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
By submitting you acknowledge that the information you submit will be used according to our