SERVICE PROVIDER: HIGHWEB IRELAND OPERATIONS LIMITED
April 13, 2020
1. WHAT WE COLLECT?
1.1. Voluntarily provided information
Certain parts of our HIGHWEB IRELAND OPERATIONS LTD may ask you to provide personal information voluntarily, such as:
your name, email address, contact details
any information you submit to our customer service team in HIGHWEB IRELAND OPERATIONS SERVICES
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be explained to you when we ask you to provide your personal information.
1.2 Information we collect automatically
When you use our HIGHWEB IRELAND OPERATIONS SERVICES, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws around a globe, such as:
Your service communications (e.g. in-Apps or Apps chats and messages with other players)
Data and analytics about your use of HIGHWEB IRELAND OPERATIONS SERVICES (e.g. in-Apps play progress, levels, Apps played, session length, preferred settings, which in-App adverts you may have viewed, in-Apps preferences or just App preferences, which friends you connect with, the means by which you were referred to our HIGHWEB IRELAND OPERATIONS SERVICES)
Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for more see here "Advertising IDs and Device IDs")
Your device type and the operating system that you use
Geographic location (e.g. country or city location) based on your IP address
GPS location, with your consent
“Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for interest-based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple, you can opt out by choosing the “limit ad tracking” option in the privacy settings. On Google Android, you can opt out by choosing the “Opt out of interest-based ads.” Advertising IDs are non-permanent, non-personal identifiers 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.
“Device identifier / information” means device type, model, manufacturer, operating system and chosen language, or any other technical data, normally available from a device for a developer or App owner.
1.3 Information we obtain from third party sources
(a) Information from social networks. You may choose to connect to our HIGHWEB IRELAND OPERATIONS SERVICES via your social network account. The exact information we receive from you will depend on your privacy settings, but it will typically include your basic public profile information, such as:
or other information
Typical uses include updating App progress on multiple devices you may own so that you can continue your progress using multiple devices. In addition, we may show your Facebook friends in the App and show your public Facebook profile name and picture in App leaderboards and in your App profile.
(b) Third party service providers. We may receive personal information about you from third-party sources.
(c) Advertising partners. We may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement directing you to one of our HIGHWEB IRELAND OPERATIONS SERVICES (such as an ad for one of our Apps in another publishers’ App), we will be provided with information about which ad network and advertising campaign the install originated from (See also "Advertising" below).
2. HOW WE USE COLLECTED PERSONAL INFORMATION
We use your personal information for the following purposes:
2.1 To provide and operate our HIGHWEB IRELAND OPERATIONS SERVICES:
To create user accounts/profiles to enable you to play our Apps
To provide you with the correct versions of our Apps and/or applications (e.g. knowing which language to make our Apps available to you in)
To enable you to communicate with other users and leaderboards local to you
To send you service-related communications including confirmations, technical notices, updates, security alerts, and support/administrative messages
2.2 To improve our HIGHWEB IRELAND OPERATIONS SERVICES and keep them secure:
To respond to your customer support requests
To receive error messages about any issues you/your device encounters with our HIGHWEB IRELAND OPERATIONS SERVICES to enable us to fix bugs and interoperability issues
To detect and prevent illegal activities (including hacking or cheating)
To track App installs (for purposes of measuring the effectiveness of marketing campaigns).
To conduct optional user feedback surveys
To understand you, your preferences and user traffic to enhance your experience and enjoyment using our App
To conduct research
2.3 To personalize our HIGHWEB IRELAND OPERATIONS SERVICES:
To remember you next time you visit one of our HIGHWEB IRELAND OPERATIONS SERVICES
Communicate with you about promotions, rewards, upcoming events, and other news about products and HIGHWEB IRELAND OPERATIONS SERVICES we offer
2.4 For promotional activities (including marketing and advertising):
To provide you with in-App offers and rewards based on your in-App behaviors
To serve you with relevant targeted advertisements (necessary to fund our HIGHWEB IRELAND OPERATIONS SERVICES)
To make you offers to purchase in-App items on discount based on your in-App activity and purchase history.
To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them
To comply with our legal obligations
To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
To prevent and/or detect fraud or fraudulent behavior
3.1 We use advertising to fund our HIGHWEB IRELAND OPERATIONS SERVICES and to make our Apps available. We show third-party advertising in our Apps and advertise our ADV ONLINE SERVICES via third parties. We want to provide you with more detail about how we use information for advertising, both in our properties and in third-party properties.
3.2 To enable us to show in-App ads, we may send your advertising ID and IP address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Apps and on third-party properties. You can control and limit our use of your advertising ID in your device settings. HIGHWEB IRELAND OPERATIONS SERVICES does not control which specific ads are shown in our Apps (this is controlled by ad networks), but we do prohibit certain types of ads.
(a) limit the number of times you see the same ad
(b) ensure they are dealing with humans with real devices and not automated “bots”
(c) 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.
(d) Other brands buy ad placements via an ad network or ad exchange to advertise their products in HIGHWEB IRELAND OPERATIONS LTD Apps. The ad network or ad exchange acts as intermediary between the other App companies and HIGHWEB IRELAND OPERATIONS LTD. In order for an ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. Views, clicks, and installs from ads are measured using the Advertising ID.
(e) Ad networks track which Apps you have used to market you similar kind of Apps.
Your IP address may be used by advertisers to identify your general geographic location, including your country, state and, sometimes, your city.
3.4 HIGHWEB IRELAND OPERATIONS LTD also advertises its Apps on other apps by asking ad networks to place ads for audiences that will be interested in them (determined using Advertising IDs).
3.5 Ad networks use Advertising IDs for this and other purposes (please refer to the Privacy policies of our advertising partners listed as "Third Parties") including, for example, to:
(a) Measure ad effectiveness (looking at total views, clicks and installs generated by its advertising in other publishers’ Apps);
(b) Inform players that have not played for a while about new content in the App. HIGHWEB IRELAND OPERATIONS LTD gives a list of these users in the form of Advertising IDs to an ad network. The ad network then shows these users ads about the new content.
(c) Not display ads for a App a player is already playing. HIGHWEB IRELAND OPERATIONS LTD may send a list of active players in the form of Advertising IDs to an ad network. The ad network then excludes these players from seeing the ad.
(d) Market Apps to a group of potential players. HIGHWEB IRELAND OPERATIONS LTD provides Facebook a list of Advertising IDs to match them with similar type of Facebook users to whom HIGHWEB IRELAND OPERATIONS LTD could then market its Apps. HIGHWEB IRELAND OPERATIONS LTD does not have information on how Facebook identifies or creates profiles of similar type of users.
3.6 You can opt out of interest-based advertising on mobile applications by changing the privacy settings of your device and selecting "limit ad tracking" (Apple iOS) or "opt out of interest-based ads" (Android).
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN WEBSITES
The HIGHWEB IRELAND OPERATIONS LTD may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, flash cookies, operating system-based identifiers, clear GIFs and web beacons.
Cookies: A “cookie” is a small file your browsers stores when told to do so by a website. Typically, websites place a number of different cookies on an end-user’s device. Some are “First-party” cookies,’ i.e. from the website itself, and others are “Third-party” cookies, meaning they belong to advertising and analytics entities or social networks. Cookies are personal information. However, HIGHWEB IRELAND OPERATIONS LTD’s cookies do not include any other personal information and are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the HIGHWEB IRELAND OPERATIONS SERVICES.
5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where (i) we need the personal information to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.
(a) Under our Terms and Conditions, “performance of contract” as a legal basis for processing your information refers to when we make the App and HIGHWEB IRELAND OPERATIONS SERVICES available to you, provide customer support, integrate Apps with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and App progress.
(b) We process your personal data on the basis of our legitimate interests for example when we provide you the App and App events, serve interest based advertisements to you (both in-App and on third-party properties), carry out marketing, keep our Apps secure, for engineering purposes, analyzing the users’ behavior across our Apps, moderating chat discussion.
(c) We have a “legal obligation” to process your personal data when complying with a legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
6. WHO DOES HIGHWEB IRELAND OPERATIONS LTD OU SHARE MY PERSONAL INFORMATION WITH?
We may share your personal information with the following types of recipients:
(b) With any competent law enforcement body, regulatory authority, government agency, court of law or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
(d) With any other person, with your consent for such disclosure.
7. HOW DOES ADV ONLINE COMPANY OU KEEP MY PERSONAL INFORMATION SECURE?
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. Specific measures include encrypting your personal information in transit and at rest.
8. 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.
The Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers, and partners and further details can be provided upon request.
9. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. For example, we periodically de-identify unused App accounts and regularly review and de-identify unnecessary personal information.
When we have no ongoing legitimate business need to process your personal information, we will either delete or de-identify it, or, if this is not possible – for example, because your personal information has been stored on a backup server – then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(b) To object to the processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict processing of your personal information or request portability of your personal information. Again, you may do so by opting out of personalized offers based on in-App behavior, or by contacting us.
(c) 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.
(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent.
(e) You have the right to file a complaint with 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 we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
11. AGE LIMIT
When we collect personal information, we do not know the age of our players. If a user has a Facebook account and has logged into a App, we obtain the age information from the player’s Facebook profile. Learn more at http://alterapps.com/terms.
13. HOW TO CONTACT US
HIGHWEB IRELAND OPERATIONS LTD
Our address: 6-9 Trinity Street Dublin 2, Ireland, 675090.
Tel: +7 921 404 2469
e-mail: [email protected]
You can exercise your right to access personal information, request the deletion of personal information or opt out of personalized offers directly in our Apps.
To do so,
open the Settings, and
tap the “Terms and Privacy”
This is our preferred contact method, as we can more accurately validate a request received directly from a device and application.