This Privacy Policy applies to Smart Project GmbH games, products, websites, and related services, collectively called the Service. We respect the privacy of users and recognize the importance of protecting information collected from users. This Privacy Policy may be periodically updated by publishing a new version. Please make sure you rely on the most current version of this Privacy Policy.
This Privacy Policy explains how we collect, use, and process the information that users provide. This Privacy Policy applies to users of the Services. Smart Project GmbH collects, uses, and processes personal information provided by users as defined below. Where required by applicable law, such collection, use, and processing will be carried out on the basis of the user’s valid consent, which must be obtained before the relevant processing takes place.By using the Service after accepting this Privacy Policy, users agree to be bound by this Privacy Policy.
If you are a California resident, please see Additional Information for California Residents below in this document. If you are a resident of Japan, please see Additional Information for Residents of Japan below in this document.
Please read the following to learn more about how we use your personal data.
For the purposes of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Smart Project GmbH (referred to as “Smart Project GmbH”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.
Data controller: Smart Project GmbH
Email: support@smartproject.com
Address:Kirchstrasse 52, Liebefeld, Switzerland, 3097
You can also find details about the data controller responsible for your information in the “Contacts” section.
DEFINITIONS In this Privacy Policy, the following terms have the meanings set out below: - "Smart Project GmbH" / "we" / "us" / "our" means Smart Project GmbH, Kirchstrasse 52, Liebefeld, Switzerland, 3097.
"Service" means Smart Project GmbH's games, applications, websites, and related services, as described in this Policy.
"User" / "you" / "your" means any individual who accesses or uses the Service.
"End User" has the same meaning as "User" in this Policy.
"Child" / "Minor" means a person under the age of 16, or such other age as may be prescribed by applicable law in the relevant jurisdiction
"Personal Data" means any information relating to an identified or identifiable natural person, as defined under applicable data protection law, including "personal information" as defined under the CCPA and "personally identifiable information" as defined under COPPA.
"Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
To the extent that the California Consumer Privacy Act (“CCPA”) applies to You, the definitions in this Privacy Policy are to be read as follows:
“Personal data” includes “Personal Information”;
“Data subject” includes “Consumer”;
“Controller” includes “Business”;
“Processor” includes “Service provider”,
all as defined under the CCPA.
For more information about the CCPA, please see the “ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS” section of this Policy.
We also adhere to the Children’s Online Privacy Protection Rule (“COPPA”). To the extent that the COPPA applies to You, the definitions in this Privacy Policy are to be read as follows: “personal data” includes “personally identifiable information”;
“processor” includes “service provider”,
all as defined under the COPPA.
We may apply additional standards to You as required by local law.
Smart Project GmbH strives to ensure that the processing of personal data by Smart Project GmbH, is carried out in accordance with applicable legislation.
If you have any questions or concerns about this Privacy Policy, including those related to exercising any of your rights, please contact us through the game’s Support feature so we can reply to you more quickly.
The restrictions and rules specified herein for persons under the age of 16 or another age to which restrictions apply fully apply to persons of any other age, if such restrictions are provided for by the applicable legislation of the relevant country.
In cases where our Services are used by anyone under the age of 16, the relevant age of adulthood, or another age to which restrictions apply under applicable law (a Child or Minor), the provisions of this Policy concerning the processing of personal data of such data subjects shall take precedence over other general provisions.
Other provisions of the Policy shall apply only to the extent that they do not conflict with these specific rules, or may apply subject to the verified consent of a parent or legal guardian, where such consent is required by the applicable law.
INFORMATION WE PROCESS
When you use the Service, we may collect information about the performance and efficiency of the Service as a whole and its individual components, whether through the Service or through social networks. When you choose to connect an Application to your social network profile, Smart Project GmbH may collect and record the publicly available information you provide to Smart Project GmbH, including your User ID and your friends’ User IDs.
Some of the information described in this section may be collected or processed differently when the Service is used by anyone under the age of 16, the relevant age of adulthood, or another age to which restrictions apply under applicable law (a Child or Minor), and the scope of data collected may be limited in accordance with applicable laws and platform rules.
In accordance with the requirements of applicable regional laws, Smart Project GmbH may collect and receive aggregated information about the user’s age category.
Where the Play Age Signals API or other age signals, age-verification mechanisms, or parental consent verification mechanisms made available through app stores or other platforms are implemented, Smart Project GmbH may receive age category information, age signals and, where applicable, parental consent status from such platforms, without directly requesting any personal data.
Such information is used solely for the purposes of age identification, legal compliance, safety-related features and default settings intended to protect child and minor users, and, where applicable, verification of parental consent requirements.
Smart Project GmbH does not use the Play Age Signals API or other age-related signals provided by platforms for advertising, analytics, or profiling purposes except to the extent necessary to prevent certain categories of ads from being displayed or to disable ad personalization for children and other users who have not reached the applicable age of digital consent, or to comply with applicable child-safety, privacy, legal, or platform requirements.
Smart Project GmbH does not retain age-related signals received from app store providers or other platforms for longer than necessary for the purposes described above, unless a longer retention period is required or permitted by applicable law for security, fraud prevention, prevention of criminal activity, protection of the Application, users, or the relevant platform ecosystem, or compliance with legal or platform requirements.
Age information obtained through other means is not retained for longer than necessary to fulfill legal obligations, ensure compliance with applicable laws, or enforce technical restrictions, in accordance with applicable platform requirements.
We do not request access to your device contacts or address book, and we do not collect, upload, sync, store, scan, read, copy, or transmit your contact list. Any social graph information, such as friends’ user IDs, is obtained exclusively through the official APIs of connected social networks, where available, for example Facebook Graph API or Google Sign-In, and does not involve accessing, reading, copying, or transmitting the contacts stored on your device. If this changes in the future, we will update this Privacy Policy, explain what contact information may be accessed or processed and for what purpose, and, where required by applicable law, request your consent or use a system-provided contact selection tool, such as the Android Contact Picker.
SOURCES OF PERSONAL DATA
We may obtain your personal data from the following sources:
a) from you directly (through the game, website, or online forms); and/or
b) from other entities and service providers that assist us in providing you with the Service (including data analytics providers, operating systems, and internet service providers), or from your social network accounts that you used to sign in to our online services (for example, Facebook, Google).
Personal Data We Process That You Provide to Us: contact information (such as name and email address), username, gender, date of birth, age group, player name and password, profile information (such as profile photo), your messages to the Service (such as chat logs and player support tickets), other data you choose to give us (such as data to identify a lost account).
We may also collect and process information contained in content you create, submit, upload, communicate, or otherwise make available through the Service, including feedback, reviews, messages, support requests, and other user-generated content, in order to operate, moderate, support, secure, analyze, and improve the Service, enforce our Terms, comply with applicable law, and pursue our legitimate business interests, including understanding, measuring, and demonstrating user satisfaction with the Service.
Your username, User ID, and profile photos are collected if you have made them public and can be seen by anyone, including people outside the relevant social network. The first time the Service connects to a social network, we may receive information about your preferred language and approximate location. If you connect the Service to the social network, we may collect information you shared with the network, store it and keep it updated. The Service may update its records about your basic information including your age group, language and approximate location.
Data we collect automatically: information about your account and game progress, your IP address and mobile device identifiers (such as your device ID, advertising ID), data about your device, such as device name and operating system, browser type and language, data we collect with cookies and similar technologies, general approximate location data, data about your use of the Service (such as gameplay data and your interactions with other players inside the Service), purchase history, including details of orders (purchase ID, amount spent, currency, date, time, vouchers or offers used), your email address and your messages to the Services (such as chat logs and player support tickets sent by email or through the Helpshift service (or another service we may use in the future) any feedback you submitted about your experience with us; and/or other data you choose to give us. We may also create a game-specific ID for you when you use the Service.
Our apps may include technologies that can collect information from your device. For example, our apps include software development kits (SDKs), which are tools that enable certain functions, such as allowing us to analyze the performance of our apps or to show you advertising in our apps.
On iOS devices, we request your permission before accessing your device's advertising identifier (IDFA) through Apple's App Tracking Transparency (ATT) framework.
A prompt will appear when you first launch the application asking whether you consent to tracking across apps and websites owned by other companies.
If you grant permission, we may use your IDFA to deliver personalized advertisements and measure advertising effectiveness.
If you decline permission, we will not access your IDFA. You will still see advertisements, but they will not be personalized based on your cross-app activity.
You may change your tracking preference at any time in your device settings.
We do not use device fingerprinting (i.e. we do not combine device signals such as IP address, device model, screen resolution, or other parameters to create a persistent identifier as a substitute for the IDFA) without your consent.
Data we collect from our partners: information we receive if you connect the Service to a third-party tool (such as Facebook, Game Center or Google, social networks) including your social network profile, your User ID and your friends’ User IDs, demographic data (such as to determine the approximate location of your IP address), data to fight fraud (such as refund abuse in games or click fraud in advertising), data from platforms that the games run on (such as to verify payment), data for advertising and analytics purposes, so we can provide you with a better Service.
We may receive or process platform verification data, including license or entitlement checks, to confirm that the Application or purchased content is validly installed, accessed or purchased.
Also, when it is applicable, we may receive age-related signals or age-range information from platform providers, such as Google Play, to help provide age-appropriate experiences and comply with applicable legal requirements. We do not receive the user's exact date of birth through these signals.
We collect technical data related to an End User’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier, unique identifiers that generally only identify a computer, device, browser or Application: IP address (which may also provide general approximate location information), User agent, identifier for advertisers, Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers.
We do not access your device's GPS, network-based location, or any other precise location service. The only location-adjacent information we collect is your approximate geographic region, derived from your IP address (for example, country or city level). This information is used solely for fraud prevention, age-appropriate content delivery, and compliance with jurisdiction-specific legal requirements. It is not used for targeted advertising or shared with advertising partners in a form that identifies your location.
We may collect and process information relating to our advertising campaigns, our applications, and applications, products or services that we publish, distribute, or promote, as well as End User actions and interactions in connection with them, such as: clicks on ads, ad impressions viewed, the type of ads shown, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application visited by an End User, the URL from the referring website, the application or, where applicable, website from which such ads were displayed, downloads and installations of Applications, and other interactions, events and actions that we choose to measure and analyze within our application or website, such as clicks, add to cart, in-app purchases made, clicks, engagement time, in-app purchases, feature use, or other in-Service events etc.
If you have consented to future payment processing related to any of our products and if We would processed it, We may collect required personal data to process renewal payments or subscriptions, such as the End User’s: bank account information, credit or debit card information, name and address, email address for account identification, preferences for particular services, if they can be considered personal information, personal data required to process future payments.
INFORMATION THE THIRD PARTIES PROVIDE US
We receive information about you from your friends on social networks as soon as they start using the Service and connect it to their profiles.
OTHER INFORMATION WE OBTAIN
The Service has access to information required to provide and enhance the Service to enable Users to enjoy the Service and for the Service to work properly. We obtain and update information about you each time you interact with the Application, for example, when you start the Service, collect a bonus, or make a micro-transaction via the Service.
Information regarding billing, a user's account, a user's Internet connection and the Smart Project GmbH software installed on a user's computer is uploaded to the server in connection with the user’s use of the Service. Service software automatically generates and submits to Smart Project GmbH bug reports upon a crash or other fault in the Service. This automatically generated bug report information may include information about other software or hardware on a user's system. We do not associate and store the automatically generated bug report information with users’ personally identifiable information. Any bug reporting information manually submitted by users (e.g., through a bug reporter form) is associated and stored with personally identifiable information sent voluntarily by the user through a bug report.
The Service may provide chat rooms, forums, or instant messaging tools to users where such functionality is technically available. If such features are made available, any information that is disclosed in chats, forums, etc. should be considered public information, and users who message one another may not know each other personally. Smart Project GmbH has no obligation to keep private personally identifiable information that a user makes available to other users or the public through these functions. Users should exercise caution when deciding to disclose personal information in public forums. Users should also be aware that gameplay information disclosed during multiplayer gameplay (e.g., player name and current player statistics) is public information and may be displayed to other users.
METHODS BY WHICH USER DATA MAY BE PROCESSED
We collect data when it is provided voluntarily, when the User integrates SDKs, APIs, pixels, redirect links, JavaScript tags, cookies, or similar data collection technologies into their Applications, websites, and/or ads, and from the various advertising networks and third parties used by the User in connection with the measurement and analysis of User marketing campaigns and partnered with Smart Project GmbH.
WHY DO WE PROCESS YOUR DATA
We may collect data to make the Service work, to create accounts and allow you to use our Service, operate the Service, verify and confirm payments, provide and deliver products and services you request, send you Service-related communications, and make the Service more suitable for our players.
We may use and share your personal information to provide you with our products or services (for example, play any of our online games and make online purchases); to communicate with you; to offer you additional products or services, including targeted promotions; to personalize your experience with us, including by reviewing and analyzing your information; and to manage our business including our credit and other risks. Our lawful basis for doing so is contractual necessity, consent, and our legitimate interests, as applicable.
We may use your personal data to send you marketing communications via email.
Our lawful basis for doing so is consent.
We may use your personal data to:
Our lawful basis for doing so is Legitimate Interest.
Our legitimate interests in doing so are:
To provide a better Service to our players, we have a legitimate interest to collect and process necessary data to: update and develop player profiles, develop and improve the Service and player experience, manage our relationship with you, provide social features as part of the Service, customize your Service experience, respond to your comments and questions and provide player support, provide you with offers in the Service as well as on other websites and services, and by email, send you related information, such as updates, security alerts, and support messages, enable you to communicate with other players, display advertisements and promotional offers that are relevant to your in-Service activity and the context of your use of the Service, measure your in-Service activity and interactions with the content, advertisements and offers you access or use within the Service, deliver and select such advertisements and offers based on the context of your use of the Service, manage their frequency, and improve our advertising and the Service. Where applicable law requires consent for email marketing, advertising, tracking technologies or similar communications, we will request such consent before carrying out the relevant processing. For information on how to manage your advertising and marketing choices, see section “YOUR RIGHTS AND OPTIONS” below.
If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in section “Contacts”. If we use your email to communicate marketing information, we will seek your prior consent if required to do so by law.
We do not knowingly collect or solicit directly identifying personal data from anyone under the age of 16, the relevant age of adulthood, or another age to which restrictions apply under the applicable law of your country (hereinafter also “age with restrictions”). We also do not direct or target interest-based advertising at such persons unless and until verifiable parental or legal guardian consent is obtained, and we do not knowingly allow such persons to use our Services without any consent required by applicable law. If you are under the age of 16 or another age to which restrictions apply, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 or another age to which restrictions apply may provide any personal data. If we learn that we have collected directly identifying personal data about a child under the age of 16 or another age to which restrictions apply, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16 or another age to which restrictions apply, please contact us.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of the Service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.
Smart Project GmbH generally retains personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. Where personal data is collected or processed through advertising, analytics, or attribution services, such data may be retained for limited periods determined by Smart Project GmbH or its service providers, typically for up to two years, unless the data is deleted earlier upon a valid user request or is required to be retained for legal, security, fraud prevention, dispute resolution, or contractual purposes.
Also We may retain certain categories of data notwithstanding an erasure request, as required by law. These include:
HOW WE USE THE PROVIDED INFORMATION
We use the obtained information about you only to provide the features and Services you request, to keep the Service and its social features safe and fair, to fight fraud and otherwise ensure acceptable use. No personal information is provided to a third party unless otherwise specified herein.
We do not collect more personal information from children than is reasonably necessary to use our Apps.
Smart Project GmbH collects, uses, and shares persistent identifiers (digital tags that are specific to a user’s device) through our Apps solely to support the internal operations of the Apps, or as otherwise permitted by the Children’s Online Privacy Protection Act (COPPA) and other applicable data protection laws. This information may be collected by Smart Project GmbH or by another organization that provides services to Smart Project GmbH.
Some of our Apps include advertising display technology provided by our service providers (via SDKs), which allows ads to be temporarily loaded into the game and displayed while a user is playing. Data collected for this purpose, often through “persistent identifiers”, may be used for ad attribution and related internal operations, such as enabling our service providers to calculate the number of ad views, limit ad frequency, and serve ads in a format appropriate for the device. Although our Apps may include contextual ads about Smart Project GmbH or the products and services of another organization, we prohibit behavioral advertising to children in our Apps or through data collected from our Apps.
We work with AppLovin to deliver ads. For more information about AppLovin’s collection and use of your information, visit: https://www.applovin.com/privacy/. Personalized ads are disabled for users under the age of consent. Ad SDKs operate in limited-data mode where applicable.
We do not share any personally identifiable information with other parties except as described in this policy. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. We may share anonymous data, aggregated or not, with third parties.
We do not share or disclose your data with any third party, except: upon User’s request, we have notified you, in particular through this Privacy Policy, to our subsidiaries as necessary to help us support and maintain the Services provided to Users; to our service providers who help to support our Services – such as data hosting providers and payment processors; when legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements; to respond to, or prevent, fraud or to protect the safety of Smart Project GmbH, its Users, End Users or the public; as part of any merger or acquisition of Smart Project GmbH, in which case your data may be transferred to the surviving or acquiring entity.
Your User ID allows personalization of your interaction with the Service, bringing together your profile in the Service with your profile in a social network. We also use the information about you for internal application management: for eliminating errors, data analysis, validation, research and improvement of the application functionality.
Personally identifiable information is used internally by Smart Project GmbH to deliver, develop and improve products, content and services, to answer users' requests, to establish matches between devices used by you; to detect fraud and to ensure more accurate attribution measurement and ad fraud protection for Users using the Services. In addition, we may allow third parties performing services under contract with Smart Project GmbH, such as order or payment processors, merchandise warehouse services, or fulfillment services located in and outside the European Union, to access and use personally identifiable information, but only to the extent necessary to provide the Service.
We may use data provided by users to send them information about Smart Project GmbH, including news about product updates, contests, events, and other promotional materials, but only if users agree to receive such communications.
PARENT’S GUIDE
We provide the best gaming experience for all ages that is compliant with the law and with industry standards. This guide is designed to provide parents and other legal guardians with information about safety in our games.
Please be assured that the Company abides by the following rules and principles:
If you have any questions regarding underage players, kindly contact us as described in section “Contacts” below.
In order to play our game, you must download the game application from your respective store (various mobile and PC platforms) or access the game via your internet browser.
What are the age limits and target audience for our game?
Our game is designed for everyone and does not contain any content that might be regarded as mature. However, as stated in our Terms of Use, players must be at least 16 years old or another age to which restrictions apply to access and/or use our games. Also access to and use of certain features of our games may be limited by age, local law, platform rules, or parental consent requirements. If a player is a minor who is over the age of 16 or another age to which restrictions apply, we recommend seeking consent from a parent or legal guardian before accessing and/or using our website or games.
Our game pages displayed in online stores such as Google Play or Apple’s App Store also contain information about age recommendations. Kindly note that these age ratings also depend on the stores’ policies and on local legislation, which is why they may differ from our Terms of Use.
Aspects of data processing, especially with regard to underage individuals
While this Privacy Policy covers all the necessary information and provisions, we have decided to clarify certain aspects of data processing, especially with regard to underage individuals.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising at anyone under the age of 16 or another age to which restrictions apply, nor do we knowingly allow such persons to use our Services. If any player is under the age of 16 or another age to which restrictions apply, we ask them not to send any data about themselves to us, including their name, address, telephone number, or email address. No one under the age of 16 or another age to which restrictions apply may provide any personal data. If we learn that we have collected personal data about a child under the age of 16 or another age to which restrictions apply, without their parent or legal guardians consent, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16 or another age to which restrictions apply, please contact us as soon as possible via the in-game customer support interface or at support@smartproject.com.
Depending on the context of use of the Service, we may rely on age-related signals or other reasonable measures to determine whether special child protection safeguards should apply. The specific methods used for this purpose may evolve over time in response to legal, technical, or platform requirements, including requirements to obtain parental consent where required by applicable law.
Such measures are used to ensure compliance with child protection requirements, data protection laws, and platform rules, and do not involve the collection of a user’s exact date of birth unless expressly stated otherwise.
Our Privacy Policy contains a full list of the personal data that we may collect: from you directly (through the game, website, or online forms); and/or from other entities and service providers that assist us in providing you with the Service (including data analytics providers, operating systems, and internet service providers), or from your social network accounts that you used to sign in to our online services (Facebook, Google, etc.). Please note that we process personal data only to provide you with our services, fulfill our duties under contractual o
REAL NAME AND USERNAME
As part of your registration for our Services, or via login or social networks, we may collect certain data, such as your name or nickname and email address.
However, it is not necessary to use your real name as your username within the game, and we strongly recommend not doing so.
Instead, we encourage our players to choose a nickname not directly related to their real-life identity to increase security and privacy. You can also change your username in the in-game settings.
Can I delete personal data?
Under the General Data Protection Regulation, you have the right to have all of your personal data or your children's data used in our application and our partners' services deleted (foe example purchase payments, in-app ad views, etc.). Please keep in mind that should you decide to delete the data, your user account will be deleted and cannot be restored. However, it will be possible to start the game over from the beginning.
Under the California Consumer Privacy Act, California residents have the right to opt out of the sale of personal information. Please keep in mind that opting out doesn't mean that you will stop seeing ads. You may opt in at any time by contacting our support team.
You can also delete data received from third parties/platforms. In this case, you or your children will lose the ability to use the functions provided by the third parties/platforms, but your account will not be deleted.
For more detailed instructions, you can contact our customer support.
Is the game free to play?
While our games are free to download, they do contain in-app purchases. You can play entirely for free, but making purchases can help you speed up your progress and increase your in-game resources.
You can limit or disable in-game purchases in your device's settings. The exact process depends on the type of device the game is installed on, whether it is an iOS device (iPhone, iPad, etc.) or an Android device.
Check the following articles to learn more about how you can protect yourself from unwanted in-game purchases:
My child accidentally made an in-app purchase. Can I get a refund?
All purchases are processed by the store where you downloaded the game, so please contact the store's customer support to request a refund.
If the purchase was made on an iOS device:
Go to the App Store Support page, select the link for "Get help with your purchases and refunds," and find the option that best suits your situation.
If the purchase was made on an Android device:
Go to the Google Play Help page, Amazon Appstore support page or Huawei App Gallery support page and follow the instructions for your device.
I am seeing an inappropriate ad. What can I do about it?
In our games, players have the opportunity to receive in-game resources in exchange for watching video ads from our partners.
We configure ad serving through third-party advertising partners with age restrictions in mind and apply commercially reasonable measures to have ads filtered in line with the age rating of our games. However, individual ad content is created and provided by advertisers and ad networks, so we cannot guarantee that every ad will fully comply with the applicable age rating.
However, if you come across video content that you think doesn't correspond to the age rating of the game, you can let us know by contacting us through the game settings and providing a screenshot of the ad. It's best if the screenshot also shows the name of the application that the ad is promoting.
Our Customer Support specialists will process your request and take all necessary measures to resolve the problem.
How can I contact you?
The fastest and most convenient way to contact us is to do it through the game settings. That way, we'll have all the technical information we need to resolve any issues quickly. Depending on the nature of the problem, please make sure that your message includes the following: the time the incident occurred, copies of transaction receipts or the purchase history, screenshots showing the problem, etc.
If you are not familiar with our games, please contact us at support@smartproject.com, where you can receive answers to common questions.
Safety tips
Our main priority is creating a safe space for all players in order for them to have a great time playing our games. If you have any concerns regarding one of our games and your child, please contact us. Here are a few tips you may find helpful:
We hope that these simple rules will make your family's gaming experience even more enjoyable!
AGE LIMITS
When you use or access our Services in any capacity, you represent that you are at least the minimum age to consent for data processing under applicable law of your jurisdiction, and not barred from accessing the Services under applicable law. Notwithstanding the foregoing, we may provide some Services that are available to younger players as permitted under applicable law. Regardless, if you are under the age of 16 or another age to which restrictions apply, you hereby agree that you have received permission from a parent or guardian to use our Services, and your parent or guardian must agree to the terms of all applicable policies and accept them on your behalf. Parents and legal guardians are responsible for the acts of their children when they use our Services. A parent or legal guardian is responsible for supervising the child’s use of the Service, including installation of the Service on a device, use of the device, and the accuracy of age-related information provided in connection with the use of the Service. If you access our Services through a third-party platform or site, you may be required to comply with their policies in addition to this Policy.
Note that we do not have any knowledge of sales or sharing of personal information of minors. While our Services may allow you to create an account, we do not otherwise use or disclose any sensitive personal information.
Smart Project GmbH will not knowingly collect personally identifiable information from any person under the age of 16 or another age to which restrictions apply. We do not knowingly collect or solicit personal data about or direct or target interest-based advertising at anyone under the age of 16 or another age to which restrictions apply or knowingly allow such persons to use our Service. If you are under 16 or another age to which restrictions apply, please do not send any data about yourself to us, including your name, address, telephone number, or email address. We encourage parents to instruct their children to never provide personal information.
If we learn that we have collected personal data about a child under the age of 16 or another age to which restrictions apply, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16 or another age to which restrictions apply, please contact us. No one under the age of 16 or another age to which restrictions apply may provide any personal data.
If you are a parent or guardian of a minor and believe that minor has uploaded personal information in connection with our Services without your consent, or if you wish to review information collected from your minor child, or have that information modified or deleted, you may contact us as described in “Contact Us” below.
If we become aware that a minor has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and move them to the underage experience, if applicable..
Access and Privacy in the Application for Children and Minors
We recognize the importance of protecting the personal data of anyone under the age of 16 or the relevant age of adulthood or another age to which restrictions apply under applicable law (a Child or Minor).
The Application implements a two-tier access model that allows users to access basic features without the processing of personal data, while also ensuring compliance with applicable privacy laws in relevant jurisdictions:
1) Standard Access.
After installing and launching the Application, anyone, including persons under the age of 16 or the relevant age of adulthood or another age to which restrictions apply under applicable law may access basic features (such as the game interface, gameplay, and core mechanics) without any collection, processing, or transmission of personal data, except for limited information that may be collected or processed solely to support the internal operations of the Service. Such limited information may be used only as necessary to operate and maintain the Service, ensure its security and integrity, provide contextual advertising, limit the frequency of advertisements, prevent fraud, debug errors, and perform other technical functions necessary for the proper operation of the Service.
2) Extended access with consent (where required by law).
Additional features that involve the processing of personal data, include, but are not limited to:
– in-app purchases,
– content or advertising personalization,
– communication with other users,
– the use of analytics technologies.
In cases where applicable law requires that a user reach a certain age and/or that consent from a parent or legal guardian be obtained in order to access such features, the provisions set out below shall apply.
In the absence of information indicating otherwise, we may rely on the age information provided to us by the user until such time as we become aware, or reasonably determine, that the user is below the applicable age of digital consent and requires consent to be obtained.
If required under applicable law, we may request anyone, including persons under the age of 1verified consent from a parent or legal guardian before granting underage users access to such features. Such consent is requested only in cases and to the extent that it is a mandatory requirement under the law applicable to the specific situation, jurisdiction, or user.
If we receive such information and determine that such consent is required, the relevant features will only be activated after verified consent from a parent or legal guardian has been obtained in the form explicitly required by the law applicable in the given context and as defined by this Policy.
If we become aware that a user below the applicable age of digital consent has accessed such features in circumstances where verified parental or legal guardian consent was required but had not been obtained, we may suspend or restrict access to the relevant features, request the necessary consent, and/or delete or otherwise process the related personal data in accordance with applicable law and this Policy, and the consequences described in the section “Can I delete personal data?” may also apply to such situations.
UK AGE APPROPRIATE DESIGN CODE (CHILDREN'S CODE)
In designing our Service for users in the United Kingdom, we apply the standards of the UK Age Appropriate Design Code (Children's Code) to the extent applicable. This means that: privacy settings for Users under 18 are set to the most protective level by default; we do not use design features that encourage children to provide more personal data than necessary; and we do not use techniques designed to keep children engaged beyond what is in their best interest.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature, and your personal data may be transferred to, stored in, or otherwise processed in countries other than the country in which you are located or in which the data was originally collected. These countries may have data protection laws that differ from the laws of your country.
Where we transfer personal data internationally, we do so in accordance with applicable data protection laws and rely on appropriate transfer mechanisms and safeguards. These may include adequacy decisions, standard contractual clauses, transfer impact assessments, supplementary technical, contractual and organisational measures, or other lawful mechanisms available under applicable law.
CROSS BORDER TRANSFERS AND EU-US AND SWISS-US
For transfers of personal data from the European Economic Area, we may rely on an adequacy decision adopted by the European Commission, including the EU-U.S. Data Privacy Framework where the recipient in the United States is duly certified and the certification covers the relevant data and processing activities. Where no adequacy decision or applicable certification mechanism is available, we may rely on the European Commission’s Standard Contractual Clauses, together with a transfer impact assessment and any supplementary safeguards required under applicable law.
For transfers of personal data from Switzerland, we may rely on an applicable adequacy decision, including the Swiss-U.S. Data Privacy Framework where the recipient in the United States is duly certified and the certification covers the relevant data and processing activities. Where no adequacy decision or applicable certification mechanism is available, we may rely on appropriate safeguards recognised under the Swiss Federal Act on Data Protection, including standard contractual clauses adapted as necessary for Swiss law.
TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPIAN ECONOMIC AREA
For transfers of personal data from the United Kingdom, we may rely on the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, a UK adequacy regulation, or another lawful transfer mechanism recognised under UK data protection law, as applicable. The EU-U.S. Data Privacy Framework alone does not apply to UK-originating transfers; we use the UK-US Data Bridge where applicable.
For transfers of personal data from Brazil, we may rely on transfer mechanisms recognised under the Brazilian General Data Protection Law (LGPD) and the international data transfer rules issued by the Brazilian National Data Protection Authority (ANPD), including, where applicable, adequacy decisions, ANPD standard contractual clauses, equivalent standard contractual clauses, specific contractual clauses, binding corporate rules, or another lawful mechanism permitted under Brazilian data protection law.
Before transferring your personal data to recipients in countries other than Japan, we confirm that the recipient country's data protection system has been assessed by Japan's Personal Information Protection Commission (PPC) (country list available at: ppc.go.jp), or we ensure equivalent protective measures are in place through contractual safeguards.
We may share personal data with our affiliates, vendors, service providers, suppliers, advisers, consultants, law enforcement authorities, courts, tribunals, tax and social security authorities, and other public authorities where this is necessary for the purposes described in this Policy and permitted by applicable law.
Where we engage vendors or service providers to process personal data on our behalf, we require them to process such data only in accordance with our instructions, to protect its confidentiality and integrity, and to apply appropriate security and data protection safeguards. All these recipients are themselves responsible to comply with the EU data protection rules. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
Where personal data is transferred outside the EU/EEA and the transfer is not covered by an adequacy decision adopted by the European Commission, we rely on lawful safeguards under Article 46 GDPR. These may include the European Commission’s Standard Contractual Clauses, transfer impact assessments, additional contractual safeguards, and supplementary technical and organisational measures, such as encryption, pseudonymisation or other appropriate security measures, where required or appropriate.
You may request a copy of these agreements by contacting us using the email address in the Contact section below.
Please feel free to contact us for additional information on third country data transfers as well as our safeguards and supplementary security measures.
WHO CAN SEE YOUR DATA
Apart from Smart Project GmbH, your data may be accessed by: other players and users who may, for example, see your profile data, in-game activities and read the messages you have posted; our partners who perform services for us. These partners process your data only according to our instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention; in order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
Our Partner Organizations and Service Providers.
We may disclose information about you to organizations that provide a service to us, and/or otherwise collect, use, disclose, store, or process information on our behalf for the purposes described in this Privacy Policy (for example, to process purchases, perform data analytics, support marketing and advertising, host websites, and provide technical support), ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
a) technical support providers who assist with our website and IT infrastructure,
b) cloud hosting, software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
c) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
d) providers that help us generate and collate reviews in relation to our goods and services;
e) our advertising and promotional agencies, advertising partners, analytics providers, attribution providers, advertising technology providers, ad mediation providers, monetization partners, and providers that help measure campaign performance, deliver advertising, prevent advertising fraud, and support advertising-related monetization, and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you. A list of such partners is disclosed in the consent notice presented to you, where you can review the relevant partners and manage your choices; and/or
f) service providers that assist us in providing our services;
g) infrastructure, payment processing, customer support, security, fraud prevention, and other technical or operational service providers that assist us in hosting, operating, securing, supporting, and maintaining our Services;
h) law enforcement or government bodies.
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
Information regarding categories of recipients and, where applicable, certain third-party partners may be made available through our consent interfaces, in-game privacy settings, or other resources referenced in this Privacy Policy.
We disclose personal data only where permitted by applicable law and only to the extent reasonably necessary for the purposes described in this Privacy Policy.
Notwithstanding the foregoing, Smart Project GmbH may share or disclose information that does not identify you (including information that has been aggregated and de-identified) with other parties, except where prohibited by applicable law.
We do not currently share personal data with third-party AI service providers or process personal data through such providers. If this changes, we will update this Privacy Policy, clearly explain what personal data may be shared or processed through third-party AI service providers, identify the relevant recipient or category of recipients, describe the purpose of such sharing or processing, and obtain your explicit permission before any such sharing or processing where required by applicable law or platform rules.We are committed to protecting Our users' personal data and are among other things using
YOUR RIGHTS AND OPTIONS
Under the GDPR, and subject to any conditions, limitations, or additional rights provided by the applicable laws of your country, You have certain rights concerning Our processing of Your personal data.
If you are located in the United Kingdom, this Privacy Policy also applies to you under the UK GDPR (the General Data Protection Regulation as retained in UK law). Your data subject rights under the UK GDPR are equivalent to those described in this Policy for EU/EEA users.
If You would like to access, correct, erase or limit the use or disclosure of any of Your personal data that has been collected and stored by Us or exercise any other right under applicable data protection legislation, please notify Us at support@smartproject.com so that We may consider and respond to Your request in accordance with applicable law.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. You can opt-out of interest-based advertising on mobile applications by sending the request to our e-mail mentioned herein. To opt out of personalized in-game offers opt-out, you can use the options provided in the game settings. You also have the right to correct your data, have your data deleted, and object to restricting how we use or share your data.
You have the following rights: to withdraw any previously provided consent; to access certain information about you that we process; to have us correct or update any Personal Information; to have certain Information erased; to have us temporarily block our processing of certain Information; to have Information exported into common machine-readable format; to object to our processing of Information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis for processing your information; and to lodge a complaint with the appropriate data protection authority.
As a data subject, you have the following rights which provided GDPR: right to obtain information in relation to your personal data; right to access your personal data; right to data portability; right to withdraw the consent; right to correct mistakes in your personal data; right to stop the unwarranted processing; right to be forgotten (erase your personal data); right to be aware of the existence of the automated individual decision-making and to object in this regard; right to lodge a complaint to a supervisory authority.
You can access your personally identifiable data we collect once you have authenticated your identity at any time directly within your account settings section. If you are unable to perform these actions yourself, please contact us for assistance. This also enables you to receive a copy of the personal data we hold about you. We may refuse or limit your request to access personal data if we believe that the information may adversely affect the rights or freedoms of others, such as if the data includes trade secrets or intellectual property rights.
We will respond to all requests within a reasonable timeframe set out under applicable laws. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us immediately as described in this Privacy Policy. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions: (1) Your request should be in writing; (2) Provide sufficient information to enable Smart Project GmbH to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.
We rely on user game account access to verify the user identity and avoid unauthorized logins. Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request.
We have the right to refuse to process requests that are not meaningful, vexatious, or unclear, requests that damage others’ privacy rights, extremely unrealistic, manifestly unfounded or excessive requests, requests that require disproportionate technical work, and requests not required under local law, information that has been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.
You are entitled to obtain information from us about how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected, or deleted from our systems. You can also limit, restrict or object to the processing of your data.
We do not carry out any decision-making based solely on automated processing, including profiling.
If you gave us your consent to use your data, e.g., so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.
You can object to our use of your personal data where we have stated that we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in relevant sections above.
If you would like to exercise any of your above rights, you may contact us as set forth in the Contact section below.
COOKIES AND SIMILAR TECHNOLOGIES
Like most online services, we and our partners may use cookies and similar technologies to provide and personalize the Service, analyze use, target advertisements, and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.
What is a cookie?
A cookie is a small file that is stored on a user's computer for record-keeping purposes. Cookies themselves do not identify you, as they are only designed to identify the device and browser when you visit the website again. In this case, only the cookies already available on your device will be used.
We use cookies and similar technologies to collect information about the use of our websites in order to make them function effectively and also to improve your experience when you browse our websites or play web versions of our games.
Types of cookies that we use
Cookies on our websites belong to one of the following categories:
Third-party cookies
Cookies may be either first-party cookies or third-party cookies. First-party cookies are cookies set directly by us to your device. Third-party cookies are cookies set by a third-party provider on our behalf.
When you visit our websites, third-party organizations may place cookies on your browser. These cookies may inform third-party organizations about your visit to our websites, which may be used by those organizations to deliver targeted messages and advertising to you. We do not control third-party cookies and cannot access them due to the way cookies work, as cookies can only be accessed by the party who originally set them.
Such cookies are subject to third-party organizations’ own cookie policies. Please read their privacy policies to ensure you are comfortable with how they use cookies.
How long will cookies remain on my device?
Please check your Cookies Settings for details.
Links to other websites
Our websites may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy or security practices of such other websites.
How to manage cookies using your browser
You can control and manage cookies in various ways. Insofar as cookies we use are not essential for the provision of our websites, we will ask you to consent to our use of cookies when you first visit our websites. You do not have to accept all of the cookies used by our websites. Consent can be provided or revoked by clicking on Cookies Settings at the bottom of this page. Please keep in mind that if you reject cookies, you may still use our websites, but your ability to use some areas of our websites will be limited and you may need to re-enter your personal data when you register.
You may also be able to change your browser settings to manage and control cookies. Your browser or device may be configured to allow you to refuse or delete cookies or to be notified when a cookie is stored on your device. To change your web browser or device settings for cookies, you can follow the instructions in the help section of your web browser.
Changes to this Cookie Notice
We may modify or amend this Cookie Notice from time to time at our discretion. When we make changes, we will update the "Last modified" date at the top of this page.
We advise you to periodically review this Cookie Notice and our Cookie Policy to be informed about how we use cookies.
To learn more about cookies, please read our Cookie Policy and visit All About Cookies.
To learn more about behavioral advertising and how to control your interest-based advertising preferences, you can review the following resources:
SECURITY
Smart Project GmbH is concerned with safeguarding your information. We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure and we audit our security measures and assess that they remain effective and appropriate. These measures include, among others:
Our employees with access to Personal Data are subject to confidentiality obligations. Our employees who have access to your information are made aware of the importance of keeping it secure and confidential. We use contracts and other measures with our subcontractors to maintain the confidentiality and security of your information and prevent it from being used for any other purpose other than that for which it was intended.
We cannot guarantee the absolute security of your Personal Data and do not accept liability for unintentional disclosure resulting from circumstances outside our reasonable control. If you have reason to believe that your data has been compromised, please contact us immediately as described in the Contacts section.
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
Smart Project GmbH will retain your data for as long as your account is active or as needed to provide you with the Service. Generally, this period equals the period you use the Service or have an application installed on your mobile device or PC. For example, we will periodically de-identify unused game accounts, and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. We shall delete your data upon a valid request to delete it.
Personally identifiable information provided to Smart Project GmbH by customers in the EU is controlled by Smart Project GmbH, with its place of business set out below. Personally identifiable information provided to Smart Project GmbH will be collected, processed, and stored by Smart Project GmbH in Switzerland and Germany.
DATA BREACH NOTIFICATION
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and, where required by applicable law, within the following timeframes:
EU/EEA (GDPR): notification to the competent supervisory authority within 72 hours; notification to affected users where high risk is identified.
Brazil (LGPD): notification to the ANPD and affected users within 3 business days.
Australia: notification to the OAIC and affected individuals where serious harm is likely.
Notifications will include: the nature of the breach; categories and approximate number of individuals affected; likely consequences; and measures taken or proposed.
If you suspect your account has been compromised, please contact us immediately at support@smartproject.com.
ADDITIONAL INFORMATION FOR USERS IN SWITZERLAND (nFADP)
Under the Federal Act on Data Protection (nFADP) Swiss residents have the same rights as under the GDPR. Also under nFADP Swiss residents have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC): edoeb.admin.ch .
ADDITIONAL INFORMATION FOR RESIDENTS OF JAPAN
This section supplements our Privacy Policy for users in Japan under the Act on the Protection of Personal Information (APPI), as amended effective April 1, 2022.
In addition to the rights described above, Japanese users have the right to:
To exercise your rights under the APPI, please contact: support@smartproject.com.
Smart Project GmbH is an international company with headquarters in Switzerland. We are the rightsholder to all our games, websites and related services.
As an international company we may entrust processing of personal information of our players and users to our subsidiaries in order to achieve the purposes stated in our Privacy Policy.
Additionally, we have commercial partners providing us marketing, advertising, support, and hosting services to which we similarly entrust processing of personal information of our players.
Likewise, we have required our subsidiaries and partners to meet these requirements in their personal-information-processing activities. To ensure the security and confidentiality of personal information during processing, our subsidiaries and partners have implemented legal, technical and organizational measures as described in our Privacy Policy.
Where we transfer your personal information outside Japan, we rely on one or more of the following mechanisms under Article 24 of the Act on the Protection of Personal Information (APPI):
(a) the recipient country has been assessed by Japan's Personal Information Protection Commission (PPC) as providing equivalent protection (see ppc.go.jp for the current list); or
(b) we have entered into contractual arrangements with the recipient that require them to implement measures equivalent to the standards required under the APPI; or
(c) where neither (a) nor (b) applies, we will obtain your separate, specific, informed consent before transferring your personal information, as described below.
Where we rely on your consent under (c), such consent is obtained through a dedicated notice presented prior to the relevant transfer, identifying: the name or category of the recipient, the country of destination, the purposes of the transfer, and the categories of personal information to be transferred. You may withdraw your consent at any time by contacting support@smartproject.com, and withdrawal will not affect the lawfulness of transfers made before withdrawal.
You may request details of the contractual safeguards we rely on by contacting us at support@smartproject.com.
By accepting our Terms of Use and Privacy Policy, you provide your consent to transfer personal information to our subsidiaries and partners in these countries as specified herein.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Privacy Policy
In this section, we provide additional information about how we handle personal data about California residents as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
A. Categories of Personal Data Under the CCPA
In this section we describe, generally, how we have collected and disclosed personal data about you since the Last Updated date above. As noted above, the data that we collect about you varies depending on your relationship with us. We may collect personal data from the following sources:
The table below identifies the categories of personal data (as defined by the CCPA) we have collected about you, as well as how we have sold such information or disclosed it for a business purpose. For more information about the business and commercial purposes for which we collect, and sell personal data, please see relevant sections above.
Under the CCPA, a “sale” includes disclosing or making available to a third-party personal data, in exchange for monetary compensation or some other value or benefit. While we do not disclose personal data in exchange for monetary compensation, we may make certain categories of personal data available in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content.
We may share your information with other players (your in-game nickname and avatar only), our business partners, service providers, affiliates and subsidiaries, advertising and promotional agencies and networks, consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you.
|
Personal Data Collected |
Categories of Entities to Whom We May Disclose or Sell this Information |
|
|
Categories |
Description |
|
|
Identifiers |
Includes direct identifiers, such as email address, IP address, device ID and other online identifiers. |
- Affiliates and Subsidiaries |
|
Customer (User) Records |
Includes personal information, such as advertising ID in order to understand which other of our products and services individuals have purchased and/or played. |
Affiliates and Subsidiaries |
|
Commercial Information |
Includes records of products or services purchased. |
Affiliates and Subsidiaries |
|
Usage Data |
Includes ad views, browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. |
- Affiliates and Subsidiaries |
|
Geolocation Data |
Includes approximately location information about an individual or device. |
- Affiliates and Subsidiaries |
|
Tech device data |
Includes device language setting, OS version, device model, user agent (browser version), connection type, and network availability, carrier etc. |
Affiliates and Subsidiaries |
|
Player activity data |
Date and time when the user has opened the app, finished the tutorial, in-game progress, etc. |
- Affiliates and Subsidiaries |
California Residents’ Rights
If you wish to exercise your rights under the CCPA, including the right to opt out of the sale or sharing of personal information where applicable, please contact us by email at support@smartproject.com.
CCPA Rights. In general, California residents have the following rights with respect to your personal data:
Do-not-sell (opt-out): to opt-out of the sale of your personal data. While we may “sell” personal data as defined by the CCPA, we do not sell personal data about California consumers who we know are younger than 16 years old or another age to which restrictions apply.
Right to deletion: to request deletion of their personal data that we have collected about you and to have such personal data deleted (without charge), subject to certain exceptions.
Right to know: With respect to the personal data, we have collected about you in the prior 12 months, to require us to disclose the following to you (up to twice per year and subject to certain exceptions):
categories of personal data collected;
Also users have the right to know whether their personal data is shared.
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising your rights under the CCPA.
Submitting CCPA Requests. California residents may submit CCPA requests through one of the following methods:
When you submit any request, we will take steps to verify your request by asking you some questions about in-game experience (such as current level, the name of the in-game pet, etc.) and matching the information provided by you with the information we have in our records. You must answer the questions to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us via as set forth in the Contact section. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
CPRA Rights. Under the California Privacy Rights Act (CPRA), certain categories of data we collect qualify as "sensitive personal information" (SPI), including: precise geolocation (we collect only IP-derived approximate location - see note below); account login credentials; and device identifiers.
California residents have the right to direct us to limit our use and disclosure of sensitive personal information to purposes strictly necessary to provide the Service.
To exercise this right, please contact us at support@smartproject.com.
Note: we do not collect precise GPS-based geolocation. IP-derived approximate location is used solely for fraud prevention and jurisdictional compliance.
CPRA ADMT: We do not use automated decisionmaking technology, including profiling, to make significant decisions about California consumers within the meaning of the CCPA. We may use automated processing for ordinary Service operation, security, fraud prevention, analytics, advertising measurement, and personalization, but not to make decisions concerning financial or lending services, housing, education, employment or independent contracting opportunities or compensation, or healthcare services. If this changes, we will update this Privacy Policy and provide any required notice and consumer rights under applicable California privacy laws.
California residents have the right to opt out of the use of automated decision-making technology (ADMT) for decisions that produce significant effects. To opt out of automated processing for personalised advertising purposes, please use the in-game settings or contact us at support@smartproject.com.
ADDITIONAL INFORMATION FOR US STATE RESIDENTS
If you are a resident of Virginia, Colorado, Connecticut, Texas, or Oregon, you have the right to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, the sale of your personal data, and profiling that produces significant effects concerning you. These rights are in addition to any California-specific rights described above.
To exercise any of these rights, please contact us at support@smartproject.com or through the in-app support feature. We will respond within 45 days. If we decline your request, you may appeal by contacting us at the same address within 30 days of our response; we will reply to your appeal within 60 days. If your appeal is unsuccessful, you may escalate your complaint to the Attorney General of your state.
Colorado and California residents
We recognise and honour the Global Privacy Control (GPC) signal as a valid opt-out request for the sale, sharing, and targeted advertising uses of your personal data.
CHANGES
We may update this Privacy Policy from time to time. Any changes will take effect immediately upon posting the updated Privacy Policy.
If We make material changes, we may provide notice through the Services, consent interfaces, our website, or by other reasonable means, where appropriate.
Where required by applicable law, we will obtain additional consent or provide additional choices before processing personal data in a materially different manner.
The "Last Updated" date at the top of this Privacy Policy indicates when this Privacy Policy was most recently updated, so you are encouraged to review this Privacy Policy from time to time. All previous versions of this document are stored in the archive.
CONTACTS
We appoint a data protection officer when required by Article 37 GDPR. For any questions relating to this Privacy Policy or to contact our data protection officer please email us at: support@smartproject.com. You may also send us or our data protection officer regular mail at: Kirchstrasse 52, Liebefeld, Switzerland, 3097
Effective date: 06 June, 2026