Factory Empire
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
controller (Section 1). If any questions will remain unanswered, please contact us at ihor.kopiov@gen.tech.
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
and Websites page .
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
the Service. Privacy Policy. Appsflyer allows you to Opt Out of having data
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
more about Facebook’s approach to data from its Privacy Policy.
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
Privacy Policy .
To perform our App analysis, we also use devtodev, a comprehensive
solution that analyzes games. Devtodev Privacy Policy .
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:
Network Advertising Initiative - http://optout.networkadvertising.org/
Digital Advertising Alliance - http://optout.aboutads.info/
Digital Advertising Alliance (Canada) -
http://youradchoices.ca/choices
Digital Advertising Alliance (EU) -
http://www.youronlinechoices.com/
DAA AppChoices page - http://www.aboutads.info/appchoices
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
hereor adjust your ads settings on Facebook .
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:
Provide our Service (in accordance with our Terms and Conditions of Use)
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.
to enforce our Terms and Conditions of Use and to prevent and
combat fraud
Our legitimate interests for this purpose are enforcing our legal
rights, preventing and addressing fraud and unauthorised use of the
Service, non-compliance with our Terms and Conditions of Use.
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.
To exercise any of your privacy rights, please send a request to ihor.kopiov@gen.tech.
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
available here ).
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
information under the statute .
To obtain this information from us, please send an email message to ihor.kopiov@gen.tech which
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
contact us at ihor.kopiov@gen.tech.
Effective as of: 08.02.2021