Super Stylist – Privacy Policy for Users in the EEA and UK

Last Revised: April 7, 2022

Crazy Labs Ltd., its subsidiaries and affiliates (“CrazyLabs” or “we””) respects the privacy of the users (“User” or “you”) of the Super Stylist app (“App” or “Super Stylist”) 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 App. This Super Stylist Privacy Policy (“Privacy Policy”) aims to give you information about how we process your personal information in relation to your use of the App.

Crazy Labs Ltd is the controller of your personal information and can be contacted using the details given in the “Got any questions?” section below.

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

Super Stylist is not intended for anyone under the age of 16 and we do not knowingly collect personal information of children under this age. If a parent or guardian becomes aware that their child under 16 years of age has provided us with personal information, please contact us using the details in section 13 and we will delete this information.

If you are under the age of eighteen (18), please ensure that your legal guardian has reviewed this Privacy Policy.

1. What information do we collect and use?

There are 3 main ways in which we collect or use information about you:

1.1 Information collected automatically when you use the App

We collect information when you use the App, independently or through use of third parties, including through APIs and SDKs embedded in the App and via generally accepted industry technologies such as “cookies” and local storage (see Section 6 below for further information on cookies and local storage). Third party advertising partners and other service providers also collect information in this way, and further details can be found in section 3 and 4.

The information collected through your use of the App includes:

information about your device such as the type and version of your device’s operating system (e.g. Android, iOS etc), the App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone etc), what other CrazyLabs apps are installed on your device, and country-level location of your device;
data relating to User activity and behaviour within the App such as data about how and when you play the game, achievements/actions within the game (e.g. rewards received, in-App purchases made, virtual items held) and events within the game;
data relating to User’s interaction with third party ads in the App (e.g. ad impressions, User’s response to ads, including ads viewed or clicked) and data relating to your interactions with ads for the App on third party sites (e.g. which ads you viewed, on which applications or sites, information about installation of the App);
data relating to the functioning of the App (e.g. performance errors and problems);
User’s device identifiers such as advertising identifier (IDFA, Advertising ID), randomly generated User ID, third party identifiers (e.g. Facebook ID or Apple ID if you log in to the App through such third party) and IP address.

1.2 Information you provide to us

You may provide information to us voluntarily when you contact our customer support or in-App support, for example, your email address and/or details of your query or problem.

1.3 Information collected from third parties

We also collect and/or use information from third parties in the following ways:

The App enables you to connect to your Facebook account using the “Log in with Facebook” feature (as described in the TOU):
- This feature allows us to save your game progress across multiple devices. When you use this feature, Facebook provides us with access to, and the App may process, certain information about you which is stored in your Facebook account, namely your public profile name, picture and its URL, Facebook identifier number and any other information which is explained to you in the notice which appears during the “Log in with Facebook” process. Please note that Facebook’s use of your personal information is governed by its own policies which you should read carefully to understand what information is available to us via Facebook. You can always revoke such access you may have given us and delete your App data from Facebook by going to your Facebook account’s Off-Facebook Activity page and using the “disconnect future activity” and “clear history” options available there.
- If you use this feature, you agree when clicking the Facebook connect or login button, that you will see your public profile name and picture within the App and that the App may show these to other Android Users on the leaderboard within the AppIf you do not want to share this information with the App you can edit the information that will be shared with the App in the Facebook permission request notice that appears during the login process.
We receive information from third party service providers such as our attribution provider (e.g. when a person views or clicks on an ad for the App or when a User installs the App).
We receive information from third party advertising partners which relates to the performance of our advertising campaigns for the App on our partners’ channels (e.g. which ads, sites, applications and campaigns a User came from, install data etc). You can find out more about our advertising practices and the role of our third party partners in section 3 below.

In addition to the processing of information described in this Privacy Policy, the App may also access information but without CrazyLabs carrying out any processing. In these cases, the App may access the information but it is not transmitted outside of your device and CrazyLabs does not collect or use it in any way. The App may access information in this way in order to provide functionality necessary for particular features of the App.

We do not process or collect any data from your device’s microphone or camera sensor.

2. How do we use your information?

We use your information for the following purposes:

To provide you with the App and features/content within the App. This includes ensuring proper functioning of the App, enabling you to participate in the App’s social features such as Log in with Facebook, enabling you to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) generated through your participation, and to provide you with technical and customer support services. If you participate in multiplayer contests in the App, your name, avatar, points and rank in the contest will be displayed on the leaderboard which is visible to the other players in that contest. If you log in with Facebook, the name and picture displayed on the leaderboard will be those from your Facebook public profile.
Analytical purposes. This includes statistical, analytical, research and business intelligence purposes, e.g. understanding how people use the App, measuring usage of the App and retention of Users, track trends within the App, understanding the demographics of our User base and testing the impact of new features.
To develop and improve our apps. We use information to develop and improve the App, its content, and User experience e.g. fixing problems within the App. We also use information to develop new apps.
We use information to personalise, customise and enhance your experience within the App.
We use information to manage and deliver ads including customised or targeted ads (i.e. ads which are more likely to appeal to you based on your interests), to measure reach and effectiveness of ad campaigns and enable ad-serving features such as frequency capping. Please see section 3 below for further information on advertising.
To communicate with you. For example, we may communicate with you in relation to the App, events and competitions, including via push notifications if you have enabled these.
Security and legal purposes. This includes authenticating Users, verifying User IDs, providing access to additional features, identifying and addressing fraud, complying with applicable laws, and protecting CrazyLabs, Users and others.

You can make in-app purchases within the App. However, we do not process your payments or receive any payment card information. These purchases are completed through the app store and your app store account. You should review the privacy policy and terms of service of the relevant app store as these will govern any processing of personal information which is carried out when you make in-app purchases.

3. Advertising and third party partners

3.1 Advertising in the App

The App contains ads in various formats (such as banners, interstitial, rewarded videos, etc.) from third party advertising partners. Having these kinds of ads in the App allows us to provide the App to you without payment at the point of download. Personal information is shared between us and our third party advertising partners and service providers in order to provide ads within the App.

You will see two types of ads in the App – contextual ads (also known as non-targeted ads) and targeted ads (also known as interest-based, personalised or behavioural ads).

Contextual ads. These are not directed towards specific Users but are rather broadly posted onto random apps. If you chose to receive contextual or non-targeted ads only within the App, 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) agreed directly with those third parties to personalized advertising.
Targeted ads. If you have agreed to tracking, or not opted out of tracking in your device settings, you will also see these types of ads which are designed to be more relevant to you.

To show in-game ads we may share information collected from you which can be used to identify your device. This information includes persistent identifiers such as advertising ID, and IP address, which may be combined with other personal information to serve targeted ads. Our third party partners use this information to show you ads which they think will be relevant to you. You can find the list of third party advertising partners at: https://crazylabs.com/sst/3rdp.

Note that if you click on any of the ads you see in the App, this will take you outside of the App and 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 the App and your interests. 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.

3.2 Ads for our App in other applications/platforms

We may also promote the App in third parties’ applications and platforms. When we do this we receive information about what ads are displayed and how you interact with such ads. We use this information to measure the effectiveness of our campaigns, improve our advertising strategies and for the purposes of attribution (i.e. attributing a particular new user to a particular ad campaign on a third party application or platform).

3.3 How to control targeted ads

You can prevent or limit targeted advertising from your 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 your 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 party advertising partners.

To cease 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 advertising partners, please see the list of our third party advertising partners at https://crazylabs.com/sst/3rdp. You can review their privacy policies and follow the instructions on how to opt-out when available.

You will still see advertising once you have opted out but the ads you see are likely to be 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.

You can also reset the advertising ID from your device’s settings which will prevent continued use of behavioural data connected to the previous advertising ID.

iOS Device

iOS device with iOS 12 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 or newer version: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 the App on a device with iOS 14, you can withdraw your tracking permission from Settings by tapping on the App and turning off Allow Tracking, or you can go to Settings/Privacy/Tracking and tap to turn off the 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”.

4. Sharing Information with other third parties

We may share personal information in the following cases:

with selected third parties that we engage to perform services on our behalf to assist us in delivering and developing the App (e.g. advertising services, cloud services, analytics, customer support etc.);
to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
to enforce this Privacy Policy and/or the TOU and other of our terms or policies, including investigation of potential violations of such policies;
to detect, prevent, or otherwise address fraud, security or technical issues;
to respond to claims that any content published on the App violates any right of a third party;
to protect the rights, property or personal safety of CrazyLabs, our affiliates, Users, suppliers, licensors, licensees or the general public;
when CrazyLabs undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of CrazyLabs, in which case your information may also be disclosed, transferred and/or assigned;
pursuant to your explicit approval prior to the disclosure;
as part of a competition, receiving rewards or otherwise interacting with our social media channels;
with affiliates/group companies of CrazyLabs for any of the purposes described in this Privacy Policy.

Please note that the App allows Users to create their own content and take in-game photos. In-game “photos” are of your avatar which you can take once you have dressed and styled your avatar. This feature allows you to have your User-generated content displayed to other App Users during contests. You also have the option of posting User-generated content on Super Stylist social media pages such as on Facebook. Any content posted on to social media sites will be processed in accordance with that site’s privacy policy and terms and you should familiarise yourself with these documents.

YOU AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR YOUR PERSONAL INFORMATION WHICH YOU CHOOSE TO SHARE WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.

5. Links to third party sites

The App contains links, including within ads, which permit you to leave the App and enter third party sites, products or services. These linked sites, products and services are not under our control and will have their own policies which you should read to understand the practices of such third party sites.

6. Cookies & Local Storage

When you access or use the App, we and some of our third parties may use industry-wide technologies, such as “cookies”, 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 (e.g. 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), retain User game progress, deliver and manage ads (e.g. frequency capping), improve the quality of our services, and make the User’s App experience and usage simpler and more convenient. Such information is locally stored in the User’s device and we and our third-party partners may access it. Local Storage used by the App may store information such as your device identifiers, game progress/state, achievements and purchases. You can prevent Local Storage by uninstalling the App from your mobile device.

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

We process your personal information, including sharing personal information with third parties as described in section 4, 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 the App and certain of its features or content, including in-app contests, rewards etc., to provide you with customer services and support, to enable in-app purchases you make and to provide you with the App’s social features such as Log in with Facebook.
Legitimate Interests:
- Based on our legitimate interests in making sure you get the best game experience we process personal information to:
  - Provide and maintain the App and its features, including fixing problems, troubleshooting etc;
  - Improve and optimise our services and game experience;
  - Carry out analytics to understand how our App and related services are working and how Users interact with them which allows us to provide, maintain and improve them ;
  - Personalise your experience within the App.

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 App securely;
- Establish, exercise or defend our legal rights;
- Monitor the use of the App 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 the App free of charge/at low cost, we process personal information, including in connection with advertisements to:
- Keep track of installations of the App 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 (e.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 the App.If you provide consent to processing for these purposes, please be aware that this consent covers such processing in this App and all our other apps within the same developer account (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 ‎3 above. This will withdraw your consent across all our apps within the same developer account (CrazyLabs 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.

8. Your rights

As well as the rights explained in the sections above, 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. The easiest way to do this is from within the App settings, using the “Forget me” button.If third parties have collected your personal information through the App, 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. However, you can modify data that a social network or platform shares with us, or stop the App interacting with that social network or platform by adjusting your settings with that third party provider.
For example, if you’ve chosen to connect the App to your Facebook account using our “Log in with Facebook” feature, you can always use Facebook’s privacy settings to delete the data Facebook has collected from the App, and disconnect the App from Facebook to avoid future access to your App data. To do that, go to your Facebook account Off-Facebook Activity page and then use the “clear history” and “disconnect future activity” options available there.
You may also disconnect the App from Facebook to avoid future collection of your App data, via the “Apps and Websites” settings in your Facebook account, by selecting the App and selecting “Remove”.
If you choose to block such interaction, you may not be able to enjoy all the features of the App.

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 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 information by us and our third party service providers and advertising partners, you can do this by uninstalling the App 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 or 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.

9. International Data Transfer

We may transfer your personal information to countries other than your own country for legitimate business purposes. The recipient country may not have the same data protection laws as your jurisdiction. However, we will take steps to ensure that wherever your information is transferred, it remains adequately protected, such as by making transfers subject to standard contractual terms or transferring to jurisdictions which offer an equivalent level of protection as your own.

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.

10. Retention of Information

After you have stopped using the App, we will retain your personal information for a reasonable period, as is necessary to fulfil the purposes for which it was collected, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, and/or to enforce the TOU and our agreements, all as permitted under applicable privacy laws.

Aggregate and/or anonymous information may remain on our servers indefinitely.

11. Security

Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of the App and User information and prevent unauthorized access to it 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.

12. Changes to this Privacy Policy

The terms of this Privacy Policy will govern the processing of personal information in connection with App. 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 App and/or our website at https://crazylabs.com/. Such material changes will take effect five (5) days after such notice was provided on the App and/or site, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

13. 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]. You can also write to us at: Crazy Labs Ltd., 20th Floor, Azrieli Center Circular Tower, 132 Menachem Begin Road, 6701101, Tel Aviv, Israel.

Our representative in the EU can be contacted at [email protected].

Our representative in the UK can be contacted at [email protected].