Privacy Policy
This is an English translation provided for convenience. In case of discrepancy, the Italian version prevails.
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy applies to Balzo’s games, apps, websites and related services (together the “Services”, or “games”, “apps”, “websites” for the individual categories). This Privacy Policy explains how we and our affiliated companies (collectively, “Balzo” or “we”, “us”, “our”) collect, use, protect and/or disclose the personal information of end users (“you” or “your”) or otherwise process your personal information when you use our Services.
The Data Controller is Balzo Srl, with registered office at Via Solferino 10, 50123 Firenze, Italy.
Information we collect and how
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact details unless you provide us with such data. The information we collect includes:
Usage information
- We automatically collect information about your activity through our Services, for example the date and time you used a service, features you used, in-app purchase history, subscriptions and advertisements you clicked on, and data generated when you use our Services, for example your game progress, which may be stored with your Apple ID on iCloud for iOS devices or with your Google Play Games profile for Android devices in some of our Services. Our Services may also contain tools from third-party service providers that may allow such third parties to separately collect and/or analyse non-personal data from users’ devices.
Other information
- We may collect other information with your permission, such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections. If you refuse permission for the collection of your geolocation, we will not collect it. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.
Information we obtain from third parties
- We may receive information about you from our analytics service providers with the data they collect through our Services in accordance with their privacy policies.
Information we obtain from Facebook
- If you use our Services on Facebook, we may receive any information that you provide or allow to be provided to us through Facebook. Such data may include your user ID and your use of our game, including whom you share our game with on Facebook, and your email address in case you wish to contact us for support. The information we receive depends on the Services you are using, on Facebook’s terms of service and privacy policy, on your privacy settings and, if applicable, on your friends’ privacy settings.The information we receive is stored and used by us in accordance with this Privacy Policy. If you are unsure about the information that Facebook shares with us, we invite you to visit Facebook’s website for further information about their privacy practices.
Customer requests
- We collect certain information from you when you provide it to us directly, for example through an online form, such as name, email, telephone number and curriculum vitae (CV), or when you contact us through the support feature built into our Services, or when you send us an email directly.
Forms on the www.balzo.eu website
- Contact form. When you write to us through the contact form we collect first name, last name, email and the text of the message. We use this data only to reply to you and to handle your request. The website is hosted by Cloudflare, Inc., which receives the data submitted through the form and forwards it by email only to our address info@balzo.eu. Cloudflare does not use the data for its own purposes.
- Gender equality reports. The form on the Gender Equality page is anonymous: it does not ask for a name or email, and the website does not read, store or forward the IP address of the person writing. The text of the report reaches only the company’s dedicated mailbox, through the same Cloudflare service indicated above.
Cookies and similar data collection technologies
- We and our advertising networks and their partners may use cookies and similar technologies, such as the mobile “SDK”, to provide and personalise our Services and to deliver targeted advertising. Some of these technologies may synchronise behaviour across different mobile apps, devices and websites so that advertisements can be personalised based on your interests. This process is called personalised advertising experience. In addition, we and some advertising networks may access your inventory of installed apps in order to avoid advertising apps that are already installed. If you wish to opt out of advertising personalisation in this way on your mobile device, please see the section below ‘Opting out of targeted advertising’.
Purpose for which we will use your information
We have set out below a description of the ways in which we use your information, the legal bases we rely on to do so, and provide the opt-out option, where applicable:
- To provide and maintain our Services, recognise you when you return to our apps and carry out essential business operations, our legal basis for processing is the performance of a contract with you, which you entered into with us when you download our Services and accept our End User License Agreement.
- To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and data hosting), our legal basis for processing is legitimate interests for running our business, provision of administration and services.
- To communicate with you regarding career enquiries, contact forms, helpdesk support and to understand how you use our Services so that we can continuously improve our offerings, our legal basis is the performance of a contract, legitimate interests or consent depending on the particular case, in order to keep our users updated about our Services and new features in accordance with your preferences and to continue to improve the Services we offer.
- To opt out of communication with us for our Services, send us your request through the online support feature.
- To cross-advertise our Services and products and to send push notifications about changes to our Services, to allow you to take part in new features of our Services when you choose to do so, our legal basis is legitimate interests in being able to advertise our Services and products to our users and keep our users updated about our Services and new features in accordance with your preferences.
- To opt out of receiving advertising for our Services and products, send us a request through the in-app support feature, by going to our app -> clicking on the three dots (or other) -> clicking on help (or support) -> and then clicking on Contact us (or +) and send us your request.
- You can opt out of receiving push notifications by disabling them at device level through the device settings.
- To provide personalised advertising in our Services using third-party advertising networks, our legal basis is legitimate interests for running our business. However, if you are located in the European Economic Area, in Norway or in Switzerland, some of our third-party advertising networks will rely on your consent to process Personal Data in order to provide you with personalised advertising; therefore you will be asked whether you consent to the collection of your mobile advertising identifier and IP address so that they can provide a personalised advertising experience.
- To opt out of or withdraw your consent to receiving personalised advertising, please see the section below ‘Opting out of targeted advertising’.
Data retention
We will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when such data is used to improve the functionality of our Services, or we are legally obligated to retain such data for longer periods of time.
Your Personal Data collected through our Services will be deleted when it is no longer needed for any of the purposes mentioned above, but in any case your Personal Data will be deleted after 14 months of inactivity in the use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right of access, the right to erasure, the right to rectification or the right to data portability.
Your Personal Data collected through our Get in Touch forms will be deleted 2 years after the date of receipt. Once we have deleted your Personal Data, you will not be able to exercise the right of access, the right to erasure, the right to rectification or the right to data portability.
Your rights and options
Access to the personal data we hold about you
- You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you with a copy of your Personal Data in electronic format. For Personal Data that you send us through the Get in Touch form on our website, simply send your data access request through the same form as a Customer Support ticket.
Other rights
- You also have other rights, such as correcting your data, having your data erased, objecting to how we use or share your data, and restricting how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your personal data, for example by disabling camera access in the settings of your mobile device. This will not affect any data processed before such withdrawal.
Opting out of targeted advertising
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To show you personalised advertisements in our apps we use third-party advertising networks and their partners, including those that require your consent and are listed in ‘APPENDIX A – Advertising networks and their partners’ below, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To this end, they use personal and non-personal information such as advertising identifiers, like the Android Advertising ID and/or Apple’s Identifier for Advertisers (IDFA), and/or other tracking technologies to enable and optimise this advertising procedure.
You can opt out of the personalised advertising experience at any time by checking the privacy settings of your Android or iOS device.
For Apple devices:
- Open Settings
- Select Privacy
- Select Advertising and enable “Limit Ad Tracking”
For Android devices:
- Open Settings
- Select Google
- Select Ads and enable “Opt out of Ads Personalisation”
When you choose to opt out, the advertising networks will treat this choice as a withdrawal of consent to the personalised advertising experience and will show contextual advertisements and not personalised advertisements based on your interests.
Exercising these rights
- Any request to exercise your rights must be made through our support feature located in our apps (by going to the particular app -> clicking on the three dots (or other) -> clicking on help (or support) -> and then clicking on Contact us (or +) and sending your request). Any request regarding our game(s) available on Facebook must be made through the built-in support feature by going to the game -> clicking on the settings icon -> clicking on help and sending your request.
You can also send us an email at privacy@balzo.eu; however, we may still direct you to make the same request through the in-app support feature or we may request further information in order to fulfil your request. These requests can be exercised free of charge and will be addressed by us as soon as possible and always within one month. You can also contact your local data protection authority within the European Economic Area for unresolved complaints.
Storage, disclosure, transfer and sharing of your information
Sharing with our service providers and partners
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We use third parties to help us operate and improve our Services. These third parties assist us with various activities, including hosting and maintenance, ongoing development, analytics, customer support, marketing, advertising. We may also share information with advertising partners that serve advertisements in our Services.
For further information about advertising networks, please see ‘APPENDIX A – Advertising networks and their partners’ below, and for further information about analytics service providers please see ‘APPENDIX B – Analytics service providers and other providers’ below.
For business transactions
- We may transfer your information if we are involved, in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.
When required by law
- We may also share information if we are obligated to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of our business, our customers or others.
To enforce legal rights
- We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) if necessary to protect our legal rights and the legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
- We may ask for your consent to share your information with third parties. In such a case, we will make clear why we wish to share the information.
Cross-border data transfers
- Sharing information sometimes involves cross-border data transfers, including transfers outside the EEA in accordance with the law. We only transfer Personal Data to entities in third countries that have provided adequate safeguards to ensure that their level of data protection complies with this privacy policy and applicable law, for example in accordance with the rules and procedures known as the EU-US Privacy Shield, or on the basis of contractual provisions that have been considered by the European Commission as sufficient to ensure the protection of personal data.
Social sharing features
- Some of our Services offer social sharing features that allow you to share the actions you take in our Services with other media. You must be above the minimum age limit set by the legislation of the individual jurisdictions in order to use any social sharing feature integrated into our Services. The use of such features enables the sharing of information with your friends or with the public, depending on the settings you establish with the entity that provides the social sharing feature.
Age limits
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for a general audience over the age of 16. We do not knowingly collect personal information from children under the age of 16. To request the deletion of personal data, for any reason, use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable steps to promptly delete such personal data from our records.
Links to other sites
Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.
Changes to this Privacy Policy
This Privacy Policy may change from time to time and we encourage you to review it periodically. Continued use of our Services implies acceptance of the changes to this Privacy Policy.
In some cases, we may inform you of changes to this Privacy Policy with a prominent notice on our Services (for example through a notification or a pop-up), before the changes become effective, and update the “effective date” at the top of this Privacy Policy.
Contact us
If you have any questions about this Privacy Policy, contact us using the in-app support feature in our Services, which is the preferred method so that we can respond quickly to your requests, or contact our data protection officer at the address provided below:
Balzo Srl,
via Solferino 10,50123 Firenze, italia,
privacy@balzo.eu.
APPENDIX A – Advertising networks and their partners
Click on the link below to read the information relating to Appendix A
APPENDIX B – Analytics providers and other service providers
Click on the link below to read the information relating to Appendix B