At SYBO ApS (“SYBO” or "we" / “our”) data protection and confidentiality is a high priority.
Information we collect
Information you provide to us
We collect information you provide voluntarily 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.
Information we collect automatically
When you access or use our Services, we automatically collect certain information from you and/or your device (which may be considered personal information under applicable data protection laws). We collect this information with your either your explicit consent in accordance with GDPR article 6(1)(a) or as part of our legitimate interest in accordance with GDPR article 6 (1)(f)., including:
• 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 surverys: 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 you userID in order to be able to match it with your in-game information. You will always be made aware that you are being transfered 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.
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.
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 networks 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 I GDPR article 44-50. You can opt out of all third-party targeted advertisements, for all apps, using the device-level opt our 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.
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 have the ability to 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.
Adnetworks 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 showed 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.
The following policy applies to the Subway Surfers Subway Studio (“Subway Studio”) feature.
Permission to Access Camera (only applies to Augmented Reality (“AR”) mode)
To use AR mode, Subway Studio will need permission to use your device’s camera. You can always change your mind and disable access to your camera in your device settings. Please note that AR mode is not available for users below the age of 16. For more information about accessing and using Subway Studio, please visit our Terms of Service.
Permission to Access Camera Roll (only applies to Non-AR mode)
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’s non-AR mode. 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.
In order for augmented reality in Subway Studio to function, a user ID may be collected on Android devices. If this applies to your device or you have not previously provided consent to user ID processing, then you may be asked if you consent when the feature launches. The user ID can be used to collect analytics data to evaluate user engagement and improve the application. If you do not wish to provide consent, then the non-AR mode is still available.
How we use your information
We may use information about you for various purposes, including to:
• Provide, maintain and improve our current Services;
• Develop new Services;
• Provide and deliver the products and services you request and send you related information;
• Facilitate communications between users;
• Respond to your comments, questions and requests and provide customer service and support;
• Send you technical notices, updates, security alerts, push notifications and support and administrative messages;
• 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;
• Personalise and improve our Services with the use of profiling to provide targeted advertisements, content or features;
• Process and deliver contest entries and rewards;
• Monitor and analyse trends, usage and activities in connection with our Services;
• Link or combine with information we get from others to help understand your needs and provide you with better service;
• Carry out any other purpose for which the information was collected.
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 may disclose your information
• 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 anonymised 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 no longer have ongoing legitimate business reason to process your personal information, we will delete your data.
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 pseudonymisation, 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.
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.
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 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
email@example.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
Name of the Data controller:
Holmens Kanal 7, 3., 1060 Copenhagen K
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.