Last Revised: May 5, 2021
1. Your consent (important, please read carefully!)
We hereby prohibit children from actively and directly providing us with any personal information other than as specified in Section 3.3 below. If you are a legal guardian of a child and believe your child has provided us with any personal information, please contact us at [email protected] and we will delete such information from our servers.
We may collect and maintain the information described in Section 3, directly or through certain products or services, solely for providing support for our internal operations as permitted under applicable laws and rules (described in greater detail below).
We include an age-gate in certain Apps to prevent access to specific features to Users who indicate they are under the age of 16 for their protection (e.g. restricting behavioral advertising or information sharing by children).
2. Offline Use
We allow an offline use (without Internet connection and without GPS enablement) of some features of our Children Apps. Offline use of Children Apps will preclude collection by us and/or Third Parties of any information pertaining to the User and its use of the Children Apps.
3. Online Use
There are three types of data and information which may be collected from Users of our Children Apps:
3.1 Non-personal Information: We and our Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such children Non-personal Information, we and our Third Parties are not aware of the identity of the User from whom children Non-personal Information has been collected. Children Non-personal Information collected by us or our 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 Children 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 gameplay (e.g. level reached, frequency and time spent in the Children 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. Children 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.), our other installed Apps, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13 or the minimum age of majority), and geo-location – only at a country. It is hereby clarified that no street name is collected.
3.2 Children’ Persistent Device Identifier and No Other children personal identifiable information:
We and Third Parties may passively collect a persistent device identifier from children, such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address (“Children Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Children Apps. In the case of IP addresses, we keep these for 1 week for error logs, then delete them. We do not collect and do not permit Third Parties to collect from children 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 children. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.
We do not link any additional personally identifiable information to the Children Persistent Device Identifier, even from other services.
We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, or any sensitive device data concerning children.
3.3 Information gathered through Children Apps “Ask a Question” or “Support” type of a feature:
If a child e-mails a question to us, using the “Ask a Question” or “Support” type of a feature which may be available within Children Apps, we may respond to such question by using the child’s e-mail address. Promptly after responding (or, at our discretion, not responding) to such question, we will delete the child’s e-mail address.
Purpose of the collection: The information described above is collected and processed solely for the purpose of supporting our internal operations. This means the following:
The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.
How is the Information about our Users of Children Apps being collected? The Non-personal Information and Children Persistent Device Identifier are collected either by us or our Third Parties through the Users’ use of Children Apps, including through Third Parties’ SDKs embedded in our Children Apps. Non-personal Information and Children Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within Children Apps, such as “cookies-like technology” and local storage (see Section 17 below for further details on Cookies and Local Storage).
In addition to the processing of information described in this policy, some of our Apps may also access Personal and Non-personal Information but without Crazy Labs carrying out any processing. In these cases, an App may access the information but it is not transmitted outside of your device and Crazy Labs does not collect or use it in any way. An App may access information in this way in order to provide functionality necessary for particular features of the App.
Face Manipulation feature. Some Apps may include a functionality which allows you to take a picture or create a video using your camera and microphone. Some Apps may allow Users to apply filters or edit photos and videos created via the App and use them within the App (for example to add to a simulated ‘social media feed’ in the App). This functionality is optional and you can always use the App without it. If you use this feature then you will need to grant the App permission to access your device’s camera and microphone (which can be revoked at any time through your device’s settings and its revocation will not affect your use of the App). Photos and Videos created via the App will be automatically saved in the App’s gallery and will be retained until you delete them from the App gallery or uninstall the App. You may also save these photos or videos in your device’s gallery, if you grant the App permission to approach it, and they will be retained there until you delete them from the device’s gallery. The App does not collect any face data, and the photos and videos that you create are restricted to the App, locally stored and are not transmitted to the Company’s servers and are not used or accessed by the Company. The App does not grant access to, share or disclose to any third party any of the photos and videos you create via the App, but Users who are 16 years old or older may share such photos and videos from within the App via the device operating system’s share functionality. Such sharing will be governed by the policies of the applicable Social Network or third party Platform.
4. Sharing children information with third parties
We may share the Children Persistent Device Identifier only in limited cases, including the following:
To clarify, we may transfer and disclose Children Non-personal Information to third parties at our discretion.
In addition, we may advertise our other Apps within Children Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random Apps.
6. Additional Terms and Conditions
7. Which information may be processed from Users of our Crazy Labs Apps?
There are two types of information which may be processed about Users of our Crazy Labs Apps:
7.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). We and our Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to us and/or our Third Parties through use by Users of the Crazy Labs Apps. For details of the categories of data constituting Non-personal Information please refer to Section 3.1 above. Some jurisdictions consider this information to be personal information, for more detail about those areas see section 20.2 below.
7.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.
● Facebook Login feature: Some older versions of certain Crazy Labs Apps may still include the “Log in with Facebook” feature (which functionality is described in the TOU), and if a User uses this feature, then Facebook provides us with access to (i) certain information about such User as is stored in the User’s Facebook account, namely, the User’s public profile, list of friends and any other information which is detailed to the User in the notice which appears during the “Log in with Facebook” process. Please read carefully such notice to understand what information is available to us via Facebook and (ii) information available in the Facebook Page Insights of the applicable Crazy Labs App. We only collect the identifier number of the User’s Facebook account (i.e. Facebook access token). Such Apps may process User’s Facebook profile name, a link to the User’s Facebook profile picture User’s e-mail and the User’s Facebook friends who installed the applicable Crazy Labs App, to enable you to interact with your Facebook friends including by sharing with other Users your name, profile picture and game data as described below. Please remember that the manner in which Facebook uses, stores and discloses your information is governed solely by its policies and the Company shall have no liability or responsibility for the privacy practices or other actions of Facebook that may take place within such Crazy Labs Apps. If the User uses the “Log in with Facebook” feature, then such User agrees, when clicking the Facebook connect or login button, that the App may share his/her name and/or profile picture and/or his/her game data with respect to the applicable Crazy Labs Apps, with Users who also used the “Log in with Facebook” feature in connection with the applicable Crazy Labs App or with the User’s Facebook friends. If you do not agree to these practices please do not use the “Log in with Facebook” feature.
● Game Center Features: If a User enables Game Center Features (defined in our TOU) in Crazy Labs Apps, then we will be provided with access to the identifier number of the User’s Game Center account (i.e. access token).
In addition, we may collect and/or process, directly or through Third Parties, the following Personal Information:
In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 18.
To clarify, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
We do 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 Users.
In addition to the processing of information described in this policy, some of our Apps may also access Personal and Non-personal Information but without Crazy Labs carrying out any processing. In these cases, the App may access the information but it is not transmitted outside of your device and Crazy Labs does not collect or use it in any way. An App may access information in this way in order to provide functionality necessary for particular features of the App.
8. How is the Information about Our Users collected?
8.1 Non-personal Information may be collected through your use of the Crazy Labs Apps. In other words, when you are using a Crazy Labs App, we and our Third Parties are aware of it and may gather information relating to such usage, through the Crazy Labs Apps, APIs or SDKs embedded in our Crazy Labs Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the Crazy Labs Apps, such as “cookies” and local storage (see Section 17 below for further details with respect to Cookies and Local Storage).
8.2 Personal Information which you provide us directly and/or through Third Parties via your installation and/or use of the Crazy Labs Apps or your behavior to ads inside such Apps. This information is collected via the Crazy Labs Apps or such Third Parties’ APIs or SDKs embedded in our Crazy Labs Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the Crazy Labs Apps, such as “cookies” and local storage (see Section 17 below for further details about Cookies and Local Storage).
8.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides through the Crazy Labs Apps “Ask a Question” type of feature. In addition, we collect Personal Information which you voluntarily provide when you use the Facebook login feature (detailed above).
9. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
Personal Information is collected in order to:
10. Sharing Information with other third parties
In addition to the sharing of Personal Information with Third Parties described in sections 7-9, we may share Personal Information in the following cases:
For clarify, we may transfer and disclose Non-personal Information to third parties at our discretion.
Please note that some of the Crazy Labs Apps may allow Users to create their own content, such as images, photos, videos and other material (for example, Face Manipulation feature) (“User Generated Content”) and may include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. We do not access, use, collect or share this User Generated Content in any way. It is restricted to the specific App, stored locally on your device and is not transmitted to Crazy Labs servers. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.
We may promote Crazy Labs Apps in Third Parties applications and platforms. In addition, we may, at our discretion, advertise our other Apps within the Crazy Labs Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random Apps.
12. Using Game Center Features and Social Features
Our Crazy Lab Apps may enable using certain Game Center Features and may include Social Features (defined in our TOU). The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”).
By using the Social Features and/or the Game Center Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby understand and agree that when you share content via Social Networks or Platforms your content may become public and any person may re-post-it.
13. Additional Terms and Conditions
14. Third Party Providers
15. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. We do not exercise control of such third parties and are not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.
16. Links to third party sites
17. Cookies & Local Storage
18. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. You can find the applicable settings for your device by following the instructions below. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent such options exist) may not cease all tracking activities by our Third Parties’ service providers.
If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such Third Parties and follow the instructions specified therein. You can see a list of our Third Parties at https://crazylabs.com/3rdp with instructions on how to opt-out when available.
Electing to opt-out will not stop advertising from appearing in your browser or applications, but may make the ads you see less relevant to your interests, and the companies you select may still collect information for other purposes, such as research, analytics, and internal operations. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choice.
If you gave permission to be tracked in a particular App on a device with iOS 14, you can withdraw your tracking permission from settings by tapping on the particular App and turning off Allow Tracking, or you can go to settings/privacy/tracking and tap to turn off any App displayed in the list of apps that requested permission to track you.
You can also limit targeted advertising by Apple within your device settings in Settings/Privacy/Apple Advertising settings.
19. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, wherever your Personal Information is transferred we will take reasonable steps to ensure the protection of your Personal Information (such as making transfers subject to standard contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. You can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
20. California Privacy Rights
20.1 To the extent applicable, if you are a California resident under the age of 18 and a User, California Business and Professions Code Section 22581 may permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.
Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
20.2 This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.
Personal Information We Collect, Disclose for a Business Purpose and Sell. We collect the categories of personal information about California consumers identified in the chart below. As further set forth in the chart below, in the past 12 months we have disclosed and “sold” (as defined in the CCPA) California consumers’ personal information to third parties for business or commercial purposes.
Fulfilment services; Facilitating transactions;
Auditing related to our interactions with you;
Detecting and protecting against security incidents, fraud, and illegal activity;
Performing services (for us or our service providers) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Activities to maintain and improve our services; and
Other one-time uses
Service providers; and
Internet or other electronic network activity information (such as interactions with an application, or advertisement)
Affiliates not under the Crazy Labs brand
Fulfillment services; Facilitating transactions;
Detecting and protecting against security incidents, fraud, and illegal activity; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
App store providers;
Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
Activities to maintain and improve our services
Inferences drawn from the above information about your predicted characteristics and preferences
Affiliates that are not under common branding
Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
To exercise any of the above rights, please contact us by email to: [email protected] or online by using this webform and submit the required verifying information.
You may also exercise the right to opt out of our sale(s) of your personal information by clicking the “Do not sell my Personal Info” button (or a similarly named option) available within the privacy settings of some of our Apps. This will stop our sale of your personal information within such Apps. You will still receive advertising that helps us provide our Apps to you.
If you reset your advertising identifier (IDFA, Advertising ID), your request to opt out of sale will not apply to your new advertising identifier and you will need to select this setting again.
We do not sell the personal information of Users located in California who we know to be less than the age of 16.
Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum information verifying your identity and providing the agent, where applicable, with written permission to make the request for you. You may designate an authorized agent to make a CCPA request on your behalf by completing this form and providing it to us.
21. Deletion and Modifications of Information
You or, as applicable, your legal guardian or agent, may request, by sending us an email to [email protected], the following:
a. to receive access to, amend, and/or delete your Personal Information and/or, as applicable, Children Persistent Device Identifier, that we may hold, and/or that we cease collection or use of your Personal Information; and/or
b. that we request Third Parties who collected through the Apps the User’s Personal Information and/or, as applicable, the Children Persistent Device Identifier, to do the same. We will use reasonable efforts to ensure that such Third Parties do so.
For some of our Apps we may develop in-app deletion request functionality which can be used by you in addition to the address above.
After you have stopped using the Apps, we will retain User’s Personal Information, and, as applicable, Children Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfil the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, and/or to enforce these Terms and our agreements, all as permitted under applicable privacy laws.
Personal Information that a User has shared using our Crazy Labs Apps via any Social Network or third party Platform cannot be amended or deleted by us, where such information is in the control of that Social Network or third party Platform. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps. Aggregate and/or anonymous information may remain on our servers indefinitely.
Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. TO THE FULLEST EXTENT PERMITTED BY LAW THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.
24. Got any Questions?