SUPERBOX.INC
Last updated: 25 May 2018
This Privacy Policy explains
how your personal data is collected and processed by SUPERBOX.INC
when you use SUPERBOX.INC mobile games (the “App”).
The
App is a free to play game (with optional in-game-purchases), and
in order to maintain the high quality and a great game experience
we process information from and about you in particular to improve
the entire experience in the App and to support internal
operations.
We update this Privacy Policy from time to
time. If we make changes, we will notify you by revising the date
at the top of the policy and, depending on the specific changes,
we will provide you with additional notice or require a renewed
consent. We encourage you to review the Privacy Policy whenever
you access the App to stay informed about how we process your
personal data and how you can protect your privacy.
Collection
of information
Information you provide to us
This
Privacy Policy only concerns the App. If you submit any
information to SUPERBOX.INC through our website or other sites or
services, please review the SUPERBOX.INC Privacy Policy (available
at www.trailtopplay.com) or such
other privacy policy as applicable for information about how we
collect, use and disclose such information.
Information
we collect automatically through the app
When you
access or use the App, we automatically collect general
information about you, including:
• Log
Information: We log information about your use of the App,
including the type of device you use, the features you use, access
times and your IP address.
• Device Information: We
collect information about the device you use to access the App,
including information about the device’s software and
hardware, unique device identifiers (i.e. Device ID and
advertising ID), device tokens for push messages, mobile network
information and time zone.
• Usage Information: We
collect information relating to your use of the App, including
your game progress, scores, achievements and interactions with
other players.
• Consumption information: We
collect information about your consumption habits relating to your
use of the App, including which purchases you make with both
virtual and real currencies and the reception of virtual goods
in-game.
• Facebook ID, Google Game Service & Apple
App Center log Information: We collect information about your
Facebook ID, Google Game Service and Apple App Center to access
the App. Including information about users’ login, including
how many times play the App or Game balance, etc.
• Game
Server AWS: We use AWS(Amazon Web Service) to maintain our
server games’ records, and access to play for users.
Information
we collect from other sources
If you log into the App
using a third party site or platform such as Facebook, Apple Game
Center and Google Sign-In, we access information about you from
that site or platform, such as your screen name, profile
information and friend lists, in accordance with the authorization
procedures determined by such third party site or platform
provided that you have given the third party site in question such
consent.
If you log into the App using a third party
site or platform, you represent and warrant that (i) your access
and use of such features in connection with the App will comply
with the applicable terms and policies of such site or platform;
and (ii) that you are over the minimum age limit that is
prescribed for such third party site or platform by the
legislation in the individual jurisdictions.
Use of
information – purpose and legal basis
We use
information about you for the following purposes in accordance
with the legal bases for each type of personal data as described
below:
Log-, device-, usage-, and consumption
information
- are being processed:
a. to provide and
deliver the products and services you request and send you related
information as requested by you / as agreed with you;
1
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.
b. to provide and maintain the App and
the game experience; and
c. to send you technical notices,
updates, security alerts, and support and administrative
messages;
Our processing for the above purposes is
necessary for the performance of a contract to which you are party
in order to support the operation of the App, facilitate the
delivery of requested products and services and enable maintenance
and update of the App, see Article 6(1)(b) of the GDPR.
d.
to provide news and information about the App that we think will
be of interest to you;
e. to personalize and improve the App
and provide tailored content and features;
f. to monitor and
analyze trends, usage and activities in connection with the App;
and
g. to provide children (as this term is construed under
GDPR in EU, COPPA in the US and relevant applicable legislation in
other jurisdictions) with reasonable contextual advertisements in
the App.
Our processing for the above purposes is
justified by our legitimate interests in providing advertisements
and content of interest to you and improving our services in
accordance with Article 6(1)(f) of the GDPR (also known as
"the balancing-of-interest rule").
h. to
provide non-child users that have given us consent to share their
advertising IDs with our ad network partners (as further specified
under Sharing of Information) for the purpose of serving them with
personalized advertisement in the App (behavioral advertising).
Our
processing for the above purpose is justified by our legitimate
interests in providing advertisements and content of interest to
you in accordance with Article 6(1)(f) of the GDPR. The disclosure
of your advertising ID to third parties for the purposes of
behavioral advertising is based on your consent in accordance with
Article 6(1)(a) of the GDPR (see more below under Sharing of
Information).
Information from other sources
- are
being processed:
i. to provide and deliver the products and
services you request and send you related information;
Our
processing for the above purpose is necessary for the performance
of a contract to which you are party in order to facilitate the
delivery of requested products and services, see Section 6(1)(b)
of the GDPR.
j. to link or combine information we get
from others to help understand your needs and provide you with
better service; and
k. to provide news and information about
the App we think will be of interest to you;
Our
processing for the above purposes is justified by our legitimate
interests in providing content of interest to you and improving
our services in accordance with Article 6(1)(f) of the GDPR.
We
only process your information to the extent that is necessary to
achieve the purposes for which the information has been
collected.
Storage of information
SUPERBOX.INC
will store your personal data for as long as necessary in order to
provide you with the App or otherwise fulfil the purposes as
described above, unless further storage is required in order to
establish, exercise or defend a legal claim or to comply with
applicable law, including accounting rules.
Your
personal data are deleted or anonymized as soon as it no longer
serves one of the above mentioned purposes and in any event no
later than three (3) years after your interaction with
SUPERBOX.INC has ceased.
Sharing of information
We
disclose information about you to the following categories of
recipients based on the legal bases in Sections 6(1)(b), 6(1)(c)
and 6(1)(f) of the GDPR (see a description of the legal bases
above):
• Social networks, see more under
"Social Sharing features";
• Third parties if
we are required to disclose your personal data by applicable law,
rule, regulation, legal process or in connection with, or during
negotiations of, any merger, sale of company assets, financing or
acquisition of all or a portion of our business by another
company;
• The authorities if we believe your actions
are inconsistent with the spirit or language of our policies or if
the disclosure is necessary to protect the rights, property and
safety of SUPERBOX.INC or others;
• Other players in
order to provide certain in-app features, such as leaderboards, if
you log into the App using a third-party service, such as
Facebook, Apple Game Center or Google Game Service;
•
Advertising network companies in order to serve contextual
advertisements (the data include your IP-address, Device ID and
advertising ID).
Furthermore, if you have given your
consent in accordance with Section 6(1)(a) of the GDPR, we share
your advertising ID to advertising network companies for the
purpose of them serving behavioral advertisements to you within
the App. We use or may use the following advertising network
companies:
• Chartboost https://answers.chartboost.com/hc/en-us/articles/200780269
• Facebook Ads https://www.facebook.com/about/privacy/
• Flurry https://policies.yahoo.com/us/en/yahoo/privacy/products/developer/index.html
• Supersonic/IronSource https://www.ironsrc.com/privacy-policy/
• Tapjoy https://home.tapjoy.com/legal/#privacy-policy
• Vungle https://vungle.com/privacy/
• AdMob https://policies.google.com/privacy?hl=en
• Unity https://unity3d.com/kr/legal/privacy-policy
• APPLOVIN https://www.applovin.com/privacy/
• Google Analytics https://policies.google.com/technologies/partner-sites?hl=en
The recipients' use of the disclosed information
will not be covered by this Privacy Policy. If you have questions
concerning the processing carried out by such third parties, you
should review their privacy policy.
In connection with
our processing, we use data processors such as server hosting
providers, technical service providers for supporting internal
operations, user login services and analytics service
providers.
Social sharing features
The App
offers social sharing features and other integrated tools (such as
the Facebook “Like” button), which let you share
actions you take in the App with other media. You must be over the
minimum age limit that is prescribed by the legislation in the
individual jurisdictions to use any social sharing features
integrated in the App. The use of such features enables the
sharing of information with your friends or the public, depending
on the settings you establish with the entity that provides the
social sharing feature.
The App has social features
from the following providers:
• Facebook
•
Game Center
• Google Game Service
For more
information about the processing carried out by the respective
third parties in connection with social sharing features, please
visit the privacy policies of the entities that provide these
features, which can be found here:
• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/internetservices/itunes/gamecenter/
• Google Game Service: https://policies.google.com/privacy?hl=en
Children
The App is for a general
audience. In order to comply with the legislation, you will be
presented to an age screen, when launching the App. When presented
with this age screen, it is important that you state the correct
age. Based on your age information and your device settings,
SUPERBOX.INC does not process personal data of children under the
minimum age limit that is prescribed by the legislation in the
individual jurisdictions for behavioral advertisement. If such
personal data have been processed without SUPERBOX.INC’s
knowledge, SUPERBOX.INC will, after having become aware of the
incident, immediately take reasonable measures to stop such
processing and promptly delete any such data from
SUPERBOX.INC’s records.
If you have additional
questions about SUPERBOX.INC’s privacy practices related to
children under the applicable minimum age, please contact us at
[email protected].
Transfer to third countries
In
connection with the processing, we will in certain circumstances
transfer your personal data to recipients in the U.S which has
been declared an unsafe third country by the European
Commission.
We only transfer personal data to entities
in third countries that have provided appropriate safeguards to
ensure that their level of data protection is in agreement with
this privacy policy and applicable law.
Consequently,
the transfers will only occur based on the following
safeguards:
• If the entity is certified to comply with
the principles for data protection under the US-EU Privacy Shield
Framework ("Privacy Shield") (you can view the entities
certified under Privacy Shield at www.privacyshield.gov), or
•
If we have entered into standard data protection clauses adopted
by the Commission with the entity, which is deemed to offer
sufficient safeguards with respect to the protection of the
privacy and fundamental rights and freedoms of individuals (you
can obtain a copy of the clauses by contacting SUPERBOX.INC).
Security
SUPERBOX.INC
takes reasonable measures to help protect information about you
from loss, theft, misuse and unauthorized access, disclosure,
alteration and destruction.
Your rights
If
you wish to use any of the rights described below, you may contact
us at any time by emailing us at [email protected].
We
process and answer your requests without undue delay and in any
event within one month of our receipt of the request unless a
longer period is required due to the complexity of the request. In
this case, our response time can be up to three months in total as
permitted by Article 12 of the GDPR.
Right to request
access
You have the right to request access into the
data that we are processing on you, see Article 15 of the GDPR,
including information about:
• the purposes of the
processing
• the categories of personal data
concerned
• the recipients or categories of recipient to
whom the personal data have been or will be disclosed
•
the envisaged period for which the personal data will be stored
Furthermore,
you have the right to obtain a copy of the personal data
undergoing processing. Please note that the access may be
restricted due to intellectual property or trade secrets.
The
right to object
You have the right to object to our
processing of your personal data on grounds relating to your
particular situation when the data are processed based on the
balancing-ofinterest rule in Section 6(1)(f) of the GDPR, see
Article 21 of the GDPR. In this case, we will cease the processing
unless there are compelling legitimate grounds for the processing
which override your interests, rights and freedoms or if the
processing is necessary for the establishment, exercise or defense
of legal claims.
To withdraw your consent, if applicable, contact us at
[email protected].
You have the right to
object to our processing of your personal data for direct
marketing purposes at any time. We will cease the processing of
your personal data for this purpose after the objection. Please
note that if you exercise this right, your user license to use the
App will cease automatically. Right to rectification and erasure
If you withdraw you rights, contact us by using the contact
details set out in the “How to Contact Us” section
below.
Right to rectification and erasure
You
have the right to have inaccurate personal data rectified, see
Article 16 of the GDPR.
Furthermore, you have the right
to have your personal data erased where one of the following
grounds applies, see Article 17 of the GDPR:
• the
personal data are no longer necessary in relation to the purposes
for which they were collected or otherwise processed,
•
if you have withdrawn your consent and there are no other legal
grounds for the processing,
• if you have objected to
the processing and there are no overriding legitimate grounds for
the processing,
• the personal data have to be erased
for compliance with a legal obligation in Union or Member State
law,
• the personal data have been unlawfully processed
or
• the personal data have been collected in relation
to the offer of information society services.
Please
note that your right to erasure may be limited if the data are
necessary for compliance with a legal obligation or for the
establishment, exercise or defense of legal claims.
Also Users may request the deletion of their personal information
at any time. If you wish to delete your personal information, you
can do so by following the steps below:
You may send a
personal information deletion request via email to
[[email protected]]. Please include "Data Deletion
Request" in the subject line and provide your request details
along with your account information (e.g., user ID, email address,
etc.).
You may request that we erase the personal information we hold about you in the following circumstances:
you believe that it is no longer necessary for us to hold such
personal information;
you believe the personal information we
hold about you is being unlawfully processed by us.
You can
also exercise your right to restrict our processing of your
personal information (as described below) whilst we consider your
request.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
The right to restriction
You have the right to
obtain restriction of processing in certain circumstances, see
Article 18 of the GDPR. If you have the right to restriction, we
will only process your data with your consent or for the
establishment, exercise or defense of a legal claim or to protect
a person or important grounds of public interest
The
right to withdraw consent
If we have asked for your
consent to our processing of your data, you have the right to
withdraw your consent at any time, see Article 7 of the GDPR.
If
you withdraw your consent, we will cease processing of the data
for which you have withdrawn consent, unless we have a legal
obligation to keep some or parts of your data.
Please
note that if you withdraw your consent, your user license to use
the App will cease automatically.
The withdrawal of
your consent does not affect the lawfulness of processing based on
your consent before its withdrawal.
If you withdraw you rights, contact us by using the contact
details set out in the “How to Contact Us” section
below.
The right to data portability
You
have the right to receive the personal data you have provided us
with which we process in a structured, commonly used and
machine-readable format and have the right to transmit those data
to another controller if the processing is based on consent or
contract performance, see Article 20 of the GDPR.
Push
notifications
We send push notifications or alerts to
your mobile device to provide game-related information, service
updates, promotional communications and other related messages, if
you have agreed to such notifications. You can deactivate these
notifications by changing your notification settings on your
device.
How to Contact Us
SUPERBOX.INC has
the following contact information:
SUPERBOX.INC
Address:
53, Digital-ro 31-gil, Guro-gu, Seoul. Korea
E-mail: [email protected]
If
you wish to make a complaint over the processing of your personal
data, you have the right to lodge a complaint to the relevant
supervisory authority.
