This is the privacy policy for mobile games and applications that we make available from time to time (Applications, Apps). The Applications are operated and provided by Digital Forloop Limited (we, us and our). For the purposes of the General Data Protection Regulation and the Data Protection Act 2018 and other relevant legislation, we are the data controller, and this policy sets out our commitment to protecting your privacy by explaining how we use and collect your information within our Applications and what controls you have.

Please read our policy to learn more:

1. Information we may collect from you and how we use it
2. Third party processing of your data
3. Security and safety
4. Your rights
5. About Digital Forloop Ltd
6. Changes to this Policy

1. Information we may collect from you and how we use it

Registration as a user

When you interact with our Apps, we do not require any login or account creation, and we do not collect or store personally identifiable information about you. Instead, we collect and identify your device primarily using your mobile device advertising identifier, e.g. Apple’s iOS Identifier for Advertising (IDFA) or Google’s Android Advertising ID, as well as other identifiers.

Information we may collect about you:

• Behaviour analytics: We use analytics tools (e.g., Google Firebase) to track how features are used, which helps us understand user preferences and improve the Apps.

• Performance data: We collect technical data such as crash reports, memory usage, and other app diagnostics to ensure reliability and performance.

• Advertising: Our Apps display third-party advertisements. Advertisers may use device-level identifiers (such as your advertising ID) to show relevant ads. No personal data is shared or stored by us in this process.

Log Information. We may automatically collect information about your use of our Apps and your device, including your device model, browser version, operating system type, operating system version, device settings, and software data.

Information from Cookies and Other Technologies. We may collect information using web beacons, cookies, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Apps and your experience, see which areas and features of our Apps are popular, count visits, and understand how users interact with ads. Web beacons are electronic images that may be used in our Apps and help deliver cookies, count visits, and understand usage and campaign effectiveness. These cookies do not collect personal information.

Device information

How we might collect

• We may collect certain technical information when you use your device, either smartphone, tablet, PC or Mac, to access or use our Apps.

Some examples of information

• Device type
• Operating system and operating version
• Browser type
• Territory
• HTTP header information
• Your device’s unique identifier, which is encrypted
• In-app progress, including time, in-app purchases, purchases, game play history, in-game rewards, state of play etc.

This information helps us to provide an effective service through our Applications and to collect statistical information about how our content is used.

Log information and unique visitor numbers

How collected

• When you use the Apps
• On install or uninstall of the Apps

Some examples of information:

• On install of an App, unique device details are encrypted and assigned an anonymous identifier tag.
• Registration details to the Apps.
• Date and time the Apps are opened, including session length of play-time within the Apps.
• Areas of the Apps you visited, including any links or features you used.
• Browser type, language, click-stream data.
• Statistical data about your interaction with our Apps.

Analytical tracking tools/code

The Applications may use third party or in-game code/technology to collect information about access or use of any Application.

The in-game code/technology collects or stores pieces of information that may include a unique encrypted reference code that an Application transfers to your device to store and sometimes track information, which may be used to track performance of App directly with our server, or third-party analytical tools. Some last only for the duration of your session in an App and expire when you exit; others are used to remember you when you return to the Application and will last for longer.

We use in-game code/technology to:

• enable you to save your state of play so you can return to a saved game without connection;
• customise elements of the layout or content of the pages of the Application for you;
• remember your game session so you can move freely within the Application; and
• collect statistical information about how you use the Applications so that we can improve the content we provide.

List of analytic tools:

Apps analytics are provided to us by Google Firebase Analytics and Firebase BigQuery, each offered by Google (1600, Amphitheatre Parkway, Mountain View, CA 94043, USA). Further information on privacy practices can be found at https://policies.google.com/privacy?hl=en.

Our Apps may contain in-game advertising where the technology and code have been provided by some or all of the following providers [TBC]. For more information about these third parties and their technology, visit [TBC].

By continuing to use the Application, you consent to our App device identifier settings.

What do we use the information for?

Some examples

• To provide you with the functions and features of the Apps.
• To enable us to ensure our content works with your devices and operates to the optimum performance of your device.
• Ability to manage your in-game App rewards and any in-game achievements.
• Ability to contact you to inform you of updates, or rewards and special offers, or new content and/or features.
• Ability to fully provide you with all features of the Apps, including support sites, and customer support contact routes.
• To provide you with the information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted by us for such purposes.
• Where advertising is supported, to provide advertising that is tailored to your needs where possible.
• Internal operations to allow troubleshooting, data analysis of App usage, testing, research and service improvements.
• To report aggregate or match information to any advertisers or third parties associated with the Apps, or the management of the Apps (you cannot be identified from this information).
• Ability to send you push notifications.
• Ability to understand your in-game preferences.
• To carry out any obligations arising from any contracts entered into between you or us.
• To allow you to find and view your friends’ activity in the Apps, when you are connected to our Apps with Facebook.

2. Third party processing of your data

Remember that when you purchase or use the App, you may be transferring your personal data to:

• the app stores;
• your mobile network provider; and/or
• any payment-processing provider.

Please note that payments made on our Applications are made through our payment-processing provider/the app store. You will be providing payment information direct to them and to their secure server, encrypting your payment information and authorising payment. Information you supply is not within our control and is subject to their privacy policy and terms and conditions.

We may share data with third parties as follows:

• Aggregated information that does not identify you.
• Where Applications carry in-game advertising, advertisers may collect information to help serve adverts to you.
• To protect our users:
  • where legally entitled or required to do so (for example, if required by law, by a court order or if we believe such action is necessary to prevent fraud or cybercrime or to protect the Applications or the rights, property or personal safety of any person); and
  • in the event we undergo reorganisation or if the brand or business or Apps are sold to another company (any personal information we hold about you may be transferred to that re-organised entity or third party).

Data storage

We store any information (though we do not store identifiable personal data) we collect for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

What grounds (legal basis) are we processing the data under?

There are a number of grounds we process your data under. These are:

• Contractual – to enable the features of an Application.
• Legitimate interest – this means the processing is in our interest. It allows us to manage the customer relationship effectively and efficiently and improve the services we provide by better understanding how our Apps are used and which Apps are popular with which groups of individuals.

3. Security and safety

Security

Although we do not process or store personally identifiable information, we understand the importance of ensuring all information associated is safeguarded and whilst we take steps to ensure the security of information, there is a risk that any information transmitted over the internet and stored on a computer may be intercepted or accessed by an unauthorised party. If you think that someone has accessed your information without your permission, you must notify us at contact at digitalforloop dot com.

App stores, Facebook or websites will have their own privacy policies. We recommend that you read these sites or app store terms. We are not responsible for the privacy policies or the content of such sites.

4. Your rights

As we do not collect or retain personal information, most data protection rights (e.g. access, correction, erasure) do not directly apply. However, you may opt out of ad personalisation by adjusting your device’s privacy settings.

The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their information and/or privacy is treated. You can do this via:

• The ICO’s website (https://ico.org.uk/concerns): follow the links or have an online Live Chat.
• Call the ICO helpline on 0303 123 1113.
• Email casework@ico.org.uk.
• Postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

5. About Digital Forloop Limited

Digital Forloop Ltd is the data controller for the purposes of the General Data Protection Regulation and the Data Protection Act 2018. We are registered with the Information Commissioner’s Office and our notification number is ZB804207. If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us using contact at digitalforloop dot com.

6. Changes to this Policy

We may change our Privacy Policy from time to time, so please check back regularly. We will try to notify you in advance where there are any significant or very important changes.