Simpencil Privacy Policy
Last updated: 3-Jan-2023
Privacy policy overview
The sole intention of the privacy policy is to provide you with the answers
pertaining to the
collection, sharing, usage, visibility, advertisement and your user rights. We
collectively call this
as our Privacy Policy. Changes made to this policy will be updated here from time to
time along
with a notification to our users. The update will be sent prior to the change date,
your continued
use of the service post the effective date will be considered as acceptance of the
new policy and
shall be governed by the new privacy policy.
Data collection
Personal information we collect include Email & Name (if relevant to show
your scores or to
certify at the end of the game). We will collect profile information, your
selections during the
game will be collected to compute your results. In case of support tickets
raised, we will store
your messages sent to us. Data surrounding identity establishment and lost
account retrieval
provided by you is one other aspect of personal information we may need.
Data collected automatically are as
follows:
1. Your account and game progress will be captured and stored to maintain
the session
grid. Else you may have to start an exited game in the mid, from start.
2. Your IP address and mobile device identifiers (such as your device ID,
advertising ID,
MAC address, IMEI)
3. Data about your device, such as device name and operating system, browser
type and
language, internet service provider, and mobile carrier
4. Data we collect with cookies and similar technologies.
5. General location data (as derived from IP address)
6. Data about your use of the Service, such as gameplay data and your
interactions with
other players inside the Service.
Data collected from partners are as
follows:
1. Data we receive if you link a third-party tool with the Service (such as
Facebook, Google
or Apple’s Game Center)
grid. Else you may have to start an exited game in the mid, from start.
2. Demographic data (such as to determine the coarse location of your IP
address)
3. Data to fight fraud (such as refund abuse in games or click fraud in
advertising, although
this does not apply to our games since they have no real or fictitious wallet or
money
management system. The question of refund does not arise in our games. If at all
there
is, then this proviso will apply)
4. Data from platforms that the games run on
5. Data for advertising and analytics purposes, so we can provide you a better
Service
6. Data that you have made available to us from a third-party service (such as
Google or
Facebook) via your privacy settings. This data helps us customize your game.
Data usage
The collected data is used
for multiple purpose not limited to Service, Support, Advertisements,
Safety and Analysis during troubleshooting.
Identity establishment:
To ascertain who has agreed to our terms of service and use, create an account to
store your
choices made in the game and retrieve the same in the form of a score. In short, the
entire game
revolves around the choices made by the user during the game. We process the data
and
choices to arrive at a score at the end of the game. We also use the data to ensure
we are
sending the right user communication to the right user.
Profile management:
To ensure we keep a track of the games played by you and provide a better and
superior service
to you every time, we require your data. We update your profile with the latest
games played and
the scores gained. We use your data to create leaderboards and competitions. Based
on your
engagement levels we may choose to reach out to you with similar games or products
which are
appreciated by you. We may use your data to communicate with other players, largely
statistical
data to compare other user’s performance. Your data will be required to be verified
time to time
to ensure that there is no unauthorised access on your profile or device. We will
also need your
data to analyse your preferences with respect to advertising on the platform.
Advertisement management:
We intend to show you only relevant advertisements based on the data about you
available with
us. To show you personalized advertisements in the Service as well as in other
websites and
services (including e-mail) we have a legitimate interest to process necessary data
to track the
content you access in connection with the Service and your online behaviour.
Deliver, target and
improve our advertising and the Service.
Safety & Analysis management:
We are committed to ensuring the right demographic uses our content. All efforts are
made at
Simpencil to ensure content authenticity and correctness and more importantly
Globally
Consumable Content has remained our top-most priority. We use your data to ensure we
are
serving appropriate content (or level of difficulty in our games) to the right age
group. We need
this also identify fraudulent and misbehaving players on our platform who indulge in
unacceptable behaviour and digital vandalism. We need your data for analysing,
correlating, and
aggregating statistics and other information to serve you better.
Data visibility
Besides Simpencil your
data can be accessed by others in the following scenarios.
Players besides you on the platform will be compared with your achievements from
time to time
when relevant. Your scores will be used to compute percentile position of others in
the game. In
the case of a leaderboard, your information will be seen by other players.
Your details will be shared with partners who work with Simpencil in the production,
distribution
and collation purposes including advertisement management.
Your details will be shared with public authorities in order to combat fraud and
illegal activities.
We may provide your data to other companies or authorities or to competent public
regulatory
bodies or authorities in response to lawful requests. We may disclose your data with
or without
your consent to comply with the law or to protect the rights, property or safety of
us, our players,
or others.
Advertisement
We will need your data for in-game advertising, social media posting on your behalf,
connecting
you to other partners who operate under their own privacy policies and data
controls. The
Service includes features, such as social media interaction tools and in-game
advertising,
provided by our below listed partners who operate under their own privacy policies
as data
controllers. These partners can use advertising identifiers, cookies, web beacons,
and other
tracking technologies to collect or receive data about you and your device (such as
your IP
address, mobile identifiers, page(s) visited, location, time of day). We may also
combine and
share data we have collected about you with third-party advertising partners. Our
statements
under this Privacy Policy do not apply to the features, technologies or practices of
such third
parties, as we may not control those features and are not responsible for them. We
encourage
you to check their privacy policies to learn more about their data processing
practices.
The Service may use third parties such as network advertisers and ad exchanges to
serve you
ads, including interest-based ads, on the Service or on third-party services after
you leave the
Service, and we may use third-party analytics and other service providers to
evaluate and
provide us and/or third parties with information about the use of the Service and
viewing of ads
and of our content. “Interest-based ads” are behavioral ads targeted to you based on
your
activities across third-party sites and across time, including retargeting of ads
after you have left
the Service and are on a third-party service.
Our Service is global by nature and your data can therefore be transferred to
anywhere in the
world. Because different countries may have different data protection laws than your
own
country, we take steps to ensure adequate safeguards are in place to protect your
data as
explained in this Privacy Policy. Adequate safeguards that our partners may use
include
standard contractual clauses approved by EU Commission and the Privacy Shield
certification in
case of transfers to the USA.
Please check the privacy guidelines of Facebook, Google Play and other frequently
visited online
services to understand the potential use of your data from time to time.
User rights
You can make a written request to contact@simpencil.com to provide you a copy of the
data we
have about you in the electronic format.
You also have the right to correct your data, have your data deleted, object to how
we use or
share your data, and restrict how we use or share your data. You can always withdraw
your
consent, for example by turning off GPS location sharing in your mobile device
settings. You
have the right to complain to a data protection authority about our collection and
use of your
personal information. For more information, please contact your local data
protection authority.
We will respond to all requests in accordance with applicable laws. To protect your
privacy, we
may also take additional steps to verify your identity before fulfilling your
request, such as by
requesting you provide us a purchase receipt or other account information, asking
you to link
your email address with your game account or asking you to answer questions
regarding your
activities on our Services. Once you have verified your identity, you may also
designate an
authorized agent to exercise your rights on your behalf by providing the agent’s
contact information to our customer support staff, as required by applicable law.
You may
have a right
not to receive discriminatory treatment as a result of your exercise of these
rights.
To provide our Games and interest-based advertising, we use advertising identifiers,
cookies and
similar technologies. This section describes our use of these technologies and how
you can
manage your preferences.
Advertising identifiers, cookies and similar technologies are used by us to provide
our Services to
you and in order to collect data from your device. These technologies allow us and
our third-party
advertising partners to (i) recognise you and your device; (ii) provide
interest-based advertising to
you; (iii) allow our Services to interact with a third party social network or
platform (where you
have chosen to allow such interaction); (iv) allow our payment processors to process
your
payment instructions; and (v) enable us and third parties to provide you with more
customized
services, for example to provide our Services in the correct language (subject to
availability).
Advertising identifiers are non-permanent, non-personal identifiers such as the
Android
advertising ID and/or Apple’s ID for advertising (IDFA), which are uniquely
associated with your
device. Similar technologies include cookies on Websites and tracking pixels within
ads. These
technologies allow companies (including marketers and advertisers) to recognise your
device
when you use websites and applications. If you wish to prevent your device’s
advertising
identifier being used for interest-based advertising, please check the privacy
settings of your
mobile device and select “limit ad tracking” (Apple iOS) or “opt-out of
interest-based ads”
(Android). You can also choose to reset your device’s ad identifier from the device
settings. In a
comparable way, you can also disable cookies from your browser’s settings if you do
not want to
be tracked by websites. This Privacy Notice does not apply to, and we are not
responsible for the
data collection practices of these third-party advertisers. Please see more
information about
these partners under the “With whom do we share your personal information” heading
above.
You may also see our own advertisements in other games and services. If you click
such
advertisements and install our Game(s), we may share a device identifier with our
partners to
verify installs. our personal information may be transferred to, and processed in,
countries other
than the country in which you are resident. These countries may have data protection
laws that
are different to the laws of your country. Specifically, our servers are located in
India, US &
Singapore, and our third-party service providers and partners operate around the
world. This
means that when we collect your personal information, we may process it in any of
these
countries.
In case of Merger or Acquisition of our company, reorganization or bankruptcy,
receivership,
purchase or sale of assets, or transition of services to another provider, your
information may be
sold or transferred in parts during the transaction as permissible by the law.
We retain your data as long as necessary to operate our legitimate business and its
needs.
When we ascertain that there is no longer any need to retain your information for
the business,
we may choose to delete or anonymize it or store you information and isolate it from
any further
processing until deletion is possible.
We do not collect information about anyone below the age of 13 or knowingly allow
them to use
our services. If you are under 13 (or as applicable age-limit in your geo territory)
please refrain
from sending us any personal information about yourself. In case we know about the
same, we
will delete the information as quickly as possible. If you think we have information
of anyone
under the age of 13, please contact us immediately.