Privacy Policy

1. Introduction

Please read this Privacy Policy and our Terms of Service carefully before using Crimson Pine Games Services.

This Privacy Policy applies to all of the games, applications, software, products, features and services (together “Services”) of Crimson Pine Games and is made available to any end Users directly by us or with a usage of all platforms and systems.

“Crimson Pine”, “we”, “us” or “our” refers to Crimson Pine Games sp. z o. o. and we refer to You as “You”, “Your”, “User” and “Users” in this Privacy Policy.

We are compliant with all applicable regulations regarding privacy and its protection. The purpose of this Privacy Policy is to provide our Users with comprehensive and easy to understand overview of what we do with Your data.

We wish to remind You that this Privacy Policy applies to the data that we control and process when You use the Service. It does not apply to any external services or third party applications and websites or any other third parties which You may encounter using our Services.

If You have any questions regarding this Privacy Policy, contact us at privacy[at]crimsonpine.com. We may modify this Privacy Policy from time to time without prior notice.

This Privacy Policy was last updated on 24.05.2018.

2. Who we are

Crimson Pine Games is a software developer and a publisher. In order to provide our Services, we collect, store and use Your data as a data controller and processor. The data we are in control of is provided by Users to Crimson Pine Games, collected automatically by Crimson Pine Games and provided to us by any third-parties (i.e. iTunes, GooglePlay).

3. What information is being collected

When You use our Services, we may collect certain information automatically from You and/or Your device which may be considered the personal information under applicable data protection laws, such as:

  • The data related to advertisements. This category includes data such as when an ad was loaded when an ad was displayed or what did You get in the Services in exchange for watching an ad;
  • Details about how You use and interact with our Services. This category varies the most since we are a publisher of various types of Services (e.g. in-game play progress, levels, games played, session length, preferred settings);
  • Device identifiers;
  • Your interactions with us on our social media channels;
  • General location data like country and city name;
  • Hardware data – things such as RAM, operating system, device model, Your battery level, which helps us estimate if the Service is well optimized for Your device.

After You have agreed to our Privacy Policy and Terms of Service all these data is collected automatically.

When You purchase items via our mobile apps (such as those You can purchase in the App Store or on Google Play) we do not collect or store any payment information from You.

The data we collect is mentioned above. To see what kind of information is being collected by third-party advertisers go to ‘Advertising’ section.

4. Why we collect the data

We use the data collected automatically for the following purposes:

  • To improve customer service.
  • To personalize the User experience.
  • To allow synchronization of game progress across multiple devices.
  • To manage the Service.
  • To provide features available in the Service.
  • To develop, improve, and protect the Service.
  • To market research.
  • To audit and analyze the Service.
  • To ensure the technical functionality and security of the Service.

5. What we do with the information we collect

We use the information we collect to provide the Service to You. Our goal is to make our Services the most enjoyable and without the information about Your playstyle we cannot conclude about why Users prefer certain things among the others. It’s necessary for us to use Your information to:

  • Identify when You use our Services;
  • Recommend content and in-game offers and promotions based on Your current and past activity (profiling);
  • Analyze why You’ve decided to watch a certain type of advertisements, bought in-app purchases or subscribed to our Services;
  • Perform tests which are the only way to improve the general gaming experience of our Services;
  • Respond to Your questions and reviews.

We have a legitimate interest in both improving User experience and learn from our past products in order to gain knowledge on how to develop better Services. In short, it’s necessary for us to collect this data and You may often find that without allowing us to automatically collect this anonymized data the Service won’t work as expected or may not work at all.

Information collected automatically shall be used only for general statistics in order to improve the Service’s functionality and correctness. The way You interact with our Services may affect Your gameplay and we may target You with certain offers more often than others. For instance, we may recommend You playing more difficult levels if our algorithm noted that You completed certain levels distinctly faster than other Users. That way both we and Users benefit from sharing Your information to:

  • Personalizing content;
  • Providing advertising;
  • Making recommendations;
  • Improve Crimson Pine Games as a company itself and its Services;
  • Send You updates and notifications. For example, we use notifications to remind You that some things require Your action in the Services. You can always turn off these notifications by updating Your settings;
  • Conduct analytics on who is using our Services and what they are doing. For example, by logging session time of Users who use two different versions of our tutorial, which lets us conclude which version is better.

We also analyze and use the information that we collect on an anonymized or aggregated basis for product development, to analyze the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole.

6. Who will the data we collect be shared with

We may disclose Information to third-parties when it is required by law or by law enforcement entity in accordance with binding regulations.

We, as a data controller, make sure that the data processing carried out on our behalf always meets regulatory requirements and ensure the protection of the rights of the data subject. Third party companies or individuals that we employ to process information work on our behalf based on our instructions and in compliance with this Privacy Policy.

We contract with third parties to provide certain services to facilitate the operations of our Services (“Service Providers”), such as to manage the analytics information about the usage of our Services.  Our Service Providers will be given access to Your information as reasonably necessary to provide the services for which they are contracted. Current data controllers and processors are listed here.

7. Advertising

We use advertising in our Services so we can continue to offer many of our Services for free. When advertisers or ad networks place ads in our Services, they may collect the following types of information from within our Services:

  • Your age, country, region, gender;
  • Information logged from Your hardware or device (browser information, MAC address, Operating System information, IP address, Flash cookies, Device ID, browser cookies, application usage data, installed software, hardware type);
  • Internet and on-line usage information and in-game information;
  • Performance data (like the number of clicks on an advertisement);
  • Ad identifiers – These are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with Your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize Your device when You use websites and applications.

Our advertisers need to collect this data in order to find appropriate ads to serve You in our Services. Crimson Pine Games does not control which specific ads are shown in the Services (this is controlled by ad networks), but we do prohibit certain types of ads.

Advertising IDs are used by ad networks for a number of purposes (please refer to the Privacy Policies of our advertising partners listed here) including, for example, to:

  • limit the number of times You see the same ad
  • ensure they are dealing with humans with real devices and not automated “bots”
  • to serve You with advertisements likely to be relevant to You based on Your advertising ID, Your engagement with other brands and ads which is recorded using Your advertising ID, and to use Your general geographic area.
  • Ad networks track which games You have used to market You similar kind of games.

Your IP address is typically used by advertisers to identify Your general geographic location, for example, Your country, state and, sometimes, Your city).

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

Our advertising partners may combine this information with information which they have collected about You when You use their services (or the websites or services of third parties) in order to serve You more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.

This Privacy Policy does not apply to the collection of Your information by our advertising partners.

For the list of all the current data controllers and processors click here.

8. For how long will we retain Your information

We collect Your data for as long as You use our Services. How long we retain this information depends on why we collected it and how we use it. We retain the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

9. Payment Information

If You purchase a license to use in-game virtual currency or virtual items or a subscription in our game, our third-party payment processor (like Apple or Google) will collect the billing and financial information it needs to process Your charges. This may include Your postal address, e-mail address and financial information. Crimson Pine Games does not collect or store Your financial information, like credit card numbers.

10. Security of Your Information

We use appropriate technical and organizational measures designed to protect the personal information that we collect about You and process. The measures we adopt are designed to provide a level of security appropriate for the degree of risk involved with processing Your personal information.

While we take precautions against possible security breaches of our Services and our databases, no transmission is completely secure. We cannot guarantee that data loss or security breaches will never occur. We have a legal obligation to notify You when a security breach occurs.

11. International data transfers

Your personal information 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.

Specifically, our servers are currently located in the United States, our headquarters are located in Poland, and third-party service providers and partners operate around the world. This means that when we collect Your personal information we may process it different countries. However, we ensure appropriate safeguards are in place so that Your personal information will remain protected in accordance with this Privacy Policy.

12. Your data protection rights

If You’re a European Economic Area (EEA) User, You have options in relation to the information that we have about You described below.

You can access or request deletion of Your personal information by contacting us at privacy[at]crimsonpine.com. We will fulfill Your request within 30 days. You will have to provide us with Your device identification number displayed in settings/options/loading screen. Otherwise, we won’t be able to distinguish and identify You. If there’s no such number in settings, then we don’t collect the data or the data we collect is fully anonymized, therefore You won’t be able to ask us to manage the data. If You can’t find this number or You’re not sure whether we collect Your data or not, contact us.

In order to use our Services, You need to agree to our Terms of Service and confirm that You have read our Privacy Policy. After that, we collect and process Your personal data automatically. You can withdraw said consent at any time in settings/options. Be aware that this action will stop us from collecting the data. It won’t remove the data that we have already collected.

After withdrawing from sharing You data with us You won’t be able to use our Services anymore. Your identification number is persistent, so if you will ever change your mind, you can start playing again and restore your progress.

We may remove your saved profile if you were inactive for over 6 months.

You have the right to opt out of marketing communications we send You, at any time. You can exercise this right by clicking on the “unsubscribe/opt out” link in the marketing communications we send You or by contacting us at privacy[at]crimsonpine.com.

You have the right to complain to a data protection authority. If You’re based in the EEA and think that we haven’t complied with data protection laws, You have a right to lodge a complaint with the GIODO or with Your local supervisory authority (contact details are available here).

Updating, correcting or transferring your personal information isn’t applicable here. The only personal information we store is your device identification number.

Have in mind that if You fill a request to stop collecting Your personal information, we won’t be able to provide the Services since collecting and processing You personal information (as described in 7. Advertising) is necessary for our advertisers.

13. Further information

This Privacy Policy is governed by Polish law.

If You have any questions related to our Privacy Policy or the Services, the best way to get in touch is through privacy[at]crimsonpine.com. If You wish to contact us via traditional post, our address is Jasna 14/10 street, Gliwice, 44-100, Poland.