PRIVACY
POLICY
and compliance
with the provisions set out in the
General Data Protection Regulation
(GDPR)
APPLIES EXCLUSIVELY TO THE CONTENT
CREATED, PUBLISHED, OR ADMINISTRATED BY
LAGOON SOFTWARE AND FULL
GAME AHEAD
Contact: gdpr@full-game-ahead.com
This privacy policy was created for the data
processing processes of the following three companies: Full Game Ahead domiciled at 9th Floor, Amtel Building, 148 Des
Voeux Road Central, Central, Hong Kong and Lagoon
Software domiciled at D19 Mezza business Hub, Domaine de Mont Calme, 90905 Tamarin, Mauritius, which market products jointly
and which are definite (hereinafter referred to as “FGA”), in order to
demonstrate their commitment to the privacy of the users of their websites and
game applications. This Privacy Policy applies to Full Game Ahead and Lagoon
Software, which have drawn up contracts strictly defining the framework for the
exchange of data between these two (2) companies. FGA may, in compliance with all
the articles in this document, use your personal data for the sole purpose of
supplying you with the services for which you supplied us with the data.
COLLECTED DATA IS LIMITED TO THE INFORMATION NECESSARY FOR THE USE OF
OUR SERVICES AND IS PROCESSED SOLELY FOR THIS PURPOSE. YOUR DATA IS STORED AND
PROCESSED WITH THE GREATEST POSSIBLE REGARD FOR PRIVACY PROTECTION. WE
UNDERTAKE TO PROTECT YOUR PERSONAL DATA AND NOT TO USE IT IMPROPERLY NOR
DISCLOSE IT IN ANY WAY FOR ANY PURPOSE OTHER THAN THE USE OF OUR SERVICES. WE TREAT
YOUR DATA WITH DISCRETION. WE INFORM YOU OF THE USE MADE OF YOUR PERSONAL DATA
AND THE MANNER IN WHICH IT IS COLLECTED AND GIVE YOU THE OPTION OF EDITING OR DELETING
THIS DATA AT ANY TIME.
OUR PROCESSES COMPLY WITH THE PROVISIONS
SET OUT IN THE GENERAL DATA PROTECTION REGULATION (GDPR).
To find out more about our privacy policy and the way in which we
process the personal identifying information collected from our visitors and
users, please read the following.
1. HOW CAN YOU
EXERCISE YOUR RIGHTS?
You have the right to access and correct your personal
information, which you can exercise by editing your information yourself on the
forms you used to send it to us or by writing to us to request its permanent
destruction at the following email address: gdpr@full-game-ahead.com. You can also object to the processing of your
personal data by writing to us at the same address. If you decide that your
data should not be processed, we will destroy said data within fifteen (15)
days following receipt of your request. On requests for the update or
destruction of your data: No requests by telephone or by any other
communication method apart from the email address given above will be
considered.
Information: When
your data is removed from our databases, as the collection and storage of
personal information is essential for identifying you, the deletion of your
data will cause you to lose access to our services when said services require
you to formally identify yourself.
2. FIELD OF
APPLICATION OF THE PRIVACY POLICY
This Privacy Policy is applicable to the way in which FGA processes the personal
identifying information it collects via its websites, Facebook® pages and
applications, smartphone applications and other platforms such as Google® and
Apple®. FGA will never pass on your
personal data to a third-party company unless a contract guaranteeing the
proper implementation of these regulations has been drawn up with this company,
or if communicating your personal data is not necessary for the proper delivery
of the services supplied by FGA. This Privacy Policy does not apply to the
practices of companies not held or controlled by FGA, nor to persons FGA does
not employ or manage, including all third-party contributors to whom FGA will
not pass on any personal data and with whom FGA has not drawn up a contract for
the transmission of content as well as third-party websites accessible from FGA’s
websites.
3. INFORMATION
ABOUT THE UTILISATION OF FACEBOOK USERS’ DATA WITHIN OUR GAME APPS
In Coin Pusher®, Maze Fiesta®, Prize
Fiesta®, and Prize Blast® apps, users are given the option to login with
Facebook. This procedure exclusively uses the secured App scoped ID provided by
Facebook. This ID is useless outside these game Apps.
You have the right to require the deletion
of your App Scoped ID at any time by requesting so at the following email
address: gdpr@full-game-ahead.com.
Apart from the App scoped ID, FGA does not save nor keep any user’s data from
Facebook including Users/Friends First/Last Names nor Pictures.
Users may load their Facebook data on
their device via Prize Fiesta®, and Prize Blast® to display information about
their interactions with their Facebook friends. This data is deleted at the end
of each session.
FGA DOES NEVER SAVE FACEBOOK USER’S PERSONAL
DATA IN FGA’S DATABASES.
4. COLLECTION
AND USE OF PERSONAL DATA WITHIN GAME APPS
We have endeavored to make our policy on the
processing, use and security of your personal data (described in the following
points) as clear as possible. You are allowed to check the personal information
we hold on you, to make sure that it is correct and represents reality. Rest
assured that your personal information is always secure with us and protected.
We use your personal information for the purposes for which you have entrusted
it to us. We will never sell your personal information and we will only share
it with the companies contributing directly to the service to be provided. We use the personal data you share with us in
the following ways:
PROCESS
1:
The collection of information during registration for a promotional gift award program.
FGA will ask you for certain personal data when you
want to take part in promotional lotteries (sweepstakes) on Apple versions only
or to register to our loyalty programs on all other versions including Android.
FGA uses this data to respond to your requests, to make the required products
and services available to you, to configure your account and to contact you
about products and services. For the games: Prize Fiesta®, and Prize Blast® you
have the option of registering for promotions that allow you to receive gifts. When
you register to enter sweepstakes organized by FGA or a loyalty program organized
by FGA, you expressly consent to the collection of your personal data by checking
a box, which is required in order for your information
to be transmitted. You acknowledge that we can make use of it in compliance
with this Privacy Policy. To do so, you will be asked for the following
information.
|
Requested fields |
Description of their use |
|
Email |
Contact information used to notify the user that they have won in
promotional lotteries or in our other promotional programs. |
|
Password |
Provides access to an account synchronized to an online version of the
games. |
|
Date of birth |
Confirmation of age and eligibility for gift-winning programs. |
|
Gender |
Customization of the packaging for some of the gifts send (boy/girl/other
packaging) |
|
Last name |
The delivery address we pass on to the carrier in the event of a win
including phone contact information required by the majority of carriers. It
will also be used to confirm the eligibility of the participant’s geographical
area. |
|
First name |
|
|
Address |
|
|
Zip code |
|
|
Town/city |
|
|
Country |
|
|
Cell phone or landline number |
During this process users will be asked to confirm
their email address. When sending your confirmation emails, FGA works with the
service provider Mailjet SAS, headquartered at 13-13 bis, rue de l’Aubrac –
75012 Paris. Mailjet SAS complies with the General Data Protection Regulation.
Process 1 is carried out by the customer service
representatives of Lagoon Software Ltd who are trained in GDPR processes and
contractually bound to comply with the privacy guidelines of these regulations.
AS PART OF PARTICIPATING IN FGA PROMOTIONS, YOU AGREE TO RECEIVE A MAXIMUM OF
THREE (3) ADDITIONAL EMAILS PER YEAR REGARDING FGA NEWS. YOU CAN REQUEST THE
DELETION OF YOUR EMAIL ADDRESS FROM OUR NEWSLETTER MAILING LIST BY CLICKING ON
THE LINKS PROVIDED FOR THIS PURPOSE IN EACH OF OUR NEWSLETTERS OR REQUESTING IT
BY EMAIL AT: gdpr@full-game-ahead.com.
PROCESS
2:
The collection of information prior to the delivery of a promotional gift.
When a participant wins a gift in one of FGA’s
promotional game programs, according to the rules outlined in these programs, they
are required to provide the following documents:
|
Requested documents |
Description of their use |
|
|
An electronic copy of proof of identity (scanned or photographed) |
Verification of the identity of the users who are going to receive a
promotional gift. We check that the information entered on the profile is the
same as that which appears on the proof of identity. |
|
|
Electronic copy of proof of address (scanned or photographed) |
Verification of delivery address. We make sure that users still live
at the same address as the one they supplied when they completed their
profile in order to avoid sending a prize to a previous or wrong address and
we reconfirm its geographic eligibility. |
|
|
A signed affidavit: DECLARATION OF ADMISSIBILITY, COMPLIANCE,
EXEMPTION FROM LIABILITY AND CONSENT FOR ADVERTISING PURPOSES |
We request this document for two reasons: 1. To obtain the legal
consent of users for the delivery terms of their gift and to give them the
option of rejecting them as laid down by the law in some countries. 2. After they
receive their gift, winners can send in a photo of them posing holding their
gift. Therefore, we request permission in advance from the parties involved so
we can publish it. |
|
This process 2 is carried out by the customer service
representatives of Lagoon Software Ltd who are trained in GDPR processes and
contractually bound to comply with the privacy guidelines of these regulations.
5. COLLECTION
AND USE OF NON-PERSONAL DATA WITHIN GAME APPS
FGA receives and automatically records non-personal
data on our server logs via your browser, or your mobile device including your
IP address, your advertising ID, your mobile device ID number, your game
account number (iOS Game Center or Android Game Service) and the source URL
when you access our websites. This non-personal data is only collected for the
following reasons:
PROCESS
3:
The use of your data for the creation and the
identification of an account on an application.
When creating your accounts on one of our
applications, after downloading it from App Store or the Google Play Store, FGA
uses the data to create your personal account and then reuses it to identify
you again on your following visits. This operation is essential for you to find
your account in the condition you left it in. The data used for this process
is: your mobile device ID number or your iOS Game Center game account number or
your Android Game Service game account number or a unique ID number generated
by Facebook (see Article 3 of this document), depending on the connection mode
you have chosen.
PROCESS
4:
The anonymous use of your data to measure the performance of our own
advertising campaigns.
For the purpose of optimizing the effectiveness of our own user
acquisition campaigns via on-line advertising, our applications may collect
your advertising ID. This ID is never transmitted to our servers, so we cannot
store this ID on our servers. Your advertising ID is only transmitted to the company
Singular (https://www.singular.net/), which allows anonymous statistics to be generated on the
performance of our products. At no point in this process are we able to link
your personal data to your advertising ID. Singular is a responsible company that
complies with the General Data Protection Regulation. If you no longer wish us
to use your advertising ID for the exclusive purpose of generating anonymous
statistics, please contact us via the following email address: gdpr@full-game-ahead.com.
PROCESS 5:
Advertisement data sharing and collection policy for
our apps
Our Privacy Policy affords users the option to accept or refuse the
sharing of their data with our company. Before any data collection takes place,
users will be presented with an option through a pop-up displayed within each
of our apps to accept or decline. Should a user choose to accept, our
third-party mediation service utilizes Google Analytics to collect certain
information such as device type, IP address, and in-app activities. This
information is used exclusively for the purpose of measuring and reporting
statistics about user interactions within our apps in an anonymous manner,
meaning that the data collected cannot be linked to the individual user's
identity. By accepting its disclosure, users will benefit from an improved
advertisement experience as the ads they see will be selected and moderated through the use of an algorithm based on their interactions.
6. SHARING AND
DISCLOSURE OF DATA
Only FGA's specially authorized staff may access data
of a personal nature concerning you and only when this is necessary for the
effective delivery of our services. FGA is also authorized to disclose your
personal data to third parties who work on the behalf of FGA, but solely for
the purposes of delivering the services and products you request under good
conditions, as defined by processes one (1) through five (5) set out in
articles four (4) and five (5) of this document. We
share personal data exclusively for these purposes, with third parties whose
privacy policies comply with our own and who comply with the provisions set out
in the General Data Protection Regulation (GDPR). FGA may also disclose your
personal data when:
·
You have
expressly consented to us sharing your data for specific purposes by checking
the box in the data collection form where you yourself entered your personal
data.
·
We are required
to comply with subpoenas, injunctions or any other
legal requirements.
·
We are required
to protect the security of our services users and applications (Apps) users or
protect FGA’s rights or ownership.
·
We observe that
your activities on websites or applications breach the terms and conditions of
service of at least one of FGA’s companies, or any other rule for the use of
specific products or services.
7. STORAGE OF
PERSONAL DATA
Length of
storage: Your data of a personal nature may not be stored beyond the length of
time strictly necessary for the management of the commercial relationship.
However, data serving as proof of a right or a contract or stored in compliance
with a legal obligation may be stored pursuant to the provisions in force for
up to 10 years.
Storage method
and computer security: Your data of a
personal nature is stored securely on our servers. Our storage system for your
data uses computer technology that greatly reduces the risk of leaks due to the
penetration of databases by computer hackers.
Storage location: All of your personal data is
exclusively stored on servers geographically located within the European Union.
8. DATA ON
SOCIAL NETWORKS
WE DO NOT SAVE ANY PERSONNAL DATA AUTOMATICALLY
COLLECTED FROM FACEBOOK IN OUR DATABASES. The information we may collect from
social networks and online websites may include personal information published
online and which is publicly available. These online websites and social
networks have their own privacy policies which explain how they use and share
your personal information. We encourage you to review these privacy policies
carefully before using these websites to make sure that you are informed about
the way in which your personal information is collected and shared. When you
use an FGA product or game via a Social Networking Site such as Facebook®
(hereinafter referred to as an “SNS”), you authorize FGA to access certain personal
and non-personal data which you have supplied to said SNS, such as your
username, your first and last names, your profile photo and user data related
to the product or game in question. By accessing a FGA product or game via an
SNS, you authorize FGA to collect, store and use all of
the data you have agreed that the SNS should make available to FGA via said
SNS. The collection, storage and use of your data is governed by this Privacy
Policy.
9. COOKIES
We use cookies, tags, invisible pixels and other similar technologies solely
to personalize your visit. Information collected using these means does not include
any personal details. The information collected using these methods is never
shared with third parties. Our cookies
contain neither sensitive personal information, nor information relative to
targeted advertising: In this case, pursuant to the provisions set out in the
General Data Protection Regulation, they require no prior consent from you.
10. CONSENT
If you do not consent to the collection, use or
disclosure of your personal data as set out herein, please do not send any
personal data to FGA. If you have sent personal data to FGA and no longer agree
to its use or disclosure as set out herein, please inform FGA of this by
contacting us at: gdpr@full-game-ahead.com.
11. AMENDMENTS
OF THE
PRIVACY POLICY
THE LAST VERSION OF THIS PRIVACY POLICY WAS
UPDATED ONLINE ON JANUARY 26th, 2023. We guarantee our updates and never change our
policy in such a way that it offers less protection of your personal data
without your consent. We publish
changes on our website at the following address: https://www.full-game-ahead.com/privacypolicy and if we have your email address, we can send you a
message to inform you directly of the changes and updates. FGA reserves the
right, at its sole discretion, to amend this policy at any time, without being
required to give you prior notification. Please make sure to re-read this
policy from time to time. By continuing to use FGA websites after changes have
been made, you indicate your agreement to said changes. No provision in this
privacy policy may be deemed to create a contract or a guarantee. FGA does not
guarantee an error-free performance by way of this document. We shall make all
reasonable efforts to comply with this Privacy Policy and we undertake to take
corrective action in as short a time as possible in the event of a failure to
do so. FGA may not be held liable for any incidental, consequential or
punitive damages linked to this Privacy Policy. This Privacy policy is governed
by the laws of the United States of America and/or of the European Union as
applicable.
12. COMPLIANCE
WITH THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a legal representative or represent an
accredited government organization, you can ask to be put in contact with our Data Protection Officer. To do so, please
explain in detail the reason for your request and send it to gdpr@full-game-ahead.com. FGA has thoroughly mapped its personal data
processing processes. Measures have been taken to ensure that our internal
processes comply with the provisions of the General Data Protection Regulation
(GDPR). An external audit has been carried out to assess all personal data
processing. This audit revealed that none of our processing threatens the
privacy of the persons concerned by our personal data processing, and that all
our processing is lawful and fulfills a need related to the performance of our
business activity. Our internal processes are highly secure in order to protect
the privacy of the persons concerned. Our processing is fully documented in the
records intended to be examined by the competent authorities when the latter
request to do so.
13. QUESTIONS
AND SUGGESTIONS
If you have any questions or suggestions related to
this Privacy Policy or your personal data, feel free to contact us by email at
the following addresses: gdpr@full-game-ahead.com.
LAGOON SOFTWARE
19D Mezza Business Hub
Domaine de Mont Calme
90905 Tamarin
Mauritius Island
Postal mails to Lagoon Software: answered
within 7 working days after reception.
FULL GAME AHEAD
C/O Profit Accounting
9th Floor, Amtel Building
148 Des Voeux Road Central
Central
Hong Kong
Postal mails to Full Game Ahead: answered
within 30 working days after reception.
Contact: gdpr@full-game-ahead.com