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 email@example.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
WHERE WE PROCESS YOUR PERSONAL INFORMATION
We have locations in the Australia and India where we process your information.
You may have rights to access, receive a copy of, or delete, your information or restrict processing of your data.
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.
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:
Information you provide to us
Information collected via our customer support medium: for example, when you interact with us via email, we ask you to provide (a) your full name, email and password, and (b) any information you choose to provide to allow us to assist you.
Information you provide when using the Games: when you play the Games, we may ask you to choose a username. Also, if you choose to invite your friends to play a game, we will collect the email address of your friends. Please make sure you have permission from your friends before sharing Information relating to your friends with us.
Information we automatically collect or is generated about you when you play the Games
Identifiers, such as your IP address, device and app ID, unique Seep King ID, city level location data and device information (such as model, brand and operating system).
Information you generate and display when playing the Games, such as profile photos and chat content
Information regarding your use of the Games, such as date and time stamps of game events, interactions with our teams and ad engagement, and transaction records, or evidence of you using cheating software or using of modified versions of the Games.
Information received from third parties
Information we receive from third party platforms when you register: when you register through a third-party account (Apple, Facebook), we may receive your third-party ID, name, avatar and city level location. If you give our Game permission, we may also collect your email address, friends list and date of birth.
Information from payment processors: when you make payments in our Games, we receive information from our payment processors about your transactions, including your Apple ID number for Apple, your postcode and state for Google.
Analytics information: we integrate certain analytics software of Google Analytics that provides reports that help us optimise our in-game features and events to each user of our Mobile Games which include your user ID and information on your in-game activity.
Information collected from advertising partners: we receive information from Google AdMob™. This includes user ID and information on your interactions with advertising shown in on our Mobile Games.
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
We use your Information to: Provide you with the Games. More in particular, we will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Games (including as a guest) and remember your progress, allowing you to play Games with your friends, provide you with a (moderated) in-Game chat functionality (if applicable), and to allow you to make purchases via Google Play, IOS App Store and maintain a record of such purchases. The Information we process when doing so includes your registration information, information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, and information regarding your use of the Games such as transaction records.
Improve and monitor Game use. It is in our legitimate interests to improve our Games for our customers. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device.
Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to create, respond and resolve your queries and complaints, facilitate support (e.g., retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration information, your identifiers, non-personal information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other information about you collected via our customer support channels.
Send you updates about in-Game offers and our other products and services that may be of interest to you.
Provide you with advertising. We will present you with ads in our Games. These may be ads relating to our own Games or other services you may be interested in. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so on the basis of our legitimate interests.
Prevent fraud, defend SirraGames against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our users against online abuse and other anti-social or illegal activity, e.g., when moderating conversation in our Games. Furthermore, it is also in our legitimate interest to protect our interests by (1) monitoring Game use to detect fraud or any other user behaviour which prejudices the integrity of our Games, (2) taking steps to remedy aforementioned fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We share your Information with selected third parties, including:
Other players and users will see your profile information and in-game activities, as well as any other information you choose to share with them, such as chat data;
Vendors and service providers we rely on for the provision of the Games, for example:
Cloud service providers who rely on for data storage, including Amazon Web Services who are based in the U.S.;
Analytics providers: we work with Google analytics who help us understand our userbase.
Social media. We integrate certain Facebook software to enhance social media features in the game such as accessing your friends list and displaying your profile picture; and
Advertising partners. We are an ad-supported service. We provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities.
Payment processors: For Mobile Games, we use payment processors such as Google (if you run Android on your mobile device) and Apple App Store payments (if you run IOS on your mobile device). These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies as below:
Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
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 firstname.lastname@example.org
Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.
Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so. Note that where the Information is held by a third-party data controller, such as an advertising partner or a payment processor, we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.
Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
Correction. You have the right to correct any Information held about you that is inaccurate.
Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.
7. CONTACT & COMPLAINTS
We welcome questions, comments and requests regarding this Policy. These should be addressed to email@example.com.
If you wish to make a complaint about how we process your Information, please contact us at firstname.lastname@example.org 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.
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:
Identifiers, including name, email address, IP address, device identifiers, advertising ID, Seep King ID, and profile photos. This information is collected directly from you or your device. If you have registered through a third-party account (Apple, Facebook), we may have also collected from those third-party services your third-party ID, name, and avatar.
Internet or other electronic network activity information, including your use of in-game features and events and information on your in-game activity, and information on your interactions with advertising shown in on our Games. This information is collected from our selected third-party analytics providers and advertising partners.
Geolocation data, including city level location data. This information is collected directly from you or your device and from third party services when you register through them.
Commercial information, including records of products or services purchased, obtained, or considered, your Apple ID number for Apple, your postcode and state for Google. This information is collected directly from you or your device, and from our payment processors.
In the preceding twelve months, we have collected Personal Information from the following categories of sources:
You/Your Devices directly.
Advertising Networks and other advertising partners.
Social Networks, to the extent this applies to you and within the limits of your permission.
We collect personal information for the following purposes:
To operate and administer the Games;
To improve the Games;
To communicate with you;
To serve advertising;
For security and verification purposes, including to prevent and detect fraudulent activity;
To address and remediate technical issues and bugs.
We may disclose personal information to the following types of entities:
Other players and users who will see your profile information and in-game activities, as well as any other information you choose to share with them, such as chat data;
Marketing and advertising partners who use your information to serve you ads in the Games;
Regulators, judicial authorities and law enforcement agencies;
Entities that acquire all or substantially all of our business.
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:
Submit a verifiable request for the following information covering the 12 months preceding your request:
the categories of Personal Information about you that we collected, sold, or disclosed;
the categories of sources from which the Personal Information was collected;
the purpose for collecting or selling Personal Information about you;
the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
the specific pieces of Personal Information we collected about you;
Submit a verifiable request that we delete Personal Information we collected from you; and
Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA, subject to certain limitations.
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 email@example.com.
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 firstname.lastname@example.org.
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
How we use your Personal Information
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:
Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
Request that personal information be corrected.
Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
Obtain information on the possibility of refusing consent and the consequences of doing so.
Obtain information about the third parties with whom we share your personal information.
Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
Revoke your consent at any time.
Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.
How to exercise your rights
You can exercise your rights by emailing us at email@example.com.