IMPORTANT PRIVACY
INFORMATION
In order to use
our
app, we will ask you to enter your email. We will also automatically
collect from your
device language settings, IP address, time zone, type and model of a
device, device
settings, operating system, Internet service provider, mobile carrier,
hardware ID,
Facebook
ID, and other unique identifiers (such as IDFA and AAID). We need
this data to
provide
our services, analyze how our customers use the app and to measure
ads.
For improving the
app
and serving ads, we use third party solutions. As a result, we may
process data
using
solutions developed by Amazon, Amplitude, Appsflyer, Facebook,
devtodev. Therefore, some of the data is
stored and processed on the servers of such
third parties.
This
enables us to (1) analyze different interactions (how often users make
purchases); (2)
serve
and measure ads (and show them only to a particular group of users,
for example, only
to
subscribers).
Please read our
Privacy Policy below to know more about what we do with data (Section 3)
, what data
privacy
rights are available to you (Section 6) and who will be the data
PRIVACY
POLICY
This Privacy
Policy
explains what personal data is collected when you use the Factory Empire
mobile
application (the “App”), the services and
products
provided through it
(together with
the
App, the “Service”), how such personal data
will be
processed.
BY USING THE
SERVICE,
YOU PROMISE US THAT (I) YOU HAVE READ,
UNDERSTAND AND
AGREE
TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16
YEARS OF AGE (OR
HAVE
HAD YOUR PARENT OR GUARDIAN READ AND AGREE
TO THIS PRIVACY
POLICY FOR YOU). If you do not agree, or are unable to make this
promise, you must
not
use the Service. In such case, you must (a) contact us and request
deletion of your
data; and (b) cancel any subscriptions using the functionality provided by
Apple (if you are
using iOS) or Google (if you are using Android), any other app stores that
may be available
from
time to time; and (c) delete the App from your devices.
“GDPR” means the General Data Protection Regulation (EU)
2016/679 of
the European
Parliament and of
the
Council of 27 April 2016 on the protection of natural persons with
regard to the
processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European
Union and
the European Free
Trade
Association.
For the purpose of this policy EEA shall include the United Kingdom of
Great Britain and
Northern Ireland.
“Process”, in respect of personal data, includes to collect,
store,
and disclose to others.
TABLE OF
CONTENTS
1.
PERSONAL DATA
CONTROLLER
2.
CATEGORIES OF
PERSONAL DATA WE COLLECT
3.
FOR WHAT
PURPOSES
WE
PROCESS PERSONAL DATA
4.
UNDER WHAT
LEGAL
BASES WE PROCESS YOUR PERSONAL DATA (Applies
only to
EEA-based
users)
5.
WITH WHOM WE
SHARE
YOUR PERSONAL DATA
6.
HOW YOU CAN
EXERCISE
YOUR PRIVACY RIGHTS
7.
AGE
LIMITATION
8.
INTERNATIONAL DATA
TRANSFERS
9.
CHANGES TO
THIS
PRIVACY POLICY
10.
CALIFORNIA
PRIVACY
RIGHTS
11.
DATA
RETENTION
12.
HOW “DO NOT
TRACK”
REQUESTS ARE HANDLED
13.
CONTACT
US
1.
PERSONAL
DATA
CONTROLLER
Obrio
Limited, a company registered under the laws of the Republic of Cyprus,
having
its registered
office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be
the controller
of
your personal data.
2.
CATEGORIES OF
PERSONAL DATA WE COLLECT
We collect data
you
give us voluntarily (for example, email address). We also may
receive data
about
you from third parties (for example, when you sign in via Facebook).
We also collect
data
automatically (for example, your IP address).
2.1. Data you
give
us
You provide us
your
email and location when you register for and/or use the
Service.
2.2. Data
provided
by third parties
When you use
sign in
with Apple to register an account in the App, we get
personal data
from
your Apple ID account. This data may include, in
particular, your
name and verified email address. You may choose to share
your real email
address or an anonymous one that uses the private email
relay service.
Apple
will show you their detailed privacy information on the
sign in with
Apple
screen. Find more about sign with Apple here
.
When you decide
to
log in using Facebook, we get personal data from your
Facebook account.
This includes your profile image, name, and Facebook
ID. Unless you
opt
out on the Facebook Login screen, we will also collect
other data, such
as
email address.
For more
information, please refer to the Facebook Permissions
Reference
(describes the categories of information, which Facebook may
share with third
parties and the set of requirements) and to the
Facebook
Data policy . In
addition,
Facebook lets you control the choices
you made when
connecting your Facebook profile to the App on their Apps
2.3.
Data we collect
automatically:
2.3.1.
Data about how
you
found us
We collect data
about your referring app or URL (that is, the
app or place on
the
Web where you were when you tapped on
our ad).
2.3.2.
Device and
Location
data
We collect data
from
your mobile device. Examples of such
data include:
language settings, IP address, time zone, type
and model of a
device, device settings, operating system,
Internet service
provider, mobile carrier, hardware ID, and
Facebook ID. We
also
record the ads in our App with which you
interact (and
the
Internet links to which those ads lead).
2.3.3.
Usage
data
We record how
you
interact with our Service. For example, we
log your taps on
certain areas of the interface, the features, and
content you
interact
with, how often you use the App, how long
you are in the
App,
your subscription orders.
2.3.4.
Advertising
IDs
We collect your
Apple Identifier for Advertising (“IDFA”),
Identifier for
Vendor (“IDFV”) or Google Advertising ID (“AAID”)
(depending on
the
operating system of your device). You can
typically reset
these numbers through the settings of your
device’s
operating
system (but we do not control this).
3.
FOR WHAT
PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your
personal data:
3.1.
To provide our
Service
This includes
enabling you to use the Service in a seamless manner and
preventing or
addressing Service errors or technical issues.
To host personal
data and enable our Service to operate and be distributed
we use
Amazon Web Services, which is a hosting and
backend service
provided by
Amazon.
3.2.
To customize
your
experience
We process your
personal data to adjust the content of the Service and
provide content
tailored to your personal preferences.
3.3.
To provide you
with
customer support
We process your
personal data to respond to your requests for technical
support, Service
information or to any other communication you initiate. For
this purpose, we
may
send you, for example, notifications or emails about,
the performance
of
our Service, security, payment transactions, notices
regarding our
Terms
and Conditions of Use or this Privacy Policy.
3.4.
To communicate
with
you regarding your use of our Service
We communicate
with
you, for example, by push notifications. These may
include
reminders to
spin the slot or build a new business, or other
information
about
the App. To opt out of receiving push notifications, you
need to change
the
settings on your device.
3.5.
To research and
analyze your use of the Service
This helps us to
better understand our business, analyze our operations,
maintain,
improve,
innovate, plan, design, and develop the Service and our
new products. We
also use such data for statistical analysis purposes, to
test and improve
our
offers. This enables us to better understand what
categories of
users
use our Services. As a consequence, we often decide
how to improve
the
Service based on the results obtained from this
processing. For
example, if we discover that users choose building certain
category of
businesses in the game more frequently, we may focus on
improving the
category or decide to remove it.
To perform
research
and analysis about how users interact with our App we
use Appsflyer. Appsflyer enables us to understand, in
particular, how
users
find us (for
example, who was the advertiser that delivered an ad to users,
which led you to
an
app store with our App). Appsflyer also provides us with
different
analytics
tools that enable us to research and analyze your use of
from my device
sent
to Appsflyer's servers for apps usage collection.
We use
Facebook Analytics, which is a service provided by
Facebook
that
allows us to use
different analytical tools. On Facebook Analytics we get, in
particular,
aggregated demographics and insights on how many people visit
our Website, how
often users make purchases, and other interactions. Lean
Amplitude is an analytics service provided by Amplitude
Inc. We use
this
tool to
understand
how customers use our Service. Amplitude collects
various
technical
information, in particular, time zone, type of device
(phone, tablet
or
laptop), unique identifiers (including advertising identifiers).
Amplitude also
allows us to track various interactions that occur in our App.
As a result,
Amplitude helps us to decide what features we should focus on.
Amplitude
provides
more information on how they process data in its
To perform our
App
analysis, we also use devtodev, a comprehensive
3.6.
To send you
marketing communications
We process your
personal data for our marketing campaigns. As a result,
you will receive
information about our products, such as, for example,
special offers
or
new features available on the App. We may show you
advertisements
on
our App, and send you push notifications for marketing
purposes. To opt
out
of receiving push notifications from us, you need to
change the
settings
on your device.
3.7.
To personalize
our
ads
We and our
partners
use your personal data to tailor ads and possibly even
show them to you
at
the relevant time. For example, if you have installed
our App, you
might
see ads of our products in your Facebook’s feed.
How to opt out
or
influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap
“Advertising” to
select “Limit Ad Track”. In addition, you can reset your
advertising
identifier (this also may help you to see less of personalized
ads) in the same
section.
Android: To opt-out of ads on an Android device, simply
open the Google
Settings app on
your
mobile phone, tap “Ads” and enable “Opt out of
interest-based
ads”.
In addition, you can reset your advertising identifier in
the same section
(this also may help you to see less of personalized ads).
To learn even
more
about how to affect advertising choices on various
devices, please
look
at the information available here
.
To learn even
more
about how to affect advertising choices on various
devices, please
look
at the information available here
.
In addition, you
may
get useful information and opt out of some
interest-based
advertising, by visiting the following links:
● Digital Advertising Alliance (Canada) -
● Digital Advertising Alliance (EU) -
We value your
right
to influence the ads that you see, thus we are letting
you know what
service providers we use for this purpose and how some of
them allow you
to
control your ad preferences.
We use
Facebook Ads Manager together with Facebook Custom
Audience, which allows us to choose audiences
that will see our ads on
Facebook or
other
Facebook’s products (for example, Instagram). Through
Facebook Custom
Audience we may create a list of users with certain sets
of data, such as
an
IDFA, choose users that have completed certain actions
in the Service
(for
example, installed the App). As a result, we may ask
Facebook to show
some ads to a particular list of users. As a result, more
of our ads may
show
up while you are using Facebook or other Facebook’s
products (for
example, Instagram). You may learn how to opt out of
advertising
provided
to you through Facebook Custom Audience here
.
Facebook also
allows
its users to influence the types of ads they see on
Facebook. To
find
how to control the ads you see on Facebook, please go
3.8. To enforce
our
Terms and Conditions of Use and to prevent and
combat
fraud
We use personal
data
to enforce our agreements and contractual
commitments, to
detect, prevent, and combat fraud. As a result of such
processing, we
may
share your information with others, including law
enforcement
agencies
(in particular, if a dispute arises in connection with
our Terms and
Conditions of Use).
3.9. To comply
with
legal obligations
We may process,
use,
or share your data when the law requires it, in
particular, if a
law
enforcement agency requests your data by available
legal
means.
4.
UNDER
WHAT
LEGAL BASES WE PROCESS YOUR PERSONAL DATA
In this section,
we
are letting you know what legal basis we use for each particular
purpose of
processing. For more information on a particular purpose, please refer to
Section
3. This
section applies only to EEA-based users.
We process your
personal data under the following legal bases:
4.1.
to perform our
contract with you;
Under this legal
basis we:
● Customize your experience
● Provide you with customer support
● Communicate with you regarding your use of our Service
4.2.
for our (or
others')
legitimate interests, unless those interests are overridden
by your
interests or
fundamental rights and freedoms that require protection
of personal
data;
We rely on
legitimate interests:
● to communicate with you regarding your use of our Service
This includes,
for
example, sending you push notification reminding
you to use the
App.
The legitimate interest we rely on for this
purpose is our
interest to encourage you to use our Service more
often.
● to research and analyze your use of the Service
Our legitimate
interest for this purpose is our interest in improving
our Service so
that
we understand users’ preferences and are able
to provide you
with
a better experience (for example, to make the
use of the App
easier and more enjoyable, or to introduce and test
new
features).
● to send you marketing communications
The legitimate
interest we rely on for this processing is our interest to
promote our
Service,
including new products and special offers, in a
measured and
appropriate way.
● to personalize our ads
The legitimate
interest we rely on for this processing is our interest to
promote our
Service
in a reasonably targeted way.
combat
fraud
Our legitimate
interests for this purpose are enforcing our legal
rights,
preventing
and addressing fraud and unauthorised use of the
4.3. to comply with legal obligations.
5.
WITH WHOM
WE
SHARE YOUR PERSONAL DATA
We share
information
with third parties that help us operate, provide, improve, integrate,
customize,
support,
and market our Service. We may share some sets of personal data,
in particular,
for
purposes and with parties indicated in Section 3 of this Privacy Policy.
The types of
third
parties we share information with include, in particular:
5.1. Service
providers
We share
personal
data with third parties that we hire to provide services or
perform business
functions on our behalf, based on our instructions. We
may share your
personal information with the following types of service
providers:
● cloud storage providers (Amazon)
● data analytics providers (Facebook, Appsflyer, Amplitude, devtodev)
● measurement partners
● communication service providers
● marketing partners (Facebook)
5.2. Law
enforcement
agencies and other public authorities
We may use and
disclose personal data to enforce our Terms and Conditions of Use,
to protect our rights, privacy, safety, or property, and/or
that of our
affiliates, you or others, and to respond to requests from courts,
law enforcement
agencies, regulatory agencies, and other public and
government
authorities, or in other cases provided for by law.
5.3.
Third parties as
part of a merger or acquisition
As we develop
our
business, we may buy or sell assets or business
offerings.
Customers’ information is generally one of the transferred
business assets
in
these types of transactions. We may also share such
information with
any
affiliated entity (e.g. parent company or subsidiary) and
may transfer
such
information in the course of a corporate transaction, such
as the sale of
our
business, a divestiture, merger, consolidation, or asset
sale, or in the
unlikely event of bankruptcy.
6.
HOW YOU
CAN
EXERCISE YOUR PRIVACY RIGHTS
To be in control
of
your personal data, you have the following rights:
Accessing /
reviewing / updating / correcting your personal data. You may
review,
edit, or change
the
personal data that you had previously provided on the App.
Deleting your
personal data. You can request erasure of your personal data as
permitted by
law.
When you request
deletion of your personal data, we will use reasonable efforts to
honor your
request.
In some cases, we may be legally required to keep some of the
data for a
certain
time; in such event, we will fulfill your request after we have complied
with our
obligations.
Objecting to or
restricting the use of your personal data. You can ask us to stop
using all or
some of
your personal data or limit our use thereof.
Additional
information for EEA-based users:
If you are based
in
the EEA, you have the following rights in addition to the
above:
The right to
lodge a
complaint with supervisory authority. We would
love you to
contact
us directly, so we could address your concerns.
Nevertheless,
you
have the right to lodge a complaint with a competent
data protection
supervisory authority, in particular in the EU Member State
where you
reside,
work or where the alleged infringement has taken place.
The right to
data
portability. If you wish to receive your personal data in a
machine-readable
format, you can send respective request to us as
described
below.
7.
AGE
LIMITATION
We do not
knowingly
process personal data from persons under 16 years of age. If you
learn that
anyone younger than 16 has provided us with
personal
data, please contact
us.
8.
INTERNATIONAL
DATA TRANSFERS
We may transfer
personal data to countries other than the country in which the data
was originally
collected in order to provide the Service set forth in the Terms and
Conditions of
Use
and for purposes indicated in this Privacy Policy. If these countries
do not have the
same
data protection laws as the country in which you initially provided
the information,
we
deploy special safeguards.
In particular, if
we
transfer personal data originating from the EEA to countries with not
adequate level of
data protection, we use one of the following legal bases: (i) Standard
Contractual
Clauses
approved by the European Commission (details available here), or
(ii) the European
Commission adequacy decisions about certain countries (details
9. CHANGES TO
THIS
PRIVACY POLICY
We may
modify
this Privacy Policy from time to time. If we decide to make material
changes to this
Privacy Policy, you will be notified by available means such as email
and will have an
opportunity to review the revised Privacy Policy. By continuing to
access or use
the
Service after those changes become effective, you agree to be
bound by the
revised
Privacy Policy.
10. CALIFORNIA
PRIVACY RIGHTS
California’s
Shine the Light law gives California residents the right to ask companies
once a year what
personal information they share with third parties for those third
parties' direct
marketing purposes. Learn more about what is considered to be personal
includes
“Request
for California Privacy Information” on the subject line and your state
of residence and
email address in the body of your message. If you are a California
resident, we
will
provide the requested information to you at your email address in
response.
11. DATA
RETENTION
We will store
your
personal data for as long as it is reasonably necessary for achieving
the purposes set
forth in this Privacy Policy (including providing the Service to you). We
will also retain
and
use your personal data as necessary to comply with our legal
obligations,
resolve
disputes, and enforce our agreements.
12. HOW
“DO
NOT TRACK” REQUESTS ARE HANDLED
Except as
otherwise
stipulated in this Privacy Policy, this App does not support “Do Not
Track” requests.
To
determine whether any of the third-party services it uses honor the
“Do Not Track”
requests, please read their privacy policies.
13.
CONTACT
US
You may contact
us
at any time for details regarding this Privacy Policy and its previous
versions. For
any
questions concerning your account or your personal data please
Effective as of:
08.02.2021