Last updated October 24th, 2019

Sybo ApS Privacy Policy

At SYBO ApS (“SYBO” or "we" / “our”) data protection and confidentiality is a high priority.

The Privacy Notice is updated because the activites connected to Subway Surfers has been transferred from Kiloo to SYBO. Because of this, SYBO is now the publisher and data controller of the personal information collected about you as part of the game.

This Privacy Notice explains how personal information about you is collected, shared and used by SYBO and how you can exercise your privacy rights. This Privacy Notice applies to 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.

This Privacy Notice governs all our Services.

We may amend and/or update this Privacy Notice 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 Notice 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 Notice.

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 explicit consent in accordance with GDPR article 6(1)(a) and 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.

• 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.

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.

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). These identifiers are used by ad networks for a number of purposes thus we encourage you to check the Privacy Notices of our partners. You can find a list of SYBO’s existing advertising networks partners and other third-party service providers and in which countries they are located by clicking hereThese 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 your consent pursuant to the GDPR article 49(1)(a). You can control and limit our use of your identifiers in your device settings.

We may allow third parties to provide analytics services in connection with our Services. These entities may use cookies, web beacons and other tracing 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, analyse 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 tailored advertisements, offers and other content. You have the ability to control the collection and use of your geo-location information at all times. You may disable location-based services at any time by adjusting the settings of your mobile device.

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. We are not responsible for Facebook’s processing of your personal information as a user of Facebook. When you use Facebook Login for authentication or when use the abovementioned features, you should read Facebook’s policies on the protection of personal information and other relevant policies to learn more about their date processing practices..

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 tailored 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; and

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

We may share information about you as follows or as otherwise described in this Privacy Notice:

• 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 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 Notice.

Data retention

We retain your personal information collected as described in this Privacy Notice 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 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.

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 the this Privacy Notice, 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 or by contacting us using the contact information below.

Age, Children

Our Services are not intended to children.

SYBO has implemented age-gate to its games to verify players age. Even if you are below the age for a valid consent, 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.
If you are above 13 years of age, we always offer the option to connect with Facebook. In this situation we are not in control of the advertising Facebook may carry out based on Facebook user data, including the use of a Facebook Login.
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 Notice, please contact us:

Name of the Data controller:

SYBO ApS
CVR: 33858183
Jorcks Passage 1A, 4.1162 København 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.

Contact Us

If you have any questions whatsoever, feel free to reach out to us.