Crazy Labs Apps – Privacy Policy for Users in the EEA and UK

Last Revised: May 5, 2021

Crazy Labs Ltd., its subsidiaries and affiliates (“Company” or “we” ) respects the privacy of the users (“User” or “you”) of the mobile applications we distribute (“Apps”) and are committed to protect Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps.

IMPORTANT – We operate Apps for all ages:

Apps distributed within our developer account under the brand “Crazy Labs” that do not include an age-gate and are intended for general audiences (“Crazy Labs Apps”), which are subject to our Crazy Labs Privacy Policy (defined below).
Apps distributed within our other developer accounts (except for Crazy Labs account) that do not include an age-gate and are treated as primarily directed at children (“Children Apps”), which are subject to our Children Privacy Policy (defined below).
Apps that include an age-gate and are not primarily directed at children but may appeal to them. Users of such Apps who indicate they are under the age of sixteen (16) are subject to our Children Privacy Policy, and Users of such Apps who indicate they are over the age of sixteen (16) are subject to our Crazy Labs Privacy Policy.

By “Children Privacy Policy” we refer to our privacy practices and principles described in Chapters A and C below. By “Crazy Labs Privacy Policy” we mean our privacy practices and principles described in Chapters B and C below.

Note that the “Children Privacy Policy” (Chapter A below) and the “Crazy Labs Privacy Policy” (Chapter B below), and each together with Chapter C detailed below, shall be referred to collectively as “this Privacy Policy”.

Capitalized terms not defined in this Privacy Policy shall have the meaning given to them to them in our Apps terms of use available at: https://crazylabs.com/atou (“TOU“).

If you are a child, please ensure that your legal guardian has reviewed this Privacy Policy.

Chapter A: Children Privacy Policy

This Children Privacy Policy is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding children using our Children Apps and Users who indicate at an age-gate in our Apps that they are under 16. For the purposes of Chapter A, the term “Children Apps” will include the age-gated section of Apps accessible only to Users indicating they are under 16, and “children” will include Users indicating at an age-gate that they are under 16.

We do not knowingly collect any personal information from children other than as expressly specified in Sections 2.2 and 2.3 below.

We hereby prohibit children from actively and directly providing us with any personal information other than as specified in Section 2.3 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 2, 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).

Third party providers of certain products or services, such as advertising providers, tracking services, analytics services etc. (“Third Parties”) may passively collect and maintain information about Users. Some of these Third Parties act on our behalf under our instructions. Others act independently as controllers of personal information in their own right. Such Third Parties are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider (such as Apple or Google) in performance of their services .

Such Third Parties are included in a list at: https://crazylabs.com/3rdp. Any question about Third Parties’ privacy practices and policies should be directed to our Privacy Policy Administrator by e-mail to: [email protected]. We will forward your inquiry to the applicable Third Party and make an effort to provide you with such Third Party’s response within a reasonable timeframe.

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).

1. 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.

2. Online Use

There are three types of data and information which may be collected from Users of our Children Apps:

2.1 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 the 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 16), and geo-location – only at a country level. It is hereby clarified that no street name is collected.

2.2 Children’ Persistent Device Identifier and No Other children personal identifiable information: We and our 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, any microphone and camera sensor data or any sensitive device data concerning children.

2.3 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:

(i) providing and improving Children Apps as well as ensuring proper functioning of the Apps and services;
(ii) maintaining or analyzing the functioning of Children Apps and services;
(iii) authenticating purchases by Users in the app stores (to provide in-app purchases);
(iv) personalizing content and enhancing User experience;
(v) performing network communications;
(vi) protecting the security or integrity of Users, Children Apps and services;
(vii) serving contextual advertisements;
(viii) capping the frequency of advertising;
(ix) ensuring legal or regulatory compliance;
(x) fulfilling a User’s request under Section 2.3.

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 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 the Children Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Children Apps, such as “cookies-like technology” and local storage (see Section 18 below for further details on Cookies and Local Storage).

If Third Parties collect Non-personal Information, Children Persistent Device Identifier and/or any other information directly from children, such collection and processing is governed by such Third Parties’ privacy policies and not by this Privacy Policy. However, all Third Parties are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider in performance of their services .

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 Apps 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 an 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.

3. Sharing Children information with third parties

We may share the Children Persistent Device Identifier only in limited cases, including the following:

a. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
b. to enforce this Children Privacy Policy or the Terms of Use, including investigation of potential violations thereof;
c. to detect, prevent, or otherwise address fraud, security or technical issues;
d. to protect the rights, property, or personal safety of the Company, its Users, suppliers, licensors, and/or licensees, or the general public;
e. when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
f. pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or the User of Children Apps may have requested from the Company.

To clarify, we may transfer and disclose Children Non-personal Information to third parties at its discretion.

4. Advertising

We accept ads from Third Party ad networks which may be displayed in Children Apps. These Third Parties ad networks are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and Platform Providers’ rules, policies and guidelines. Note that if the User of Children Apps clicks on any of these ads, the User will leave our Children Apps and go to the advertisers’ site which the User selected, and the advertisers may use cookies and other tracking technologies to collect Non-personal Information and/or children personally identifiable information. We recommend that children and their legal guardians review the terms of use and privacy policies of these advertisers. Their privacy policy, not ours, will apply to any of those interactions. We may also promote Children Apps in Third Parties’ applications and platforms.

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.

5. Additional Terms and Conditions

See further terms and conditions which also apply to Users of Children Apps in Chapter C below: “Terms and Conditions Common to Both Children Privacy Policy and Crazy Labs Privacy Policy”.

Chapter B: Crazy Labs Apps Privacy Policy

This Crazy Labs Privacy Policy is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding Users of our Crazy Labs Apps and Users who indicate at an age gate in our Children Apps that they are above the age of 16. For the purposes of Chapter B, the term “Crazy Labs Apps” will include the age-gated section of Children Apps accessible only to Users indicating they are above the age of 16.

6. 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:

6.1 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 2.1 above.

6.2 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:

the User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;
the User’s persistent device identifier such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address. We keep IP addresses for 1 week for error logs and then delete them. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable Platform Provider’s rules, policies and guidelines.

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 17.

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.

7. How is the Information about Our Users collected?

7.1 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 SDK 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 16 below for further details with respect to Cookies and Local Storage).

7.2 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 16 below for further details about Cookies and Local Storage).

7.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides us 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).

8. What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:

● Use it for statistical, analytical and research or business intelligence purposes (e.g., to track trends within our Crazy Labs Apps, for reports and for public relations purposes); and for customization, development and improvement of our Crazy Labs Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on behavior and preferences shown by Users usage within the Crazy Labs Apps).

● Measure traffic and usage on the Crazy Labs Apps.

● Promote our Apps.

Personal Information is collected in order to:

● Personalize and enhance the Users’ experience while using the Crazy Labs Apps.

● Improve the Crazy Labs Apps.

● Provide the Users with personalized content and information, including customized ads, interest-based ads, targeted ads, etc.

● Enable certain ad serving features, such as frequency capping etc.

● Ensure proper functioning of the Apps and services, respond to questions or requests which were provided using the “Ask a Question” feature.

● Enable certain functionalities available within the Apps, such as the Game Center Features, Social Features and the features which are available while using the “Log in with Facebook” feature.

● Provide Users with updated information regarding our products and services, including about competitions which we may hold, where Users have asked us to do so.

● To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User’s participation.

● Authentication purposes including to verify clicks and/or installs, verify User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.

● Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the User (i.e. behavioral ads).

● Any other purpose explained at the time of collection.

9. Sharing Information with other third parties

In addition to the sharing of Personal Information with Third Parties described in sections 6-8, we may share Personal Information in the following cases:

a. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

b. to enforce this Privacy Policy and/or the TOU and other of our terms or policies, including investigation of potential violations of such policies;

c. to detect, prevent, or otherwise address fraud, security or technical issues;

d. to respond to claims that any content published on the Crazy Labs Apps violates any right of a third-party;

e. to protect the rights, property or personal safety of the Company, its Users, suppliers, licensors, licensees or the general public;

f. when the Company undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case your Personal Information may also be disclosed, transferred and/or assigned;

g. pursuant to your explicit approval prior to the disclosure;

h. as part of a competition, receiving rewards or otherwise interact with our social media channels..

For clarity, 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.

10. Advertisements

We accept ads in various formats (such as banners, interstitials, rewarded videos, etc.) from Third Party ad networks which may be displayed in our Crazy Labs Apps. These Third Party ad networks may collect and use: (i) information about your visits to Crazy Labs Apps in connection with such marketing, sales and advertising activities; and (ii) geographic tracking and carrier network preferences; (iii) information, such as age, gender and other information logged from your device to ensure that appropriate advertising is presented within the App, to calculate or control the number of views of an ad, to deliver ads relating to User’s interests and to measure the effectiveness of ad campaigns. The delivery of ads to you may be based on IP address, device identifiers and other Personal Information gathered during your use of the Crazy Labs Apps. You may also be presented with non-personalised or non-targeted ads, i.e. ads which are not directed towards specific Users but are rather broadly posted onto random Apps. If you have chosen to receive non-personalized ads only within our Apps, please be aware that you may still see some targeted ads served by third parties if you have separately (e.g. on that third party’s website or app) provided consent to personalized advertising directly to those third parties. You can find the list of Third Parties ad networks providing services in relation to Crazy Labs Apps at: https://crazylabs.com/3rdp. Note that if you click on any of these ads, the advertisers may use cookies and other tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) on your device to collect data regarding ad performance, your interaction with such ads and our Crazy Labs Apps and your interests (which may include, non-personal and/or personal information such as, device and network information, unique identifiers, gender, age and geo-location about you) in order to serve you ads, including targeted ads, and for the legitimate business interests of such Third Parties ad networks. We recommend that you review the terms of use and privacy policy of any third party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

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.

One Third Party we work with in relation to our general audience apps is TikTok. TikTok and Crazy Labs act as joint controllers (this is where two or more orgnisations jointly determine how and why personal data is processed) when we collect and transmit personal data to TikTok in connection with the following activities:

● measurement and insight reporting;

● audience creation and ad targeting; and

● improving, optimising and personalising ads.

Further information on how TikTok processes personal data, including the legal basis TikTok relies on and the ways you can exercise your rights withTikTok, can be found in TikTok’s privacy notice (https://www.tiktok.com/legal/privacy-policy-eea?lang=en) .

We and TikTok have entered into a written agreement which sets out our respective responsibilities for compliance with the applicable data protection law obligations. We have agreed with TikTok that we (Crazy Labs) are responsible for providing Users with the information contained in this section, and that TikTok is responsible for dealing with requests from Users to exercise their data protection rights in relation to personal data stored by TikTok after the end of the joint processing.

11. 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”).

The Game Center Features and Social Networks and Platforms are created and maintained by third parties who are not affiliated with and/or controlled by us. If you enable this integration, your use of the Game Center Features and/or the Social Features is subject to the terms of use and privacy policies of the applicable third party provider of the Social Network’s or Platform (for example, Apple Game Center which terms are available at: http://www.apple.com/legal/internet-services/itunes/gamecenter/us/terms.html; Google Play Games which terms are available at: https://play.google.com/store/apps/details?id=com.google.android.play.games;). You should ensure that you read their terms of use and privacy policies to understand how they treat your information and to understand the methods for changing the privacy or sharing settings on such services. If you do not agree to the practices described in such terms you should not allow our Crazy Labs Apps to interact with such Social Networks or Platforms, however you may find that you are not able to enjoy all the features that may be made available by our Crazy Labs Apps. You understand that where you allow interaction with any third party Social Network or Platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy social elements. This data may include your scores and/or progress in our Crazy Labs Apps, your name, your social media profile picture and any test that you may upload.

By using the Social Features and/or the Game Center Features you 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 acknowledge that when you share content via Social Networks or Platforms your content may become public and any person may re-post-it.

12. Additional Terms and Conditions

See further terms and conditions which also apply to Users of the Crazy Labs Apps in Chapter C below: “Terms and Conditions Common to both Children Privacy Policy and Crazy Labs Privacy Policy”.

Chapter C: Terms and Conditions Common to both Children Privacy Policy and Crazy Labs Apps Privacy Policy

13. Third Party Providers

When you use the Apps Third Parties may collect, store and/or process the information detailed in this Privacy Policy. You may find the list of Third Parties at: https://crazylabs.com/3rdp. These Third Parties are carefully selected to ensure that they, and their related entities who may access Your information, provide Your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws and the Platform Providers’ rules, policies and guidelines. We use commercially reasonable efforts to engage with Third Parties that post a privacy policy governing their collection, retention, processing and use of non-personal and personal information. For further information regarding the collection, processing and usage of your information by the Third Parties, please review their privacy policy practices.

14. 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.

15. Links to third party sites

Certain links provided in the Apps through ads or otherwise permit Users to leave our Apps and enter third party sites, products or services. These linked sites, products and services are not under our control . Most of such linked sites, products and services provide legal documents, including terms of use and privacy policies, governing the use of these sites. It is always advisable to read such documents carefully before using those sites and services so that you know what kind of information they are collecting.

16. Cookies & Local Storage

When you access or use the Apps, we and/or our Third Parties may use industry-wide technologies such as “cookies”, web beacons, tags and local storage (or other similar technologies), which store certain local information on your device (“Local Storage”), to identify a User’s device and ‘remember’ things about the User which may enable automatic activation of certain features (for example, if a User muted the sound within the App at a certain stage, this preference will be stored in the cache on the device and maintained the next time the User accesses the App on his device), monitoring of use of the Apps (counting Users who visit certain pages, use certain tools, viewed certain advertisements), frequency capping (for example, if we promote another App, this ensures that we do not advertise the same App more than a set number of times), to improve the quality of our services, measure ad performance, provide relevant ads etc. and making the User’s App experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User’s device. We and/or our Third Parties may access such information. Third Parties may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Apps may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier and geo-location data, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, including via uninstalling the App from your mobile device and/or through the Settings option of your device. Most browsers and platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your device or according to the specific instructions provided by the technology provider and/or Third Parties privacy policies and terms of use. However, if you block or erase cookies, or change the settings of your device, your App experience may be affected and may be limited.

17.“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.

iOS Device

● iOS device with iOS 7 or a newer version (up to iOS 14): go to Settings/Privacy/Advertising and select resetting advertising identifier or limiting ad tracking setting.
● iOS device with iOS 14: go to Settings/Privacy/Tracking and disable tracking across all apps on your device or on a per App basis.

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.

Android Device

● Google Android device with Android 2.3 or a later version, go to Settings/Google/Ads and enable “Opt Out of Ads Personalization”.

You have the right to withdraw your consent to sharing your Personal Information for the purposes of personalized ads at any time by going to the applicable Crazy Labs App settings, clicking the Privacy Settings option and toggling the disable personalized ads button. This will withdraw consent to such processing across all Crazy Labs Apps within the same developer account on the applicable online store.

18. 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). 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 or UK Supervisory Authority.

19.Retention of Information

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 fulfill 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.

20. Security

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.

21. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Apps and any information collected therein. We reserve the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Apps and/or our website at https://crazylabs.com/. Such material changes will take effect five (5) days after such notice was provided on our App and/or Site, whichever is the earlier. Otherwise, all other Changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Apps on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

22. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: [email protected] and we will make an effort to reply within a reasonable timeframe. You can also write to us at: Crazy Labs Ltd., 24 Raoul Wallenberg Street, Tel Aviv, Israel.

Crazy Labs is the controller of your Personal Information and can be contacted using the details given in the “Got any questions?” section below. Our representative in the EU can be contacted at CrazyLabsEUrep@bmdataservices.co.uk. Our representative in the UK can be contacted at [email protected].

23. What legal bases do we use for processing your personal information?

We process your Personal Information on one of the following legal bases:

Performance of a contract: We use this ground where we process Personal Information to provide you with a service that you have requested e.g. to provide you with access to our Apps, to provide you with customer services and support, to enable in-app purchases you make and to deliver Game Center Features and Social Features.
Legitimate Interests:
Based on our legitimate interests in making sure you get the best game experience we process Personal Information to:
- Provide and maintain our Apps, including fixing problems, troubleshooting etc;
- Improve and optimise game experience;
- Carry out analytics to understand how our games are working and how users interact with them which allows us to ensure that the games function properly and to improve our games;
- Personalise your experience within our Apps.
Based on our legitimate interests in ensuring a safe environment for users and protecting our operations we process Personal Information to:
- Detect and prevent fraud and other unauthorised behaviours;
- Provide the Apps securely;
- Establish, exercise or defend our legal rights;
- Monitor the use of our Apps and where necessary enforce our terms of use.
Based on our legitimate interests in promoting our services, being competitive in the market place and enabling us to offer Apps free of charge/at low cost, we process Personal Information, including in connection with advertisements to:
Keep track of installations of our Apps including how a user reaches us;
Promote our own products and services in the context of cross promotions;
Ensure the basic display, functioning and measuring of advertisements (g. displaying the ads, linking the ads to views and installs, limiting the number of times the same ads are shown);
Carry out related analytics to ensure that the ads are working, optimised and displayed correctly and to measure the effectiveness of ads.
In all of these cases we will look after your information at all times in a way that is proportionate and respects Your privacy rights and You have a right to object to processing as explained in the “Your Rights” section below.
Consent: We rely on your consent to process your Personal Information for targeted advertising, and to share Personal Information with Third Parties for these purposes. We ask for this consent when you download and access our App.
- If you provide consent to processing for these purposes, please be aware that this consent covers such processing in this App and any other Apps within the same developer account (i.e. Crazy Labs or Coco Play) on the applicable online store that you download and use. You can withdraw consent at any time by adjusting the privacy settings within the App as described in section ‎17 above. This will withdraw your consent across all Apps within the same developer account (Crazy Labs or Coco Play as applicable) on the applicable online store which you have downloaded and are using. Within the privacy settings of the App you will also find an option to request deletion of your Personal Information by clicking on the “forget me” button.
Legal Obligation: In certain circumstances, we may be required to comply with a legal obligation or by a court, regulator or law enforcement agency to process Personal Information for specific purposes or to share it with such an authority. This would only be after due consideration of the request and legal means available to respond thereto.

24. Your rights

As well as the rights explained in Chapter C, users in the EEA and UK have the following additional rights (please note that these are subject to certain exemptions and in some cases dependent on the processing being undertaken):

Right to access Personal Information

You have a right to request that we provide you with a copy of your Personal Information that we hold and you have the right to be informed of: (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.

Right to rectify or erase Personal Information

You have a right to request that we rectify inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it.

You can also request that we erase your Personal Information in limited circumstances, for example, where it is no longer necessary for the purposes for which it was collected, or where our processing was based on consent, and you withdraw your consent.

If Third Parties have collected your Personal Information through the Apps, we will use reasonable efforts to inform the Third Parties of your request for deletion.

If you have shared your Personal Information via any Social Network or third party Platform we cannot amend or delete this information. 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.

Right to restrict the processing of your Personal Information in certain instances

Right to transfer your Personal Information

You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

the processing is based on your consent or on the performance of a contract with you; and
the processing is carried out by automated means.

Right to object to the processing of your Personal Information

You can object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

If you want to opt out of all future collection of your Personal Data by us and our Third Parties, you can do this by uninstalling the Apps from your devices.

Right to obtain a copy of Personal Information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside of the EEA and UK. We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.