Sugarfree Privacy Policy

Last Revised: 19 February2021

sugarfree, represented by UAB „Edukacinės sistemos“ ("Sugarfree", "we") are committed to protecting your Personal Data. We offer services and games that can collect information from our clients (included adults, children and their parents or guardians) (“you”), so we have prepared a document called the Privacy Policy. In this Privacy Policy, we will explain what we do with the Personal Data that you provide to us, or which we can collect from you in the provision of services to you.

This Privacy Policy is in compliance with the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

CONTENT

1. WHO WE ARE

2. WHAT IS THE PURPOSE OF THIS PRIVACY POLICY

3. WHAT PERSONAL DATA WE COLLECT

4. HOW WE COLLECT PERSONAL DATA

5. HOW WE USE PERSONAL DATA

6. ON WHAT LEGAL BASIS WE USE PERSONAL DATA

7. WHAT ARE COOKIES

8. HOW CAN WE DISCLOSE YOUR PERSONAL DATA

9. WHAT SHOULD I KNOW ABOUT PERSONALISED ADVERTISING

10. OUR THIRD-PARTY DATA CONTROLLERS AND PROCESSORS

11. HOW WE PROTECT YOUR PERSONAL INFORMATION

12. HOW LONG WILL WE USE YOUR PERSONAL DATA

13. WHERE WE STORE AND HOW WE TRANSFER YOUR DATA

14. WHAT RIGHTS DO YOU HAVE

15. YOUR CALIFORNIA PRIVACY RIGHTS  

16. HOW TO CONTACT US

1. WHO WE ARE?

Sugarfree is represented by UAB “Edukacinės sistemos” with its registered address in Studentų g. 3A-11, LT-50232 Kaunas, Lithuania.

We are the Personal Data controllers responsible for your Personal Data. A Personal Data controller is the person who decides for what purposes Personal Data will be used.

Our contact details are as follows:

UAB “Edukacinės sistemos”

Studentų g. 3A-11, LT-50232 Kaunas, Lithuania

Phone: +370 37 300 833

Email: hello@sugarfree.games

If you have questions about this Privacy Policy or wish to exercise your rights, contact us by email at hello@sugarfree.games.

2. WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

While you visit our website at sugarfree.games or you play Sugarfree games ("Services" or "Games"), we may collect information about you ("Personal Data").

We care about your Personal Data protection, so we have developed this Privacy Policy. By this Privacy Policy, we want to clearly and comprehensively explain what data we collect, how we use, disclose and transfer it.

From time to time, we may change the terms of this Privacy Policy, so do not forget to read this Privacy Policy on a regular basis to understand how we use your Personal Data.

3. WHAT PERSONAL DATA WE COLLECT?

Personal Data refers to any information about a person which can identify that person. Please note that you must be at least 16 years old in order to sign in and provide us with your personal data as described below.

We may collect, use, store and transfer various Personal Data we have grouped into these categories:

Personally identifiable and information. 

We have integrated Facebook and Apple (only available on iOs) login features, which allow you to sign into our Services.

By choosing Facebook registration method, you provide us your Facebook related data (name, last name, profile picture and your email address which is associated with your facebook user account).

By signing in with Apple, you provide us with your name, surname and your email address (AppleID). Also, you have an option to hide your email address by choosing this option when signing in.

Contact information (provided when contacting sugarfree). You can provide us with your Contact Information, such as your phone number and email when you contact us with a question or request.

Location Data. We do not collect data about your exact location (address) in any case. We can collect data about your location, i.e. city, country or time zone. We collect this data automatically when you use our Services or play our Games.

Technical Data. We may collect such information as your IP addressand advertising ID on the devices that you use in our Services or play our Games. We can also collect non-personal Technical Data such as mobile operating system, device model, processor cores, mobile browser type, screen resolution, device vendor, language, total disk space, remaining disk space, username. We collect this data automatically when you use our Services or play our Games.

Usage Data. We collect and receive information on how you behave using our Services, i.e. during registration process, while playing games, during in-game purchases, the interaction with social networks, such as Facebook.

We can collect statistics on how you use our Services or play our Games. This information does not contain information that will help us identify you. We need this information so that we can provide you with the Services, improve their quality, adapt them to your needs.

We do not collect or store any financial data because the processing of your financial data is done by your chosen payment service provider, such as iTunes, Google Play, etc.

Data about consent regarding personal advertising. When you give us your consent regarding personal (contextual) advertising, we collect information about your consent – content of consent, date and time when consent is given, third-party controllers and processors to whom consent is disclosed etc. To find out more see section What should I know about personalised advertising.

We do not collect and do not intend to collect sensitive personal data of yours, such as any information about health, race, religion, political opinions or philosophical beliefs, sexual beliefs or orientation.

We do not collect any data that is not necessary for the provision of our services.

4. HOW WE COLLECT PERSONAL DATA?

We use several methods to collect Personal Data discussed further:

Personal Data is provided directly by you. You provide us with your data when you contact us by email, social networks or phone, ask to answer your question. By signing into our Services, you also provide us your personal information, such as Facebook name, last name, profile picture, email address.

We collect Personal Data automatically. When you use our Services, e.g. visit our website, play our games, we can automatically collect technical information, such as your IP address, advertising ID, promotional identifiers, mobile operating system, processor cores, screen resolution, device vendor, language, total disk space, remaining disk space, equipment, browsing actions and models you use, as well as statistics. We collect this Personal Data using cookies, automated event logs and other similar technologies.

NOTE: We do not collect Personal Data about you from third parties.

5. HOW WE USE PERSONAL DATA?

We will only use your Personal Data as permitted by law. Usually, we will use your Personal Data in the following circumstances:

In order to fulfil our obligations when you use our website or our mobile applications, e.g. to ensure that the Services are provided, to improve the Services, to personalize the content you use, to respond to your requests and inquiries.

When it is necessary to fulfil our contractual obligations or safeguard our legitimate interests, we use your Personal Data, e.g. to provide you with contextual advertising, to analyse your behaviour using our Services, to ensure the security and integrity of our Services.

We may also use your Personal Data to enforce or defend our rights, protect your interests, prevent and/or detect fraud or deceptive behaviour.

We will not use your data to provide you with behavioural advertising, as well as re-marketing, profiling and automated decision making. To find out more regarding advertising see section What should I know about personalised advertising.

6. ON WHAT LEGAL BASIS WE USE PERSONAL DATA?

Generally, we collect and process your personal information only in order to fulfil our obligations to you, use it for legitimate interests and protect your rights (support for the internal operations), or if we have your consent to do so.

Below, we provide you with information on the purposes and grounds for usage of your Personal Data.

Activity

Data type

Legal basis for data processing 
according to GDPR / COPPA

Manage and protect our website and our mobile applications

Contact Data

Necessary for our legitimate interests (GDPR)

Technical Data

 Necessary for fulfilling our contractual obligations (provide you with our services) (GDPR)

Usage Data

Necessary for our legitimate interests (GDPR)

Provide Services, improve Services, customize the Services for your individual needs

Personally Identifiable Data

Necessary for fulfilling our contractual obligations (GDPR)

If you choose to sign into our Services with your Facebook account and/or decide to use your Facebook name as Games username, we will process Facebook related data relying on your consent (GDPR).

If you choose to sign into our Services by using Apple authentication method, we will process your name and surname (as provided on your Apple account) and your email address (if you choose to disclose this data).

Technical Data

Necessary for fulfilling our contractual obligations (provide you with our services) (GDPR)

Usage Data

Necessary for fulfilling our contractual obligations (provide you with our services) (GDPR)

Submit contextual advertising to you, analyse your behaviour using our Services

Technical Data

Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR)

Usage Data

Necessary for our legitimate interests and for fulfilling our contractual obligations (provide you with our services) (GDPR)

Submit personalised (contextual) advertising to you, analyse your behaviour using our Services

Technical Data

Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR)

Data subject has given consent to the processing of his/her personal data (GDPR)

Usage Data

Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR)

Data subject has given consent to the processing of his/her personal data (GDPR)

Reply to your applications, requests, notifications

Contact Data

Necessary for fulfilling our contractual obligations and for legitimate interests (GDPR)

(email, phone)


We will use your Personal Data for the purposes for which we have collected them, unless we reasonably believe that we must use it for another purpose that is compatible with the original purpose.

Please note that where we must process Personal Data when required by law, we may process your Personal Data without your knowledge or consent.

7. WHAT ARE COOKIES?

When you use our services, we may use industry-wide technologies such as cookies and/or other technologies, hardware-based device identifiers, flash cookies, operating system-based identifiers and web beacons.

Cookies are small text files that we place in visitors’ computer browsers to store their preferences.

The cookies are created for each session, they do not include or collect any information about you other than your session key, and they are removed as soon as the session ends (usually done automatically by your web browser).

You can disable cookies on your device or set your device to alert you when cookies are being sent to your device.

If you do not accept, block or erase cookies, or change the settings, your online experience may be limited.

We may also use certain third-party cookies (e.g. Google Authentication). These are a different kind of cookie that is stored on your computer by third parties. This kind of cookie is only read (and is not altered by the Service) each time you use our Services. Third party cookies store only Usage Data, such as the different pages you have visited strictly within the Service (such the “About” page, the “Contact Us” page, the duration of your browsing session, etc.).

8. HOW CAN WE DISCLOSE YOUR PERSONAL DATA?

We may share your personal information with these persons:

(a) Companies of our group, third-party service providers and partners providing data processing services (e.g. to ensure the provision of our Services, to provide services or to improve our Services security), as well as to those who otherwise process Personal Data for the purposes specified in this Privacy Policy. Here is a list of our current service providers and partners (see section Our third party data controllers and processors).

b) To any competent law enforcement authority, regulatory authority, government agency, court, or other third party, if we consider that disclosure is necessary (i) in accordance with applicable laws or regulations, (ii) to exercise or to protect our rights, or (iii) to protect our or any other person's interests;

(c) A potential or actual buyer (and its representatives and advisers) involved in the purchase, merger or acquisition of a proposed or actual any part of our business, provided that we inform the buyer that it will have to use your Personal Data only for the purposes specified in this Privacy Policy;

(d) Any other person with your consent to disclose information.

9. WHAT SHOULD I KNOW ABOUT PERSONALISED ADVERTISING?

If you are not considered to be a child, we may use your Personal Data for personalised advertising reasons. Personal Data for personalised advertising are processed only if you give us consent to do so. We do not show personalised advertising ourselves. This activity is performed by our third-party data controllers and processors. We only collect your consent for this data processing activity, which is disclosed to our third-party data controllers and processors. You can find a detailed list of our third-party data controllers and processors in the section below “Our third-party data controllers and processors”. Third-party data controllers and processors may disclose your information to their third-party controllers and processors which adhere to strict confidentiality obligations and implement reasonable measures to secure Personal Data.

After your consent is given, you will receive personalised advertising only when you use our Services or play our Games.

You have the right to withdraw your consent at any time by emailing us at hello@sugarfree.games. Withdrawal of consent would mean that you would not get any personalised advertising anymore.

10. OUR THIRD-PARTY DATA CONTROLLERS AND PROCESSORS

KIDOZ
KIDOZ is an advertising service provided by KIDOZ Ltd. KIDOZ uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Chartboost (Chartboost, Inc.)
Chartboost is an advertising service provided by Chartboost, Inc. Chartboost uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: your consent and our legitimate interest (support for internal operations).

SuperAwesome Trading Ltd.
SuperAwesome is a contextual advertising service provided by SuperAwesome Trading Ltd. SuperAwesome uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interest (support for internal operations).

Flurry, Inc.
Flurry Inc. is an analytics service provided by Oath (Americas) Inc. Flurry uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google Analytics uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: your consent and our legitimate interests (support for internal operations).

AdMob by Google (Google Inc.)
AdMob is a mobile advertising platform which allows developers to monetize their app(s) by displaying in-app ads from other advertisers. AdMob allows to set TFUA (Tag for Users under the Age of Consent in Europe) on ad requests. All ad requests that include TFUA disables ads personalization for users under the age of consent and collection of data by third party partners. Admob uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: your consent and our legitimate interests (support for internal operations).

SafeDK Mobile Ltd.

SafeDK is an online data marketplace of software development kits provided by SafeDK Mobile Ltd. SafeDk uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

ironSource Mobile Ltd.

ironSource Mobile Ltd. is a network that connects app developers with advertisers, and helps app developers to serve ads on their apps, a mediation platform that helps app developers to manage all the ad providers with which they have a direct relationship and a marketing platform that helps advertisers to create and optimize advertising campaigns. ironSouce uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Vungle Limited

Vungle is an ad network providing a technology platform for clients that want to advertise and/or monetize their applications, games, and other products. Vungle uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: your consent and our legitimate interests (support for internal operations).

AdColony, Inc.

AdColony is an advertising service provided by AdColony, Inc. AdColony uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: your consent and our legitimate interests (support for internal operations).

Unity Technologies ApS.

Unity Ads is an advertising service provided by Unity Technologies ApS. Unity Ads uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: your consent and our legitimate interests (support for internal operations).

Unity Analytics (Unity Technologies)

Unity Analytics is a data platform that provides analytics. Unity Analytics uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Firebase by Google (Google Inc.)

Firebase is a mobile analytics platform which allows developers to analyse crash reporting and retention. Firebase uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

AppsFlyer Ltd.

AppsFlyer is a SaaS mobile marketing analytics and attribution platform. AppsFlyer uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

AppLovin Corporation

AppLovin is an advertising service provided by AppLovin Corporation, a Delaware corporation. AppLovin uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

GameAnalytics

GameAnalytics is game development and analytics services and resources, including but not limited to, various software applications, site profile services, game development analytics and game usage analytics, including users who access and use these services through a mobile device. GameAnalytics uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Facebook SDK

Facebook SDK is a tool integrating our Services with Facebook and providing analytics and advertising services.

Legal basis of processing: legitimate interests (support for internal operations).

Facebook Audience Network

Facebook Audience Network (by Facebook, Inc. and Facebook Ireland Limited) is an advertising service which uses Personal and Non-Personal Data only for advertising and other internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Pangle

Pangle is a mobile advertising platform, including support systems and services operated by Bytedance Pte. Ltd.

Legal basis of processing: legitimate interests (support for internal operations).

11. HOW WE PROTECT YOUR PERSONAL INFORMATION?

We have implemented security measures to ensure that your Personal Data is not lost, used or accessed without authorization, altered or disclosed. We restrict access to your Personal Data to those employees, representatives and other third parties who need to know your details. They will process your Personal Data in accordance with our instructions and will be subject to the confidentiality obligation.

We have put in place procedures to combat any alleged breach of Personal Data security and we will inform you and all authorities of the breaches that we are required to notify about.

12. HOW LONG WILL WE USE YOUR PERSONAL DATA?

We will only store your Personal Data to the extent required by the purposes of this Privacy Policy and to meet any legal, accounting or reporting requirements.

In order to determine the appropriate period of Personal Data storage, we will assess the amount, nature and sensitivity of Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve these objectives by other means and applicable legal requirements.

You can request to delete your data by emailing us at: hello@sugarfree.games.

13. WHERE WE STORE AND HOW WE TRANSFER YOUR DATA?

Your data is stored on rented and properly protected servers in Lithuania operated by company called “Interneto vizija” UAB (see their Privacy Policy).

However, your Personal Data may be transferred and processed in a country other than where you live. Personal Data protection in these countries may be different from the one in which you live.

Our service providers and partners operate globally. This means that when we collect your Personal Data, we can process it in any other country. Nevertheless, we will ensure that appropriate measures are taken to protect your Personal Data as provided for in this Privacy Policy.

This means that all our service providers and partners must process their Personal Data in such a way as to comply with the European Union's General Data Protection Regulation and other legislation.

14. WHAT RIGHTS DO YOU HAVE?

You have these Personal Data protection rights:

If you want to exercise all of the abovementioned rights, contact us at hello@sugarfree.games.

15. YOUR CALIFORNIA PRIVACY RIGHTS

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).

For more details about the personal information we’ve collected over the past 12 months, please see section ‘WHAT PERSONAL DATA WE COLLECT?’ above. We collect this information for the business and commercial purposes described in sections ‘HOW WE USE PERSONAL DATA?’ and ‘ON WHAT LEGAL BASIS WE USE PERSONAL DATA’ above. We share this information with the categories of third parties described in section ‘OUR THIRD-PARTY DATA CONTROLLERS AND PROCESSORS’ above.

We are committed to exercising your privacy rights, including the rights granted to you under the CCPA.

In accordance with the CCPA’s requirements, we will not discriminate against you for exercising any of your CCPA rights. You may make a request pursuant to your rights under the CCPA by contacting us via email (hello@sugarfree.games) or by mail using the contact details set out below.

You may request to opt out of the sale of your personal information to third parties. The CCPA defines a sale very broadly and this includes showing you a contextual (personalised) ads while you are using our apps.

We would never sell your data for profit, however, where we transfer it to our partners for things like displaying personalized ads to you or to deliver improvements to our service, these uses fall within the broad definition of a “sale” under CCPA. We only engage in this kind of data transfer where we believe it benefits you by providing you with a better experience, quality of service or to deliver content that you may be interested in.

You can opt out from any practice that may lead to the sale of your personal data at any time. To manage your privacy preferences and opt out of the sale of your personal information, please contact us via email hello@sugarfree.games.

 

16. HOW TO CONTACT US?

You can contact us at any time with any of your Personal Data protection issues at:

UAB “Edukacinės sistemos”

Studentų g. 3A-11, LT-50232 Kaunas, Lithuania

Phone: +370 37 300 833

Email: hello@sugarfree.games

We will respond to all your requests within the shortest possible time.