This Privacy Policy will be effective from August 1, 2020.
Introduction
In this Privacy Policy, “Full Force Studios” refers to Full Force Studios Ltd. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to Full Force Studios as "we" or "us".
Full Force Studios is committed to protecting the privacy of its users and provide them a better social gaming experience ("users" or "you").
This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content, Full Force Studios.com and/or the other domains provided by Full Force Studios, together referred to as “Services.” This Privacy Policy describes:
1. what information we collect, how we collect it
2. how we use that information and with whom we share it
3. how you can access and update that information and means of communications
4. how we protect the information we store and share about you
By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want Full Force Studios to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play Full Force Studios’ games or use our Services. Full Force Studios may amend the Privacy Policy from time to time, and Full Force Studios encourages you to consult the Privacy Policy regularly for changes.
Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law.
1.Information We Collect, How We Collect It and The Legal Basis for It.
Full Force Studios only collects Personal Information to the extent necessary to fulfil one or more of its functions and activities, and will do so only by fair and reasonable means. Generally, we will collect Personal Information directly from the users, but in some circumstances (including as outlined below), it may be necessary for us to collect information from a third party source.
The legal basis for collecting and using the information depends on what the information is and the context in which we collect it.
Generally, we’ll normally process your personal Information for legitimate interest of efficiently fulfilling our contractual and legal obligations, account management, management reporting (including at our corporate group level), market review and analysis, promotion of our products and services and business development. In some cases the processing is necessary to perform our contract with you (i.e., our Terms of Service) or to fulfill legal obligations, or to protect your vital interests or those of another person (for example, another user).
If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are requesting your information (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Service), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.
2. How We Use the Information We Collect and With Whom We Share It
How We Use Your Information
The main use of the information we collect, and store is to provide a better gaming experience, but there are other uses as well. The uses for which we collect and store your information may include:
• to create your game accounts and allow you to play our games;
• to operate, improve and optimize our Services and our users’ experiences;
• to identify and suggest connections with other Full Force Studios users and personalize our Services to you;
• to enable users to communicate with each other;
• to provide technical support and respond to user inquiries;
• to protect the safety and well-being of our users;
• to protect Full Force Studios's rights and property in connection with our Services;
• to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
• to manage and deliver contextual and behavioral advertising;
• to notify users of in-game updates, new products, conent or promotional offers;
• to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to comply with our legal obligations, resolve any disputes we may have with you or other users, and to enforce our agreements with third parties;
• to conduct research.
One important use of your information is communication. If you have provided your e-mail address to Full Force Studios, we will use it to respond to customer support inquiries, and keep you informed of your in-game activity, including comments from friends, let you know about in-game status and promotions as well as tell you about gift and neighbor requests. Some messages, like invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages (e.g. text messages) ("Promotional Communications") directly or in partnership with other parties, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages. Receipt of such communications depends on Full Force Studios having certain contact information from you. If you play one of our games designed for children under 13, you will not be able to provide us with certain contact information. Please see the section on Our Policies Concerning Children for more information.
How We Share Your Information
We may disclose or publish aggregated and analytical information (information about you and other users collectively that is not intended to specifically identify you, for example, users between the ages of 25 and 30 who live Chicago) and other non-personal information about our users for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.
3. How to Access, Update and Manage Your Information and Means of Communication
A. Accessing and Updating Your Information Held by Full Force Studios
If you want to review, delete, or change the information Full Force Studios has about you or have additional questions, you can submit a request in the Full Force Studios Privacy Portal or through the Privacy category in the support page within the game you play.
B. Deletion of Your Personal Information
If you no longer want Full Force Studios to make active use of your personal information, you can submit a request for deletion of your personally identifiable information in the Full Force Studios Privacy Portal.
Following such request, a verification email will be sent to you to authenticate your identity and to ask your confirmation.
We will respond to your request within thirty days of your verification. Please note that certain records, in some cases will be maintained in Full Force Studios archived databases in order to:
(1) Complete the transaction for which the personal information was collected, provide a good or service requested by you.
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
(3) Debug to identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure another user’s right to exercise free speech, or exercise another right provided for by law.
(5) Comply with a legal obligation.
(6) Use the your personal information, internally, in a lawful manner that is compatible with the context in which the you provided the information.
If you have sent content through or posted content on the Service, we may not be able to delete it.
4. How We Protect the Information We Store and Share About You.
Security of Your Information
Full Force Studios has undertaken reasonable technical and organizational measures designed to secure your information both online and offline from accidental loss and from unauthorized access, use, alteration or disclosure, and we are committed to the protection of customer information. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
When you sign into your Full Force Studios account or enter payment information, we or our third-party payment processor use secure socket layer technology ("SSL") to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure, and Full Force Studios cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur and that third parties will never be able to overcome those measures or use your personal information for improper purposes.
Also please note that email and messaging systems are not considered secure, so Full Force Studios discourages you from sending Full Force Studios personal information through these media. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If you access our Services through a social network and your social network account is hacked, this may lead to unauthorized play of your Full Force Studios games without your permission. So, be careful to keep your Account Information secure.
Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access. If you have questions about the security of our websites, please submit a ticket via the applicable support channel of the game.
Safety, Security and Compliance with Law
Your information, and the contents of all of your online communications in our Services and between You and Full Force Studios may be accessed and monitored as needed to provide our Service and may be disclosed:
• when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
• to satisfy any laws or regulations that apply;
• where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally;
• to protect the rights or property of Full Force Studios and other applicable third parties, including to enforce our Terms of Service.
International Operations and Transfers Out of the EEA
When you use our Services, your personal data may be sent outside of the European Countries, for example, to the United States. Israel and possibly other countries. When we transfer, store, and use personal data collected in the EEA outside of the EEA, we comply with our legal obligations and ensure that your personal data is subject to suitable safeguards (such as encrypting communication) or transferred to “approved” territories.
As a global company, we may transfer your personal data to our “Affiliated Entities,” located in European Countries and outside like United States, Israel and Hong Kong which are any other corporate entities under common ownership with Full Force Studios, or to our business partners and service providers from time to time for our legitimate business purposes. For example, Full Force Studios may provide certain services to its Affiliates.
We store personal data about users and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, marketing communication with users and product development. When we transfer your personal data internationally, we will take reasonable steps to ensure that your data is treated securely, lawfully, and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your data is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.
Additionally, if we share with entities which are not subject to the Privacy Shield framework, we make sure that these entities ensure an adequate level of protection, the transfer is supported by the European Commission’s standard contractual clauses for the transfer of personal data to a country outside the European Countries. These standard contractual clauses are available here.
How Long We Keep Your Information
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we collect or process your personal information and whether we can achieve reasonably those purposes through other means, and the applicable legal requirements.
We may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.
Changes to Our Privacy Policy
If we decide to make material changes to our Privacy Policy, we will tell you and other users by placing a notice on Full Force Studios.com or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Full Force Studios websites. You should periodically check www.FullForceStudios.com and this privacy page for updates.