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34BIGTHINGS

PRIVACY POLICY

Last Modified on 2nd September 2021

  1. What’s in this Privacy Policy?

In this Privacy Policy, you’ll find:

  • What information we collect about you
  • How we might use that information
  • What information we might share with others
  • Your rights and choices about that information
  1. What does this Privacy Policy cover?

We are 34BigThings, in this document we’ll refer to ourselves as “34BT,” “we,” or “us.”

In this Privacy Policy, we will describe how the products and services that we offer to you collect and process your personal data. This Privacy Policy applies to titles published by 34BigThings or titles which link to this policy within the game.

Together, we’ll refer to these as the “Service.” For titles published by third parties, their privacy policy will apply unless otherwise noted.

  1. What types of personal data do we collect?

Below you’ll find details about the types of personal data we collect from you and how we use it. We call this “processing” your data.

We’ll also tell you the reason for processing that data, which is known as our “legal basis.”

Note that in previous versions of our privacy policy where the legal basis for processing was based on your explicit consent, you still have the ability to revoke that consent by either using the game options or contacting us at privacy@34bigthings.com. However, processing of certain personal data may be necessary to provide you with the Service (such as having an Account with us for online gaming).

First, the personal data we collect from you:

Type of data

Examples of the data

How we use it

Our legal basis

Account Information

Your username, email address, country, gender, date of birth, and account profile photo or avatar

·        To create and manage your Account on the Service

·        To allow you to use the Service

·        To contact you for technical support, customer support, and promotional purposes

·        To administer contests, sweepstakes, and other promotions

·        To personalize and improve the Service

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Device Information

Your device’s hardware model and operating system, unique device identifiers (such as an Advertising ID or IP Address), network information, information about where you accessed the Service, your browser type, access times, pages and portions of the Service viewed, source of Service installation, and your activity and interactions with other Service users

·        To operate the Service and ensure that it functions properly on your device

·        For analytics purposes

·        To make improvements to the Service

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Advertising Information

Your device’s unique Advertising ID or similar information may be collected on portions of the Service which display advertisements

To personalize advertisements on the Service to your interests

In connection with our legitimate interests under GDPR Art. 6 (1) (f).

Purchase Information

Information about your purchases on the Service, including the items purchased and any billing information shared directly with us

To facilitate any purchases on the Service and ensure that your Account is credited with the purchase

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Gameplay Information

Information about your gameplay, in-game progress, the games modes you have played, matchmaking times, and information about other Accounts with whom you played online matches.

To operate and improve the Service

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Next, the personal data that third parties share with us:

Type of data

Examples of the data

How we use it

Our legal basis

Social Media Login

Your username and other Account Information provided by a social media platform (like Facebook) or third-party login service (like a Google sign-on), when allowed by that portion of the Service

To create your Account on the Service and for all the purposes that we would use Account Information for above.

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Platform Information

Certain information from your platform account, which is shared with us by the third-party platform that you are using the Service on, such as the Apple App Store, Google Play Store, Steam, Epic Game Store, PlayStation Store, etc.

·        To operate and improve the Service

·        To ensure that any purchases are credited to your Account

·        To contact you for customer support and technical support purposes, and other Service-related purposes

To fulfill a contract with you, under GDPR Art. 6 (1) (b).

Finally, the personal data that we share with others:

Our reason for sharing

What data is being shared?

Who are we sharing it with?

Analytics and allowing Service functionality

Your Device Information, Account Information, and information about your activities on the Service

Google Analytics – https://policies.google.com/privacy?hl=en-US

Google Firebase – https://firebase.google.com/support/privacy?hl=en

Dev to Dev – https://www.devtodev.com/policy

Facebook Business Tools – https://www.facebook.com/legal/technology_terms

Adjust – https://www.adjust.com/terms/privacy-policy/

Appsflyer – https://www.appsflyer.com/services-privacy-policy

Newsletters and other marketing communications

Your name and email address

Note: You may opt out of such communications by following the instructions given in each message

SendGrid – https://www.twilio.com/legal/privacy

Personalizing Service advertisements

Your Advertising Information

Google Admob – https://www.google.com/adsense/new/localized-terms

Technical and Customer Support

Your Account Information

Zendesk – https://www.zendesk.com/company/customers-partners/privacy-policy/

Your public Account profile

Certain Account Information that you make public

Third-party users of the Service who view your profile

Hosting

Any information transmitted through our servers

Microsoft Azure servers: https://privacy.microsoft.com/en-us/privacystatement

We may also need to share your personal data in a few other situations:

  • To comply with the law, a court order, or orders from government agencies
  • To detect and combat fraud or security issues
  • To protect the Service, our employees, and our business’s rights or safety

Other than that, we will not share your personal data with anyone else.

  1. How long do we keep your personal data?

We only keep your personal data as long as it’s required to provide you with the Service. Sometimes a longer period might be required by law.

After that, we will delete your personal data within a reasonable time.

Please note that we may retain some data if necessary to:

  • resolve disputes,
  • enforce our user agreements,
  • follow any technical and legal requirements related to the Service.
  1. Cookies, Mobile Advertising, Do Not Track signals, and sharing to Social Media

Certain parts of the Service, including our website and mobile games, may feature cookies, social media sharing, and online advertising.

Cookies: A cookie is a small amount of data that is sent to your browser from a web server and is stored on your computer’s hard drive. Cookies are not spyware or adware and can’t deliver viruses or run programs on your computer. Other similar methods include tracking pixels and web beacons.

We do not use cookies on the Service. However, certain third-party service providers may use cookies when you go to their websites. For example, if you go to our support page hosted on Zendesk, they may use cookies. Your use of any third-party service providers or websites is subject to their privacy policy.

Mobile Advertising Opt-Out: If you would like more information about online advertising and your choices about not having personal data used to personalize ads for you, please see the following links:

“Do Not Track” Signals: We do not comply with web browser-based and other “do not track” mechanisms.

Social Media Sharing: The Service may allow you to share certain information from the Service or your Account to various third-party social media sites and networks. When you do this, any information you share outside of the Service will be subject to that third party’s privacy policy. We encourage you to review their privacy document before sharing any personal data.

  1. Children’s privacy rights

We don’t knowingly collect any personal data from children under the age of 13. We also don’t knowingly allow them to create accounts, sign up for newsletters, make purchases, or use the Service.

We may also limit our personal data processing for EU users between 13 and 16.

We take children’s privacy seriously and encourages parents to play an active role in their children’s online experience. If you have any concerns about your child’s personal data, please contact us at privacy@34bigthings.com.

  1. Transfers of your personal data

We are a worldwide game studio based in Turin, Italy with cloud servers in the United States, the EU, and Russia.

No matter where you live, by using the Service you consent to the processing and transfer of your personal data in and to the United States, EU, Russia, and Belarus. This processing will be under our privacy policy for our internal studios and the privacy policies of third parties that we share personal data with.

The laws of the Italy governing data collection and use may not be as comprehensive or protective as the laws of your country.

If you would like more information, please contact us (see “How to contact us” below).

  1. EU residents’ rights

We are regulated under the General Data Protection Regulation (GDPR), which applies across the European Union (including in the United Kingdom). We are responsible as a controller of personal data for GDPR purposes.

Under the GDPR, EU residents have several important rights:

  • You can request a copy of your personal data
  • You can ask us to correct that personal data, delete it, or request that we use it only for certain purposes.
  • If you’ve consented to our processing, you can change your mind and ask us to stop using your personal data. For example, you can unsubscribe from our mailing list at any time – just click the link in each marketing email.
  • In some circumstances, you can ask us not to use automated processing or profiling about you.

If you would like to exercise any of those rights, please email us at privacy@34bigthings.com. We may ask for additional info to verify that you’re the owner of that data.

Also, in some cases where the law requires it, we may not be able to help with the above requests.

  1. California residents’ rights

We are regulated under the California Consumer Privacy Act (CCPA), which applies to California residents.

Under the CCPA, California residents have several important rights:

Right to Know: You can ask us what personal data we hold about you and request a copy. This includes:

  • The type and specific pieces of personal data we have collected
  • The types of sources we collect the data from
  • The purpose for collecting your personal data
  • The third parties we share that data with

Right to Delete: You can request that we erase your personal data. There are some exceptions to this right, if we:

  • Need to complete the transaction for which the personal data was collected or if there is an ongoing business relationship or contract with you
  • Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity
  • Need to identify and repair errors affecting Service functionality
  • Exercise free speech or ensure another consumer can exercise (or another lawful right)
  • Need to comply with the California Electronic Communications Privacy Act
  • Engage in research in the public interest
  • Enable solely internal uses that are in line with your expectations for using your personal data
  • Need to comply with a legal obligation
  • Otherwise use your personal data internally, in a way that’s compatible with the reason we collected it in the first place

Sale of your personal data: We don’t sell any of your personal data for any purposes.

Other Rights: California residents also have the right to request information about our disclosure of personal data to third parties for direct marketing purposes during the calendar year before your request. This request is free and may be made only once a year.

We also won’t discriminate against you for exercising any of the rights listed above.

If you would like to exercise any of those rights, please email us at privacy@34bigthings.com. We may ask for additional info to verify that you’re the owner of that data.

Also, in some cases where the law requires it, we may not be able to help with the above requests.

  1. Brazilian residents’ rights

We are regulated under the Lei Geral de Proteção de Dados (“LGPD”), which applies to Brazilian residents.

Under the LGPD, Brazilian residents have several important rights:

  • Know when we use your personal data
  • Access your personal data, correct any errors, or delete your personal data
  • Anonymize, block, or delete data that we don’t need or are not processing in compliance with the LGPD
  • Request we transfer your data to another provider
  • Be informed about who we share your data with
  • Be informed about your ability to deny consent and any consequences
  • To revoke your consent

These rights apply to any personal data collected or processed in Brazil, as well as any personal data processed for the purpose of providing goods or services in Brazil.

If you would like to exercise any of those rights, please email us at privacy@34bigthings.com. We may ask for additional info to verify that you’re the owner of that data.

  1. How do we protect personal data?

We have taken steps and put security measures in place to prevent the accidental loss or misuse of personal data.

For example, we limit access to those who have a genuine business need and protect all personal data using firewalls and other data security measures. Those processing your information will do so only in an authorized manner and under the terms of strict confidentiality agreements.

We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach when legally required.

  1. Resolving Disputes

We hope that we can resolve any questions or concerns you raise about our use of your personal data.

Please contact us at privacy@34bigthings.com to let us know if you have questions or concerns. We will do our best to resolve the issue.

For EU residents, the GDPR also gives you right to lodge a complaint with a supervisory authority. You may do this in the EEA state where you live, work, or where any alleged infringement occurred.

  1. How will we notify you of changes?

We last updated this Privacy Policy on 2nd September 2021.

We may make further updates from time to time. If we have your email address on file, we will inform you via email. Otherwise, we will post a message on the Service about the change.

  1. How to contact us

Please contact us if you have any questions about this Privacy Policy or your personal data.

You can contact our Data Protection Officer by using the following contact information:

  • Sending us an email at privacy@34bigthings.com.
  • Sending us physical mail 34BigThings, Via Gian Domenico Cassini 39, 10141 Torino (TO), Italy.
  • If you are an EU resident, you can contact us by email at privacy+eu@34bigthings.com.