy governs all our Services.
We may amend and/or update this Privacy Policy from time to time by posting a new version in response to changing legal, technical or business reasons and developments. If we make material changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.
Information we collect
We collect information you provide to us, such as when you participate in a contest and promotion, communicate with us via third-party social media sites, request customer support, send us an email or otherwise interact with us. The types of information we may collect about you include your name, social networking screen names or IDs, email address and any other information you choose to provide.
We also collect the following information:
• Age: when you download our game, we collect your age as indicated by you.
• Log Information: about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Device information: about the device you use to access our Services, including information about the device’s type, software and hardware, Media Access Control (“MAC”) address, and other unique device identifiers (such as Device ID and Advertising ID), device token, mobile network information, and time zone.
• Location information: We collect location information in order to comply with legislation and policies that apply to your area. However, neither we nor our partners collect location information more granular than city level without your explicit consent.
• Usage information: relating to your use of our Services, including which applications you use and your interactions with other users.
• Consumption information: about your consumption habits relating to your use of our Services, including which purchases you make with both virtual and real currencies.
• Other Information: collected by cookies and other tracking technologies: we use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your computer’s hard drive or in device memory that help us to improve our Services and your experience and see which areas and features of our Services are popular. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
• Information from third parties: We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you log into our Services by using a third-party site or platform such as Facebook and any other social media, we may access information about you from that site or platform, such as your screen name, profile information, including picture, and friend lists, in accordance with the authorisation procedures determined by such third party site or platform. We may also collect information from app stores when you download or update one of our applications. We may also receive personal information about you from other third-party service providers and advertising partners.
• Information from third-party surveys: We may invite you to participate in surveys facilitated by third-party survey partners. From these services, we will collect the information you provide as well as your userID in order to be able to match it with your in-game information. You will always be made aware that you are being transferred to the third-party service before the collection starts and thus have the opportunity to opt-out. The partners’ policies will be made available to you and we encourage you to review them before participating in the survey.
However, we do not request or intend to collect any “special categories information” such as information on health, race, religion, political opinions, sexual preferences or orientation. Be cautious when sharing this information about yourselves (or others) in our Services.
How we use your information
We may use information about you for various purposes described below. We have also indicated our lawful basis for such processing.
• Provide, maintain, and improve our current Services (necessary for the performance of the contract we have with you);
• Develop new Services (our legitimate interests so that we can continue to make great games and Services);
• Provide and deliver the products and services you request and send you related information (necessary for the performance of the contract we have with you);
• Respond to your comments, questions, and requests and provide customer service and support (our legitimate interests so that we can respond to queries);
• Send you technical notices, updates, security alerts, and support and administrative messages that are required for the operation of our Services (necessary for the performance of our contract with you);
• Communicate with you about products, services, offers, promotions, and events offered by SYBO and others, and provide news and information we think will be of interest to you (consent);
• Provide targeted advertisements, content or features (consent);
• Process and deliver contest entries and rewards (necessary for the performance of our contract with you);
• Monitor and analyze trends, usage, and activities in connection with our Services (our legitimate interests so that we can understand how our Services are being used and improve them);
We may also process your personal data for other purposes consistent with those set out above. If we carry out any new processing we will update this Privacy Policy.
Ad Networks
We may feature advertising in our Services via showing third-party advertisements in our Services, as well as advertise our own Services via third parties.
This is only done for users aged 16 years or more and only where such users have given their consent.
SYBO may disclose your personal information to advertising networks for the purpose of their direct marketing. Thus, we may send your advertising ID and IP address to ad networks to enable our partners to serve appropriate ads in accordance with GDPR Article 6(1)(f). "Advertising ID" means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that SYBO and our advertising network partners use for interest-based advertising (targeted). They are consistent across all apps and thus allow cross-app tracking. These identifiers are used by ad networks for a number of purposes, in addition to targeted advertisement, thus we encourage you to check the Privacy Policies of our partners. You can find a list of SYBO’s existing advertising network partners and other third-party service providers by clicking here. These advertising networks may be located in countries outside EU/EEA that have less restrictive data protection legislation. For such advertising networks in countries outside EU/EEA, the legal basis for the transfer is always in accordance with one of the lawful instruments set forth in data protection laws. You can opt out of all third-party targeted advertisements, for all apps, using the device-level opt-out settings on your device. If you use an Apple device, a guide for opting out can be found here. If you use an Android device, navigate to the Google Settings page, select Ads, and then choose to reset your Android Ad ID or opt-out of targeted ads.
We may allow third parties to provide analytics services in connection with our Services. These entities may use cookies, web beacons, and other tracking technologies to collect information about your use of our Services, including your IP address, MAC address, device identifiers, software and hardware information, browser information, time zone and usage information. This information may be used by SYBO and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your activity on our Services.
Third-party ad serving and analytics technologies are integrated into our Services, so if you do not want to be subject to these technologies, do not use or access our Services.
Our Services may also integrate third-party Application Program Interfaces (APIs) and/or SDK’s, which allow others to collect and process information about you, including but not limited to your geo-location information, to provide you with targeted advertisements, offers, and other content. You always can control the collection and use of your geo-location information. You may disable location-based services at any time by adjusting the settings of your mobile device.
Ad Networks may use information about you, such as your advertising ID, to identify users who are likely to have an interest in our services and display advertising to them. They may also use this information to identify whether you are an existing user of our services and exclude you from further advertising of our services.
Social media, links to websites, other platforms
Our Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. 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 and information about your game status and progress, etc. may be shown on these media. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Our Services may contain links to websites, social media, platforms etc. We are not responsible for the contents of the websites, social media, platforms etc. of other companies or for the practices of such companies regarding the collection of personal information.
If you use Facebook Login for authentication, Facebook may use your personal information for their own purposes. In this situation please refer to Facebook’s privacy- and other relevant policies.
Subway Studio
The following policy applies to the Subway Surfers Subway Studio (“Subway Studio”) feature.
Permission to Access Camera Roll
For users over the age of 13, you can choose to provide access to your device’s camera roll. If you allow access to the camera roll, then you can choose to use one of your images as a background for Subway Studio If you choose to allow access to your device camera roll, then you can virtually place Subway Surfers characters onto your own images. You can change your mind and disable access to your camera roll in your device settings at any time.
Permission to Access Device Storage
In order to save content, such as photos or videos, Subway Studio may need permission to access storage on some devices. If you provide permission, you can change your mind and disable this permission at any time in your device settings.
Sharing content to social media platforms
Social sharing features (i.e. to Facebook, Instagram, etc.) and other integrated tools, which let you share content you create with Subway Studio, are available to users above the age of 13. If you are a user under 13 years old, sharing is not enabled but you can save the content you create to your device.
Subway Studio User Data
SYBO does not collect or process the content created within the Subway Studio. All content (photos/videos) generated using the Subway Studio feature is only stored locally on the user’s device.
How we may disclose your information
We may share information about you as follows or as otherwise described in this Privacy Policy:
• With other users of our Services;
• In response to a request for information if we believe disclosure is in accordance with any applicable legal requirement;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of SYBO or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction.
We also may share aggregated information or otherwise anonymized information, which cannot reasonably be used to identify you.
International Data Transfers
SYBO operates globally and our Services are global by nature. Your personal information collected via and/or by SYBO may be stored anywhere in the world and may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.
When we transfer your personal information internationally, SYBO takes steps to ensure that adequate safeguards are in place to protect your personal information and it is treated securely, lawfully, and in accordance with this Privacy Policy.
Data retention
We retain your personal information collected as described in this Privacy Policy for as long as needed to provide you the Services or we have a legitimate business reason to do so.
When we no longer have ongoing legitimate business reason to process your personal information, we will delete your data.
Security
We have implemented security measures to ensure that our internal procedures meet our high-security policy standards. Accordingly, we strive to protect the quality and integrity of your personal information. This includes encryption of data and use of pseudonymization, whenever applicable.
Your data protection rights
You are at any time entitled to be informed and/or access the personal information about you that we process but with certain legislative exceptions. You have the right to:
i) object to the collection and further processing of your personal information;
ii) have your personal data updated, rectified, erased or blocked;
iii) receive information about you that you have provided to us;
iv) opt out of certain uses and disclosures of your personal information; and
v) have your personal information transmitted to another data controller (data portability). In order for you to exercise your data protection rights we are obliged to verify your identity.
We can only verify your identity if you are logged in on one of our Services. You will therefore only be able to exercise your rights if you log in and follow the steps as explained.
If you want us to update, amend or delete the personal information that we have collected about you, wish to get access to the data being processed about you, or if you have any questions concerning this Privacy Policy, you may contact us by email at privacy@sybogames.com
Withdrawal of consent
You may, at any time, withdraw any consent you have given, and we will no longer process your personal information unless we can continue the processing based on another purpose. If you wish to withdraw your consent, you can withdraw it in the game via the settings menu or by contacting us using the contact information below.
Age, Children
Our Services are not intended for children.
SYBO has implemented age-gate to its games to verify players’ age. Even if you are below the age needed for providing a valid consent for targeted advertising, profiling and geolocation, you can continue accessing our Services. However, there will be no profiling, targeted advertising or geolocation tracking, Our Services will then only contain contextual advertising. We will only collect data, on players under 13 years of age, (or under 16 in certain jurisdictions in the European Union), when it is needed to provide the service and ensure that they are protected in accordance with the applicable privacy laws.
If you are above 13 years of age, (or above 16 in certain jurisdictions in the European Union), we may offer the option to connect with Facebook. In this situation please refer to Facebooks privacy policy.
If you are a parent or legal guardian of a child under the age of 13 (or under 16 in certain jurisdictions in the European Union) who uses our Services, please contact us at
privacy@sybogames.com, if you have any questions or comments. On your request we will delete your child’s personal information if we are able to identify your child, unless you provide us with your verifiable consent for your child to continue to use our games.
How to contact us
If you have any questions about this Privacy Policy, please contact us:
Name of the Data controller:
SYBO ApS
CVR: 33858183
Holmens Kanal 7, 3.
1060 Copenhagen K
privacy@sybogames.com
Complaints
If you wish to appeal against the processing of your personal information, please contact us as indicated above. You may also contact the Data Protection Agency (Datatilsynet), Borgergade 28, 5., 1300 Copenhagen K.