Privacy Policy

Last updated November 1, 2020

Spring Games Ltd. (“Spring Games”, “we”, “us”, “our”) values your privacy. This privacy policy (“Policy”) describes how Spring Games processes Personal Data (as defined below) which we receive or collect in relation to your access and use of our website, https://www.springames.com/ or other website we operate (collectively, “Site”) and our mobile software application, “MaxiBoom” (“App”), and other products and services we offer (the Site and App, products and services, all together “Services”) and from our business contacts (such as representatives of customers and suppliers) and other third parties who provide us with Personal Data.

The term, “Personal Data”, as used in this Policy means information relating to an identified or identifiable natural person.

The term, “processing”, as used in this Policy means any action taken in respect of the data.

We may change this Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularly visit and review this Policy to stay informed of such practices. If you are under 18, please be sure to read this Privacy Policy with your parents or legal guardians.

Table of Contents

1. The Personal Data we Collect and How we use it
1.1. When you access and use our App or interact with our Services (automatically collected data)
1.2. When you create an account and when you log in
1.3. When you contact us (including for support)
1.4. When we process your job application
1.5. When you claim a Prize from our App shop
2. How (and with whom) we Share Personal Data
2.1. Cloud and Hosting Services
2.2. Law Enforcement or Other Government Entities
2.3. With your Consent
2.4. Disputes
2.5. Mergers and Acquisitions
2.6. Affiliates
2.7. Additional Information on our Service Providers
3. How Long we Retain Personal Data
4. Your GDPR Rights
5. Transfers of Personal Data to other Countries outside the EU or EEA
6. Your California Privacy Rights
7. California Do Not Track Notice
8. Personal Data of Children
9. Third Party Websites, Services & Data Collection
10. Anonymous Information
11. Our Contact Information

1. The Personal Data We Collect and How We Use It.

We collect and receive Personal Data from outside our company and affiliates, such as from users of our products and services as described in the table below. Certain Personal Data is collected automatically, while other Personal Data is provided by you voluntarily, for example, when you contact us. The description in the table may be supplemented by additional information in other parts of this Policy. For example, you may find for more information on third-parties to whom your information may be transferred in Section 1.5 below.

When we Collect Data

1.1 When you access and use our App (automatically collected data)

Type of Personal Data we Collect
• IP address
• Google and Apple IDs
• Advertiser ID
• unique User ID
• screen resolution and ratio
• screen DPI
• device ID
• network type
• country
• city
• device model and type
• operation system
• user behavior in-app (including in-app purchases, revenue, player level and score, inapp events, etc.)

Purposes of Processing the Data
• operating, providing, maintaining, protecting, managing, customizing and improving our Services;
• analysis of traffic, user and visitor;
• auditing and tracking usage statistics and traffic flow;
• improving our products and services
• display and personalization of advertisements in the Services.

Retention Period (How long we store the data)*
2 years following the deletion of your account.

Legal Basis under the GDPR
• Your consent
• Legitimate interest

Third Parties with Whom We Share your Personal Data**
• Google
• Apple
• MixPanel
• Anzu.io

Consequences of not Providing the Personal Data
• Cannot access and use the App;

1.2 When you create an account and when you log in

Type of Personal Data we Collect
• Nickname

Purposes of Processing the Data
• To be able to create an account and interact with other players
• To be able to log in

Retention Period (How long we store the data)*
2 years following the deletion of your account.

Legal Basis under the GDPR
• Your consent

Third Parties with Whom We Share your Personal Data**
• Google
• Apple
• MixPanel

Consequences of not Providing the Personal Data
• Cannot create an account
• Cannot log in
• Cannot enjoy all the features
• Cannot interact with other players

1.3 When you contact us (including for support) on the Site

Type of Personal Data we Collect
• Name
• Email
• Phone number
• Any other information you provide

Purposes of Processing the Data
• Verify your identity, process your request and respond to or contact you regarding your request;
• To display and contact you with information that is relevant to you in the future, and to assist you with further requests for support;
• Improve our customer support and communication practices;

Retention Period (How long we store the data)*
1 year

Legal Basis under the GDPR
• The performance of our contract (Terms of Service) with you.
• Your Consent
• Our legitimate interest.

Third Parties with Whom We Share your Personal Data**
• WebFlow

Consequences of not Providing the Personal Data
• We may not be able to provide you support or respond to your request.

1.4 When we process your job application

Type of Personal Data we Collect
• Name
• Email
• Phone number
• CV / resume

Purposes of Processing the Data
• To process your job application
• To assess the candidate

Retention Period (How long we store the data)*
1 year

Legal Basis under the GDPR
• Legitimate interest (e.g. to assess a candidate)

Third Parties with Whom We Share your Personal Data**
• None

Consequences of not Providing the Personal Data
• application.
• Cannot assess your suitability as a candidate.

1.5 When you claim a prize from our App shop

Type of Personal Data we Collect
We usually do not request for additional information. In some cases (as specified in the Terms of Use we would ask for these Personal Information:
• First Name, Last Name
• Email address
• Phone number
• Physical address

Purposes of Processing the Data
• Delivering the prize to your address.
• Protecting the security of the Services, as well as our and third parties’ rights.

Retention Period (How long we store the data)*
90 days.

Legal Basis under the GDPR
• Your Consent
• Performance of our contract (Terms of Service) with you.

Third Parties with Whom We Share your Personal Data**
• None

Consequences of not Providing the Personal Data
• We may not be able to provide you with the Prize.

*Please see Section 3 for more information on how long we retain data we collect.

**Please see Section 2.7
below for more information about third parties listed in this column.


2. How (and with whom) we Share Personal Data

In addition to any methods or third parties with whom we may share your Personal Data described above, we share Personal Data in the following manner:

2.1. Cloud and Hosting Services. We use cloud storage provider to host the Services and store all information we collect. We currently engage DigitalOcean LLC (or one of its affiliates), for such services and in addition to the third parties listed in Section 1 above, copies of all data we collect are stored on their servers.

2.2. Law Enforcement or Other Government Entities. Where required by law or government or court order, we will disclose Personal Data relating to you to the extent we believe we are required by law.

2.3. With your Consent. In the event that you have requested or have consented to the transfer of Personal Data relating to you to a third party (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.

2.4. Disputes and Legal Advice. In case of any dispute or request with, by or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.

2.5. Mergers and Acquisitions. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users and other personal data, to the purchaser or the entity with which we are merged. We may also transfer personal data to a potential acquirer, their legal counsel or service providers as part of an evaluation or due diligence review of our company in anticipation of an investment, acquisition or merger, though such transfers do not typically include personal data and are subject to obligations of confidentiality.

2.6. Affiliates. We share personal data with our affiliates, who assist us in processing personal data and providing our Services.

2.7. Additional information on our Service Providers (listed in Section 1).
To help you understand where data about you is transferred, here is more information about the service providers listed above whom we engage to process Personal Data that we collect. Where such service providers have made available information about their data security or processing practices which we think is relevant to you, we have provided links to such information. We take no responsibility for information found on their websites, including, without limitation, whether it is accurate or up-to-date.
• DigitalOcean LLC is a provider of cloud services, which we used to host the backend of our Services and store data that we collect. For more information about how DigitalOcean handles data stored on behalf of its customers like us, visit https://www.digitalocean.com/legal/privacy-policy/.
• Google LLC and its affiliates provide us with email (Gmail) services. Its SDKs, which are tools that provide help to business, their customers and others to integrate, use and exchange information with Google, interact with the App and the Google Play Center. You can read more about Google’s policies in connection with data received from its customers at: https://privacy.google.com/businesses/compliance/.
• Apple, Inc., installs SDKs that provide help to interact with the App and Apple Game Center. You can find out more about how Apple handles data you provide when using the App at: https://developer.apple.com/app-store/user-privacy-and-data-use/
• Anzu.io Inc., is an in-game advertising platform that provides advertising services. For more information please read its privacy policy: https://anzu.io/privacy/
• Mixpanel, Inc., is a provider of data analytics services, including “Mixpanel”. We engage Mixpanel to help us analyze and understand data we collect through our Services. You can visit Mixpanel’s website, www.mixpanel.com for more information about Mixpanel’s services.

3. How Long We Retain Personal Data

We may store Personal Data for longer periods of time than stated in Section 1 above: (i) where we believes we are required to do so to comply with laws or in connection with legal proceedings; (ii) resolve disputes; (iii) enforce agreements between us and others.

4. Your GDPR Rights.

Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member states or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:

Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Right to Rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, you may also request to complete incomplete Personal Data we maintain.

Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.

Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.

Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.

Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.

Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, when the decision produces legal effects concerning you or significantly affects you.

Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.

Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

You can exercise your rights that apply to us by contacting us by email at privacy@Springames.com. We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

5. Transfers of Personal Data to other Countries outside the EU or EEA

We transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and European Economic Area. If Personal Data from the EU is transferred outside the EU to our affiliates or to third-party service providers, to countries which the European Commission has not determined to adequately protect Personal Data, we take steps to ensure that such Personal Data receives the same level of protection as if it remained within the EU. This includes entering into data transfer agreements and using the European Commission approved Standard Contractual Clauses.

• Israel, where we are located. As of the date of this Policy, the European Commission has determined that the State of Israel adequately protects Personal Data. (A list of countries which the European Commission has determined to adequately protect Personal Date can be found, as of the date of this Policy, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

• The United States, where MixPanel stores information on our behalf.
If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).

6. Your California Privacy Rights

If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at privacy@Springames.com. Please note that certain exceptions may apply.
Disclosure of Direct Marketing Practices (“Shine the Light”). Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties. This right only applies if our relationship is primarily for your personal, family or household purposes and related to the purchase of our products and services.

7. California Do Not Track Notice.

We do not track individuals’ online activities over time and across third-party web sites or online services (though we do receive information about the webpage you visited prior to access our websites, products and services such as our Site, the App, and advertisement landing pages. We do not permit third-parties to track individuals’ online activities on our Site and App, unless it is part of a service provided to us. We do not respond to Web browser “do not track” signals or similar mechanisms. You can find out more information at: http://www.allaboutdnt.com/.

8. Third Party Websites, Services & Data Collection

Our Services may contain links to other websites, products or services offered by third parties (“Third Party Services”). This Policy does not apply to data collected by or on behalf of such third parties, whose privacy practices may differ from ours and who are not under our control. We are not responsible for the actions of such third parties or their data practices. Please review the privacy policies of any such third parties before you interact with them or provide them with Personal Data.

Furthermore, we are not responsible for the accuracy of information contained on Third Party Services linked to in this privacy policy or from our Services. We refer to such websites for your convenience only.

9. Personal Data of Children.

We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from “Children” as defined under all applicable law (under the age of 16 in the EU or under the age of 13 in the US) with the sole exception of persistent identifiers (such as model and type of device, User ID and IP address). Persistent identifiers are identifiers that do not identify you personally, but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.

We might ask you to add more information to receive a prize (as defined in the Terms of Use and we may process other Personal Information such as your address, phone number and email (as detailed in Section 1 above). In this case, as we do not knowingly process Personal Information from Children, we will ask for an email confirmation that confirms you are not a Child. If we learn that we have collected Personal Information without its parent’s consent, we will take all reasonable steps to delete the information as soon as possible. If you become aware that a Child has provided us with Personal Information without your consent, please contact us at privacy@springames.com.

In order to preserve the family-friendly reputation of our App, we age-gated some of the features in our Apps, so that they are not available for use by Children, unless they have parent consent. The age gate is being conducted after the download our in order to assure the privacy and protection of younger users of our App. We do not store the year of birth of users who have identified themselves as below the age of 16 in our App, but only the information that their device ID did not pass the age gate.

When using the persistent identifiers we will not contact Children, display behavioral advertising to them, nor do any user tracking or profiling. In addition, we strive that all of our advertising partners adhere to the same standards for the collection, usage and disclosure of children’s personal information as we do, but we cannot be responsible if they breach the commitments they gave to us regarding the collection of information. For any additional questions about third party information disclosure please refer to privacy@springames.com.

10. Anonymous Information.

We do not treat information we collect or receive which is not or cannot reasonably be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as “Personal Data”, even if it was originally linked to or stored with Personal Data. Such anonymous information is not subject to this Policy and we may use it for a variety of purposes, may share it with third parties or even publish it for any reason.

11. Our Contact Information

For inquiries regarding this Policy, you may contact us as follows:

Mail us:        
Spring Games, Ltd.
11, Menachem Begin
Ramat-Gan
ISRAEL

Email us:
privacy@springames.com