PRIVACY POLICY 

This privacy policy was last modified at the 3rd of January 2022. 

OVERVIEW 

ABOUT US AND HOW TO CONTACT US 

SirraGames provides free games online and will process your personal information when you play our games. If you have any questions about our data practices, your rights or have any concerns or complaints, you can contact us at codablestudio@gmail.com. 

PERSONAL INFORMATION WE COLLECT 

We collect personal information from you directly, e.g., when you play games or register for an account, and also generate information about your use of our games, including game play and log data. If you log in to a game with your social media account, we will receive information about you including your name, profile picture and email address. 

HOW WE USE YOUR PERSONAL INFORMATION 

We use your information to provide you with our games, support and analyse your use, and improve them. We will also use your information to respond to your questions. 

WHO WE SHARE YOUR PERSONAL INFORMATION WITH 

We rely on third parties for the purposes set out in the privacy policy, including support services, such as game servers and game analytics. We also work with certain advertising partners to show you ads. Additionally, we share your information within our group and as required by law. 

WHERE WE PROCESS YOUR PERSONAL INFORMATION 

We have locations in the Australia and India where we process your information. 

YOUR RIGHTS 

You may have rights to access, receive a copy of, or delete, your information or restrict processing of your data. 

CHANGES TO THE PRIVACY POLICY 

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the in-Game. 

INTRODUCTION 

This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Information (as defined below). In this Policy, SirraGames described as “SirraGames”, “we”, “us” or “our”. We are the data controller under the applicable privacy laws. 

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. This includes Information relating to your use of our mobile games (“Mobile Games”). When you use the Mobile Games, you accept our rules and policies which set out how we handle your Information, and you understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy. 

1. PERSONAL INFORMATION WE COLLECT 

We will collect and use the following Information about you: 

 

 

Children 

Our Games are not targeted at children. Where Children under 16 use our Games, we advise that they obtain the permission of a parent or guardian, and we recommend that parents or guardians take all other steps highlighted in this policy to minimise the data collected. 

2. HOW WE USE YOUR PERSONAL INFORMATION 

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH 

We share your Information with selected third parties, including: 

Security 

Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process. 

4. WHERE WE PROCESS YOUR PERSONAL INFORMATION 

Your Information will be processed by SirraGames in Australia and India. 

5. HOW LONG WE STORE YOUR INFORMATION 

Your Information is kept for as long as you are registered or using our games, and then for up to five years from the date you stop interacting with the games. 

When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently. 

6. YOUR RIGHTS 

If you are based in the EEA, Switzerland or are a legal resident of California in the U.S., you have certain rights in relation to your Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights. For Brazilian residents, please refer to Addendum 2 – Brazil Privacy Rights. For EEA and Switzerland based, you will find more information below on when which rights can apply. For EEA and Switzerland based, you will find more information below on when which rights can apply. 

To exercise your rights, please email us at codablestudio@gmail.com 

7. CONTACT & COMPLAINTS 

We welcome questions, comments and requests regarding this Policy. These should be addressed to codablestudio@gmail.com. 

If you wish to make a complaint about how we process your Information, please contact us at codablestudio@gmail.com and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority. 

8. CHANGES 

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through in-Game. 

9. DEVELOPER PARTNERSHIPS 

We do not work with any third-party developers. 

ADVERTISING AND USER ACQUISITION PARTNERS 

We use the following user acquisition and advertising partners, that are integrated into some or all the Games. Please check the following privacy policies to learn more about their privacy practices, including how you may exercise your data subject rights. 

This list was last updated on 29th January 2022. 

Google Admob - https://policies.google.com/technologies/partner-sites 

Unity Ads - https://unity3d.com/legal/privacy-policy 

ADDENDUM 1 - CALIFORNIA PRIVACY RIGHTS 

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this addendum, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is: lawfully made available from government records, deidentified or aggregated, or otherwise excluded from the scope of the CCPA. 

Collection and Disclosure of Personal Information 

Over the past 12 months, through your use of the Games, we may have collected and disclosed the following categories of Personal Information from or about you: 

In the preceding twelve months, we have collected Personal Information from the following categories of sources: 

  1. You/Your Devices directly. 

  1. Advertising Networks and other advertising partners. 

  1. Analytics Providers. 

  1. Social Networks, to the extent this applies to you and within the limits of your permission. 

We collect personal information for the following purposes: 

For additional information about what each type of personal information is used for, see “How We Use Your Personal Information” in the main portion of the Privacy Policy. 

We may disclose personal information to the following types of entities: 

For additional information about how we disclose personal information is used for, see “Who we share Your Personal Information With” in the main portion of the Privacy Policy. 

SALES OF PERSONAL INFORMATION 

Over the past 12 months, we have used third party advertising and other tracking technologies on our Games to collect information about you, your device(s), and your use of our Games. We share that information with selected third parties such as advertising partners who use it to target advertisements to you online. 

Rights under the CCPA 

The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to: 

 

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. 

How to Exercise Your Rights 

You can exercise your rights by emailing us at codablestudio@gmail.com. 

Verification 

Requests for access to or deletion of Personal Information, whether submitted by you directly or via an authorized agent, are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please be prepared to provide us with identifying information (such as your User ID, Game name etc.) that and we can match against our records in order to confirm you are the rightful account holder. 

Authorizing an Agent 

To authorize an agent to make a request to know or delete or opt out on your behalf, please email us at codablestudio@gmail.com. 

Shine the Light 

We do not rent, sell, or share Personal Information with non-affiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission. 

Do Not Track 

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. 

ADDENDUM 2 - BRAZIL PRIVACY RIGHTS 

The terms of this Addendum apply to residents of Brazil under the Lei Geral de Proteção de Dados (Lei nº 13.709, de 14 de agosto de 2018) and its implementing regulations, as amended or superseded from time to time (“LGPD”). For the purposes of this Addendum 2, Personal Information has the meaning as defined in the LGPD. 

Categories of Personal Information collected and processed 

To find out what categories of your Personal Information are collected and processed, see “Personal Information We Collect” in the main portion of the Privacy Policy. 

How we use your Personal Information 

To find out how we process and use your Personal Information, including on what grounds, see “How We Use Your Personal Information” in the main portion of the Privacy Policy. 

Your rights under the LGPD 

The LGPD provides residents of Brazil with certain legal rights; these rights are not absolute and are subject to exemptions. In particular, you have the right to: 

How to exercise your rights 

You can exercise your rights by emailing us at codablestudio@gmail.com.