terms and conditions
When you install our games and apps, we may collect and record information to enhance the experience and benefits of using our Services. Phoenix may collect personal and non-personal information from you when you use the Service. This can include instances such as
- By using Phoenix’s mobile apps or visiting our websites,
- Registration for Services, contests and special events;
- Accessing Services using a third party ID, such as social networking sites or gaming services;
- Purchasing a product or services through "in-app purchase"
- Using “tell a friend,” "email this page," “share this code” or other similar features;
- Requesting technical support; and
- Otherwise through use of Phoenix Services where personal data is required for use and/or participation.
The data we collect on you may include, but is not limited to: email address, device ID, IP-address, user names and passwords. We may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services. Any information collected will only be used to enhance your game play experience and will never be misused in any manner.
The Service can offer several integrations with sharing services and other tools (like Google +1 button, Facebook Like button, among others), that can be used to share information and take actions while interacting with our Service. Also we may integrate Social Media Services in our Games competitive services for sharing Scores and Achievement between players, like Google Play Games Services or others. The use of these services and tools is a free choice of each user. It's not necessary to use these services. The social features that each User agreed to use enables the sharing of information with other contacts or the general public, depending on the configuration options the entity provides. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
If you use one of our applications and connect to your Facebook or other Social Media account within such application, you will be providing us with basic account information i.e., user ID, name, email, gender, birthday, current city, profile picture URL and the user IDs of your friends who have also connected with our applications. In addition, we will cache data we receive from the Facebook or other Social Media APIs to improve our user experience.
This information is used solely to connect to the Social Media and allow users to display their data on the game accounts as their username, etc. This also allows Users to complete their actions such as sent request to their friends, connect and play with their friends, share information on their walls or timelines, etc.
This information is voluntarily provided by the user when they connect the app to their social media accounts. If you do not want to share this data with us, please refrain from connecting the app with your social media accounts. If you want us to delete the data we have received from your accounts, please contact us for the same.
We may use information about you for various purposes, including to:
Phoenix will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfill the purposes as described above. The information will be stored further if it is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with Phoenix has ceased.
We may share Your Information with third parties with whom we have a strategic relationship such as ad networks and analytics providers. The information shared with these third parties may be used for industry analysis, tracking ad conversions or demographic profiling.
We may employ third party companies and individuals to facilitate the Service, to provide the Service on our behalf, or to assist us in analyzing how the Service is used. These third parties have access to Your Information only to perform these tasks on our behalf and may not use Your Information for any other purpose. We may also provide Your Information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.
Furthermore, if you have given your consent in accordance with the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App.
AdMob (Google) https://policies.google.com/technologies/partner-sites
Unity Ads https://unity3d.com/legal/privacy-policy
We may disclose the personal information we hold about you in the following circumstances:
If we are required or authorized to disclose by law or by a law enforcement agency;
To our business partners in the course of providing our Products and Services to you, or generally in the conduct of our business. This may include organizations that provide services to us, such as payment processors or hosting services
To avoid, lessen or prevent a serious emergency or crime. If we use or disclose personal information about you in those circumstances we will make a written record of such use or disclosure.
Phoenix Games LLP saves your Email address, Device ID that you provide on login to serve you a good service. We have a legitimate interest to collect and process necessary data to
(i) Update and develop player profiles and improve the service and player experience
(ii) Manage our relationship with you
(iii) Provide social features as part of the Service
(iv) Customize your service experience
(v) Respond to your comments and questions and provide player support
(vi) Send you related information, such as updates, security alerts, and support messages
(vii) Enable you to communicate with other players We do not sell your data “Email address” to anyone.
If you choose to use communication features in Phoenix Games LLP Services that allow you to communicate or share information with other players (Eg. Using chat feature), then we do not collect or save information on what is communicated or shared. If Phoenix Games LLP get complaints from Users, Phoenix Games LLP have full rights to conduct research and review your Information you Generate Using Our Services and take necessary actions related to your behavior and Blocking your account to use our services.
We hereby prohibit Kids from actively and directly providing us with any personal information. If you are a legal guardian of a Kid and believe your child has provided us with any personal information, please contact us at email@example.com and we will delete such information from our servers.
Phoenix Games may collect and maintain the information described in Section 3, directly or through certain products or services, solely for providing support for Phoenix Games internal operations as permitted under applicable laws and rules (described in greater detail below).
We included an age-gate in certain Apps to prevent access to specific features to Users who did not pass the age gate for protection of Kids (e.g. restricting behavioral advertising, information sharing by Kids, or the option to accept push notifications)..
Phoenix Games and Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such Kids Non-personal Information, Phoenix Games and the Third Parties are not aware of the identity of the User from whom Kids Non-personal Information has been collected. Kids Non-personal Information collected by either Phoenix Games or Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Kids Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s game play (e.g. level reached, frequency and time spent in the Kids App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Kids Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), other Phoenix Games Apps installed, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.
Phoenix Games and Third Parties may passively collect a persistent device identifier from Kids, such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address (“Kids’ Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Kids Apps. In the case of IP addresses, we keep these for 1 week for error logs, then delete them. Phoenix Games does not collect and does not permit Third Parties to collect from Kids any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that Phoenix Games may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.
Phoenix Games does not link any additional personally identifiable information to the Kids’ Persistent Device Identifier, even from other services. Phoenix Games does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Kids.
If a Kid e-mails a question to Phoenix Games, using the “Ask a Question” or “Support” type of a feature which may be available within the Kids Apps, Phoenix Games may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at Phoenix Games discretion, not responding) to such question, Phoenix Games will delete the Kid’s e-mail address.
Purpose of the collection: The information described above is collected and processed solely for the purpose of supporting Phoenix Games internal operations. This means the following:
The Non-personal Information and Kids’ Persistent Device Identifier are collected either by Phoenix Games or by Third Parties through the Users’ use of the Kids Apps, including through Third Parties’ SDKs embedded in our Kids Apps. Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Kids Apps, such as “cookies-like technology” and local storage
We may share the Kids’ Persistent Device Identifier only in limited cases, including the following:
To clarify, Phoenix Games may transfer and disclose Kids Non-personal Information to third parties at its discretion.
Some of our products and Services offer in-app purchases for certain features or items, such as in-game currency against real money. It is not necessary to make any in app purchases to win prizes or effectively use the apps. There is no cap on the number of in app purchases you can make and you acknowledge and agree that you are fully responsible for managing your in app purchases and the amount you spend on in app purchases within our app. If you do not want to make in-app purchases, please do not use these options and consider disabling them on your device.
Making an in-app purchase may require you to share personal identification information with us. If any private information is shared through Google Play during purchases, it is stored and secured by Google. We only receive the Order ID or Transaction ID and the Receipt Data, which we store as a record of the transaction on our end. Same applies for transactions on Apple ID.
It should also be noted that the purchase of these features and in-game currency, such as virtual coins, cash, gold, gems and diamonds, points, etc. last only for the duration of the app or game. If you choose to uninstall the game or app, these features and coins will cease to exist, and are not transferable. These virtual items subsequently cannot be exchanged into real money or refunded. You understand that you do not own Virtual Items, but acquire a limited license to use Virtual Items according to the specific Game’s game play.
We reserve the right to use and disclose the collected, non-personal data for purposes of advertising by us or our partners and contractors. We may employ third parties for ad serving technologies who may use certain methods to collect information as a result of ad serving through Services.
We and these entities may use various identifiers to collect information about your use of the App, including but not limited to your IP address, MAC address, device identifiers, software and hardware information, time zone and usage information.
This information may be used by us and others to, among other things, determine the popularity of certain content, deliver contextual advertising and content and better understand your activity on the App.
Third-party ad serving technologies are integrated into the App, so if you do not want to be subject to these technologies, please do not use or access the App.
We reserve the right to use and disclose the collected, non-personal data for the purpose of analytic services by us or our partners and contractors. We may employ third parties to provide analytics services for us. We and these entities may use certain methods to collect information in order to provide analytics.
The information collected may include your use of the App, including your, device type, brand and model, IP address, device identifiers, such as Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, Internet and on-line usage information, in-game information, geo-location, country, time zone and usage information.
This information may be used by us and others to, among other things, determine the popularity of certain content, deliver contextual advertising and content and better understand your activity on the App.
Third-party analytics technologies are integrated into the App, so if you do not want to be subject to these technologies, do not use or access the App.
With your consent, we may send push notifications or alerts to your mobile device to provide app-related information, service updates, promotional communications and other related messages. You can deactivate these notifications by changing your notification settings on your device.
We follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in our possession. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your Account or any of Your Information will be protected against, loss, misuse, or alteration by third parties. However, in case of such a scenario, we will notify you as soon as we know, and no later than 72 hours since such an event.
If you wish to use any of the rights described below, you may contact us at any time by emailing us at firstname.lastname@example.org. We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by the GDPR.
You have the right to request access into the data that we are processing on you, including information about:
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted in case of intellectual property or trade secrets.
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of interest rule of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.
You have the right to have inaccurate personal data rectified. Furthermore, you have the right to have your personal data erased where one of the following grounds applies:
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The General Data Protection Regulation (GDPR) is effective from 25th May 2018. The GDPR aims to strengthen the security and protection of personal data in the EU and will replace the European Privacy Directive and national legislations accordingly.
Phoenix understands the importance of customer data and welcomes the arrival of the GDPR. At Phoenix Games, we believe that customers are the most important part of our business and the success of our company builds on the trust that our customers, employees and other stakeholders have in our ability to deliver premier quality including the protection of personal information.
Phoenix Games services complies with all applicable parts of the GDPR.
Any consent you may give or choose to withhold in relation to the GDPR shall apply to all services (games and website) provided by Phoenix Games LLP as part of the phoenixgames.in domain.
The following are key aspects of the GDPR, and how it relates to Phoenix Games LLP.
The GDPR is the General Data Protection Regulation established by the European Union.
At its core, GDPR is a new set of rules designed to give EU citizens more control over their personal data. It aims to simplify the regulatory environment for business so both citizens and businesses in the European Union can fully benefit from the digital economy.
Follows EU Data Protection Directive (Directive 95/46/EC). For more information, please see eugdpr.org.
There are 4 aspects to the GDPR that Phoenix Games LLP has considered as part of our GDPR compliance:
The right to data portability
Individuals have the right to a copy of all the personal data that controllers have regarding him or her. It also must be provided in a way that facilities reuse.
This gives individuals the right to have certain personal data deleted so third parties can no longer trace them. Phoenix Games LLP does not store any personal data, only authentication tokens to Facebook. Those tokens can be invalidated by removing the game app according to these instructions by Facebook.
Since we currently do not store any PII directly, and the only way to link game state and analytics data collected with a particular user is via their Facebook Access Token, simply removing the Phoenix Games LLP game app from the users’ Facebook profile will anonymized any information we hold. This will happen instantly, the moment the user removes our app.
This helps to facilitate the inclusions of policies, guidelines, and work instructions related to data protection in the earliest stages of projects including personal data.
This aspect does not apply to Phoenix Games LLP.
Controllers must report personal data breaches to the relevant supervisory authority within 72 hours after having become aware of it. If there is an high risk to the rights and freedoms of data subjects, they must also notify the data subjects.
Phoenix Games LLP has an escalated process in order to ensure the security of user data. Information about whether or not user data has been part of a breach is available upon request.
To Understand the position of Phoenix Games LLP in the compliance of GDPR, it is important to understand the actors. These actors are:
is the individual or the legal person who controls and is responsible for the keeping and use of personal information on a computer or in structured manual files.
in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller. “processing”, in relation to information or data means. obtaining, recording or holding the information or data.
means an individual who is the subject of personal data. In other words, the data subject is the individual whom particular personal data is about.
The following are key elements of our GDPR Compliance:
We do not process personal data on behalf of the Customer and we don’t have access to any personal data in our customer’s systems (Customer Personal Data). Moreover, Phoenix is not able to monitor the processing of Customer Personal Data in our customer’s systems.
At Phoenix we collect two types of data on our users; passive and active. Passive collection is the data that is collected when users play games, whether on their mobile device or the web. This data is collected using Google Analytics or similar and contains the following information:
This data does not contain any personally identifying information. Our active data collection is currently limited to high scores and game information, such as coins collected. We allow users to log in using their Facebook account, and from their Facebook account we store the following:
User Access Token: we simply use this token to identify a user from one play session to the next. We do not gain access to any details about the user.
As such we don't store any data that can be used to identify and track an individual. The user access token can be invalidated at any time by removing our app from the users Facebook profile.
The controller shall implement appropriate technical and organizational measures for ensuring that by default, only personal data which are necessary for each specific purpose of the processing are processed.
Each controller and where applicable, the controllers representative, shall maintain a record of processing activities under its responsibilities
Organizations must implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the pseudonymization and encryption of personal data
Appropriate technical and organizational measures may need to include “the ability to ensure the ongoing confidentiality, integrity, availability and resilience of the processing systems and services
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use the App will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance.