PRIVACY POLICY

1. Introduction and General Terms

These terms apply to the use of Metalife developed by Sugar Social Networks INC (‘we’/‘us’). 

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game”), as well as any other online features relating to the Games including our websites (the “Website”).  Together the Game(s), the Website are referred to as the “Online Services”.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use. 

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit, or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

2. Information We May Collect About You

We collect and process the following information which may include your personal data.

Information provided by you when using the Game
(“Basic Information”)

We will collect the following information from you when you play our Game:

• your mobile device’s unique device ID (Device ID) and a unique ID attributed to your device to enable us to send you notifications;
• your mobile device’s location (if you agree to provide it when using the Game);
• email address;
• your IP address;
• your user preferences; and
• information related to your gameplay, including the actions you take, copies of chat logs between you and other players, your progression through the game, and the virtual items you collect or use.

Contact information provided by you (“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you contact us. This may include:

• your email address;
• your name;
• your password;
• your country;
• the make, model and operating system of your device;
• the mobile network operator linked to your device.

Information used for the purposes of serving advertisements (“Advertising Data”)

Through our third-party advertising network partners, we may gather information about your devices when you install or play our Game, depending on the permissions you’ve granted. This may include:

• the make, model and operating system of your device;
• properties of your device, such as screen size and orientation, audio volume and battery;
• the mobile network operator linked to your device;
• the Game played;
• the country, time zone and locale settings on your device (i.e. country and preferred language);
• the network connection type and speed;
• the IP Address;
• the MAC address;
• the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

Information collected for the purposes of providing analytics (“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. Personal data we may collect includes the following:

• your Device ID;
• your user ID (which is generated by us and allocated to you when you first play our game);
• your device operating system & version;
• your device make and model;
• purchase transaction types and spend you have made using virtual items in the Game;
• the country of your Device;
• a record of where you found a link to install our software;
• advertisements viewed and clicked; and
• identification of crashes and defects.

Information about you collected from third parties (“Third Party Log In Information”)

When you access the Game via a third party provider, we may collect and store personal and non-personal information which is available on that third party provider, , provided that you have expressly agreed to the use of third party cookies within the Game. We will also receive technical data in order to ensure the Game connect to the correct account.

Identification and address information (“ID and Address Information”)

Account Security

If you provide it, we will use your telephone number to strengthen the account security

3. Why We Collect Information About You

To provide our app to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics and User Content) for delivering our Game to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Game deliver the features promised and function properly, so that you have the best experience when playing our Game.

To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Game and Online Services.

This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing our Game and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Game and Online Services and (iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

To acquire new users and engage current users

We may process information (including some Advertising Data and Analytics) in order to pursue our legitimate interests to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.

We may also process this information to pursue our legitimate interests of acquiring new users for our Game as part of which we use unique links to let us know where our users have come from.

We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you. In particular, we may use some third parties to support us with onlinemarketing. We provide limited information about you to the relevant social media platform through their tools, such as your name and email address so the social network can find users with similar characteristics to you, who may also be interested in our game. This processing is carried out only if you have given your consent. You may withdraw your consent at any time.

To improve the monetisation of the Game

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Game, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Game and increasing the amount of revenue generated via purchases of content within or associated with the Game.

For advertising purposes

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Game.

The information we collect about you may be used to pursue our legitimate interests, in particular to understand how advertisements placed in our Game have performed or how many people have viewed certain advertisements. That information may be collected by the third-party advertising networks linked to below. Once we receive it, we aggregate this information so that it does not personally identify you or permit you to be treated individually.

We may use the information we collect about you to serve you targeted advertisements in our Game. We do this to provide you with more relevant advertising content. 

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

We may also process personal data where necessary for the purpose of preventing or detecting unlawful acts and the safeguarding of children and individuals at risk. This may include processing your username, playerID (a unique identifier assigned to your account) IP address and chat logs.

We process ID and Address Information in order to pursue our legitimate interests in ensuring that users who have been banned and dispute that ban meet applicable age thresholds.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

We work with Apple, Google, Amazon to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes,Google Play and the Amazon App Store).

4. Data Sharing

We will share your information with third parties only in the ways that are described in this Privacy Policy.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Sugar Social Networks INC, our customers, or others.

Digital Content Stores: Where the Games are downloaded though Google Play, Amazon App Store and/or iTunes, we may disclose your personal information to any of them for the purposes of facilitating any in-Game payments made through these platforms.

5. Your Rights in Relation to Personal Data Which We Process Relating to You

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

• you consented to our processing the personal data, and have withdrawn that consent;
• we no longer need to process that personal data for the reason it was collected;
• we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Sugar Social Networks INC or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
• the personal data was unlawfully processed;
• you need the personal data to be deleted in order to comply with legal obligations;
• the personal data is processed in relation to the offer of a service to a child.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

6. Data Retention

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

After 6 years of inactivity, we will irreversibly anonymise all your personal data we hold about you which was collected through our Online Services.

Children

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13years of age please contact us.

7. Security

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are encrypted, password protected and limited to essential employees only.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

8. International Data Transfers

Whenever we transfer your personal data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government and the European Commission whichever is relevant.
• Where we use certain service providers, we may use specific contracts approved by the UK Government and the European Commission, whichever is relevant, which give personal datathe same protection it has in the UK and Europe.
• Where we use providers based in the US, we may transfer data to them if the transfers are based on Standard Contractual Clauses approved by the relevant supervisory authority, EEA EDPB or UK ICO.

9. Your California privacy rights 

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.
For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see 2. Information We May Collect About You in this Privacy Policy. We collect this information for the business and commercial purposes explained in 3. Why We Collect Information About You and we share this information with our partners as explained in 4. Data Sharing section above. Sugar Social Networks INC does not sell (as the term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).