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PRIVACY POLICY

Holden’s Digital Ltd. provides this Privacy Policy to explain how it collects, stores, and uses the information collected in connection with Holden’s Digital’s applications, and websites (collectively, “services”). Holden’s Digital respects the privacy of their users and is committed to protecting the user’s information. You have a right to know our practices regarding the information we may collect and use when you use our services.

 

1. The types of information we collect and how we collect it

 

1.1. Personal Information

  • Holden’s Digital may collect the advertising identifier (Apple’s IDFA and Google’s advertiser ID) and a unique identifier for each user in our mobile apps.

  • Holden’s Digital may integrate third party SDKs in to our services. These SDKs may be used for advertising to our users, analyze service usage, enabling in-app purchases, or providing game services like achievements and leaderboards. We allow third party operators this collected solely for internal operations of the service as permitted by applicable rules and laws. This may include, but is not limited to, persistent advertising identifiers, geolocation information, and IP address. We encourage you to review the policies of the third party operators listed below.

  • Should a user explicitly provide it to us when prompted, we will collect email addresses of our users for our mailing list(s).

  • Some of our services require or allow a user to provide a screen name so they can be identified within the service.

 

1.2. Non-personal Information

  • We allow third parties to collect some anonymous information by which users cannot be identified. Non-personal information may include technical information about your device, such as your browser type, screen resolution, device type, language, type of operating system and geo location (only general location). Non-personal information is gathered by third party services while you are accessing the service. They are allowed to use this information to conduct research and analysis, but only for strictly limited purposes. We encourage you to review the policies of the third party operators listed below.

  • Internally, Holden’s Digital also reserves the right to collect anonymous information for research and analysis. This information is generic in nature and cannot be used to individually identify a user. This information is collected each time a user runs one of our services.

 

1.3. Service Specific Information

  • In order to support some services, Holden’s Digital may collect identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle.

 

2. What we do with the personal information we collect

  • Advertisers collect data regarding advertisement performance, user’s interaction with ads, our apps and user’s interests. Collected data may include user’s personal information in order to serve users ads and for the third parties’ legitimate business interests.

  • Holden’s Digital may collect persistent identifiers in order to provide support for our services to our users. Additionally, Holden’s Digital may use persistent identifiers to send promotions regarding new products or updates to our users. If we keep track of persistent advertising identifiers, it allows us to only notify these users about new products that they will actually be interested in.

 

3. What we do with the non-personal information we collect

  • Third party operators are allowed to collect and use non-personal information to conduct research and analysis, or to target advertisements, or other limited purposes. This information cannot be used to individually identify any user. We encourage you to review the policies of the third party operators listed below.

  • Similarly, Holden’s Digital also uses non-personal information to conduct research and analysis. We do this to improve our services in future updates or to gain knowledge about how our users our interacting with the service.

 

4. What we do with service specific information we collect

  • If Holden’s Digital collects identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle, then it is explicitly required for some feature in that service. For example, the identifier could be saved so that a user’s connections on the social network can see their high score or progress in the game. As stated elsewhere in this policy, you can contact us to have this information deleted for yourself or your child under the age of 13.

 

5. Children

We understand the importance of protecting the privacy and safety of children using our services, as outlined by the Children’s Online Privacy Protection Act of 1998 (COPPA). Accordingly, we do not knowingly collect, use, or disclose personal information from children under 13.

Services that are determined to be targeted at children will still receive advertisements from our third-party operators, and promotions from Holden’s Digital using its internal systems. In this case the ads and promotions will not be targeted at specifically for users, but will be broadcast to all users of the service.

If you are a parent of a child under 13 years of age and you believe your child has provided us with personal information, please contact us using the information below and we will delete the information from our systems.

 

6. Disclosure of Personal information

The scenarios in which we will share your personal data are as follows:

  • we determine that it is required by law;

  • we have a good faith belief it is necessary to protect our rights or property;

  • we are participating in a merger, acquisition, liquidation, dissolution or sale of assets;

  • we have your consent; and

  • as described above in relation third-party operators collecting information from our services.

Under no other circumstances will Holden’s Digital share, sell, rent, or release your data.

You may contact Holden’s Digital to request access, change, update or delete your personal information at any time via the contact details below.

 

7. Security

We follow generally accepted industry standards and internal procedures to protect personal information submitted to us, both during transmission and once we receive it.

 

8. Third-party Operators

 

a) Advertising Networks: Holden’s Digital may allow advertisements from the Third Party ad networks to be displayed in our services. Holden’s Digital makes commercially reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws, and we reasonably believe this to be the case for each of them. If we determine a service to be directed at children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA). For persons in European Union countries, we also configure networks to respect user’s choice to opt-out of behavioural advertising to be compliant with the General Data Protection Regulation of 2016 (GDPR).

 

b) Social Networks: Some of our services integrate a third-party social network such as Facebook or Twitter to allow sharing progress with friends, or allowing them to be invited to use our service. The privacy policy of each social network will indicate what data is available to us and how we use it.

 

c) Game Services: Many of our services integrate either Apple Game Center, Google Play Game Services, or Amazon Game Circle. Each of these third-party operators offer their own privacy policy (listed below), and we encourage you to review them.

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How to contact us and exercise your rights

 

We will do our best to assist with any queries you have about your personal data. You can also exercise the right at any time, or discuss any other data protection matters with us, by contacting us at dataprotection@holdensdigitalltd.com for the attention of the Data Protection Officer. The email address is monitored within working hours and you should receive a reply within two working days.

 

If you have unresolved concerns, you also have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the Information Commissioner's Office in the UK.

 

Last updated 17th January 2019

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