Introduction:
Clark Bros and its affiliates (collectively, “Clark Bros,” “us,” “our,” or “we”) develop and publish games for mobile devices. This Privacy Policy (this “Policy”) describes the ways we collect, store, use, and disclose information, including personal information and data, that our users (“users” or “you”) provide or that we collect in connection with our website, available at [Website URL], and any of our games provided on a mobile platform (each a “Service,” collectively, the “Services”). Additionally, this Policy describes your rights and choices concerning your information.
Please note that the scope of this Policy is limited to information and data collected or received by Clark Bros through your use of the Services. Clark Bros is not responsible for the actions of individuals with no relationship to Clark Bros or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.
If you do not want Clark Bros to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.
Why Does Clark Bros Collect Data from Its Apps and Games?
When you install and use Clark Bros mobile applications, we may collect and process some of your data for different legitimate purposes. Below, you will find explanations regarding the reasons why Clark Bros may collect data and the legal bases we rely on in each case.
Clark Bros collects data for the following purposes:
-
To provide you with the services you requested
(e.g., knowing that you completed the first level to allow access to the second one)
Legal basis – Such data processing is strictly necessary for the service(s) requested. -
To run analytics and understand how users interact with our products and services to continuously improve them
(e.g., identifying that a feature is frustrating for users or that a level is too difficult for most players)
Legal basis – Express consent. Clark Bros only processes or shares personal data collected through our apps for analytics purposes once you provide your consent through the pop-up notice included in our apps. -
To serve advertisements tailored to the preferences and interests of our users
and to allow Clark Bros to continue providing free services and products
Legal basis – Express consent. Clark Bros only processes or shares personal data collected through our apps for personalized advertising purposes once you provide your consent through the pop-up notice included in one of our apps.
For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “Settings” page in our various applications. Please note that if you withdraw your consent or refuse to provide it initially, you will still receive advertisements, but they may be less relevant to you as they will not be tailored to your interests.
What Data Does Clark Bros collect from its Apps and Games?
For all the purposes listed above, the data that Clark Bros collects is limited to:
- The apps you are using
- Your IP address
- Your Mobile Advertising ID (Apple IDFA or Google AAID – these are technical identifiers developed by mobile operating systems for advertising purposes, which remain under your control. You can reset or erase these identifiers at any time through your device settings. For Apple devices, go to Settings > Privacy > Tracking to manage advertising preferences. For Android devices, go to Settings > Google > Ads to reset or opt-out of personalized ads.)
- Technical information about the device you use and your connection (user agent, type of connection, timestamp)
- Data about your activities on our applications, notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, the number of ads served, potential clicks)
To Whom May Your Data Be Shared and Why?
Clark Bros does not share your data with third parties without your prior consent.
When you consent to the collection of data for advertising and analytics purposes, we may share the data listed above with the following categories of recipients:
Ad Partners: These partners allow us to monetize the ad inventory of our apps and provide users with free products and services. These partners usually collect data via their tools (Software Development Kits, or “SDKs”). Below is a list of our partners implementing advertising SDKs through our applications, along with the privacy policies of their services. These policies describe their practices and allow you to exercise your rights directly toward them:
Adcolony – https://www.adcolony.com/privacy-policy/
Applovin – https://www.applovin.com/privacy/
Criteo – https://www.criteo.com/privacy/
Facebook – https://www.facebook.com/about/privacy
Fyber – https://www.fyber.com/privacy-policy/
Google – https://policies.google.com/privacy
Inmobi – https://www.inmobi.com/privacy-policy/
Ironsource – https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Mintegral – https://www.mintegral.com/en/privacy/
Mopub – https://www.mopub.com/legal/privacy/
Oath – https://policies.oath.com/in/en/oath/privacy/
Ogury – https://ogury.com/privacy-policy/
Tapjoy – https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy
Vungle – https://vungle.com/privacy/
Analytic Companies: These partners provide us with tools and technologies that help us better understand how users interact with our services, enabling us to improve them. These partners also usually collect data via their own SDKs. Below is a list of our partners implementing analytical SDKs through our applications:
GameAnalytics – https://policies.google.com/privacy
Google – https://policies.google.com/privacy
Authorities: We may share your data with authorities only to the extent we are obliged to by applicable laws and regulations.
Data retention: Third-party partners are responsible for their own data retention policies. Please refer to their privacy policies for more details about how long they retain data. We encourage you to review their policies to understand how long your data may be retained by these third-party partners.
User Rights Regarding Third-Party Data Sharing: If you wish to access, modify, or delete your data held by third-party partners, please refer to their individual privacy policies or contact their support team directly. By doing so, you can exercise your rights regarding your data with these third-party providers.
Registration Information
We may also offer you the option to complete a user profile visible to other Clark Bros users (“Account”). If you create an Account, you may provide us with your name, username, email address, password, and other information to confirm your identity when accessing your Account. This information may be collected through in-game dialog boxes, which you may choose to skip.
If you sign in to the Services with Facebook Connect, we will collect information visible via your Facebook account, such as (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. By using Facebook Connect, you agree to Facebook’s privacy policy, and we encourage you to review it for more details on how your information is handled.
Your Account may be used to publicly identify you as part of social features of the Services, such as user-to-user interaction, chat or messaging, public leaderboards, and other similar features. The Clark Bros username will be public and visible to other users, but we do not share your private information (e.g., email address, full name) unless specified in your profile settings.
We may also allow you to import your contacts or manually enter email addresses to locate and connect with your contacts on Clark Bros. These contacts are stored solely for the purpose of helping you make connections through our Services and are not shared with third parties unless you have explicitly given consent.
You can update your privacy settings or limit the visibility of your profile and information at any time through the settings section of the app. If you choose to delete your Account, we will remove your personal information from our records, unless we are required by law to retain it.
Payment Information
When you purchase any goods or services through the Services, including virtual currency or virtual goods, our payment processing service provider will collect your name, phone number, email address, mailing address, billing address, and complete credit card information needed to process your payment. The provider may retain this information to make it easier for you to complete future purchases without needing to re-enter it. You may contact the payment provider directly to manage or delete your stored data.
Please note that purchases made through third parties may be subject to their respective privacy policies. We encourage you to review these policies to understand how your data will be used. We use industry-standard encryption and security protocols to protect your payment information during transactions.
By providing your payment information, you consent to its processing by our payment service provider.
Information Collected by Customer Support:
Information Collected by Customer Support
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and email address), information about your gameplay or activity on the Services, and your username or ID number. This may include gameplay statistics, error reports, and logs that help us diagnose issues or improve the user experience. We will also store the correspondence and any information contained within.
We will retain this information as long as necessary to resolve your request or for internal record-keeping. The information we collect may be used to help resolve your issue, improve our Services, or for internal analysis. We will not share your contact or gameplay information with third parties without your consent, except as required by law.
You can request access to, or deletion of, the personal information collected during your support interaction by contacting us directly. We implement appropriate security measures to protect the information you share with our Customer Support team.
Technical and Usage Information
When you access our Services, we may collect:
(i) certain technical information about your mobile device or computer system, including your IP address, mobile device ID (IDFA, Google Advertising ID, or other identifiers), and the version of your operating system; and
(ii) usage statistics about your interactions with the Services.
In certain Services, we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or email address. We may also access your contacts to enable you to invite friends to join you in the Services.
This information is typically collected through the use of third-party mobile device software development kits. Some of the collected data may be shared with third-party services for analytics, advertising, or other purposes. You can review the privacy policies of these third-party services for more information on how they use your data.
We may occasionally send you push notifications through our Services to send you game updates, high scores, and other service-related notifications that may be of importance to you. You may, at any time, opt out from receiving these types of communications by turning them off at the device level through your settings.
How We Use Your Information
Clark Bros’ primary goals in using your information are to create your account, provide Services to you, troubleshoot, improve and optimize our Services, contact you, conduct research, and create reports for internal use. We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service.
For example, we may use your information to
Create accounts and allow users to use our Services
Identify and suggest connections with other Clark Bros users
Operate and improve our Services
Understand you and your preferences to enhance your experience and enjoyment using our Services
Respond to your comments and questions and provide customer service
Provide and deliver products and services you request
Deliver advertising, marketing, and promotional information to you
Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by Clark Bros and our selected partners
Conduct and administer contests promoted by Clark Bros
Enable you to communicate with other users
Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services
Use of Your Information by Others
Third-Party Services
We may provide your information to third-party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, customer service, and marketing efforts. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws. These third-party service providers are contractually obligated to use your information only for the specific purposes for which it was shared and in accordance with this Privacy Policy.
Advertising
If we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads. This information may include Device make, model, and operating system; Device properties (e.g., screen size, orientation, audio volume, battery); Carrier information; Network connection type and speed; IP Address; Internet browser user-agent; Advertising ID (IDFA on iOS devices, GAID on Android devices).
To learn more about interest-based advertising and to opt-out, you can visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU). If you wish to opt-out of mobile app advertising, you may use the DAA’s AppChoices app, available for iOS, Android, and Amazon devices.
Please note that opting out of personalized advertising will not stop ads from appearing, but it may make them less relevant to your interests. If you switch devices, browsers, or clear cookies, you may need to renew your opt-out choices.
How We May Disclose Your Information to Third Parties
We do not share your personal information except as approved by you or as described in this Policy. We may share the information we collect with third parties for the following purposes: With service providers performing services on our behalf, such as those referenced above under “Third-Party Services”; With our affiliates for business purposes; For analytics, research, and improving our services; In response to lawful requests by public authorities, including law enforcement, to comply with legal obligations; To protect our or a third party’s legal rights, investigate fraud, or defend against legal claims; As part of a business transfer, such as a merger, acquisition, or bankruptcy; With advertisers, publishers, and business partners for aggregate or anonymous data sharing.
We may use third-party analytics services, such as Google Analytics, which may use cookies to collect information about your activities across websites. To learn more about how Google Analytics collects and processes data and to manage these activities, you may visit Google’s Privacy Policy.
Specific Provisions for EU Individuals
Under the General Data Protection Regulation (GDPR), you have certain rights with respect to your personal data, including the right to access, correct, delete, or restrict your data. To exercise these rights, please contact us using the details provided in the “Contact Clark Bros” section.
Accessing and Correcting Your Information: You may contact us to request access to or correction of your personal data. We may ask you to verify your identity to ensure data accuracy.
Withdrawing Your Consent: You may withdraw your consent to data processing at any time. This will not affect the lawfulness of data processing before your withdrawal.
Erasing or Restricting Access: You may request to delete or restrict access to your data. We may deny such requests if we need to retain the information for legitimate purposes, such as fulfilling contractual obligations or complying with legal requirements.
Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transfer it to another party where technically feasible.
Right to Complain: If you believe that our data processing infringes applicable data protection laws, you have the right to file a complaint with a supervisory authority, particularly in your country of residence.
Data Security
We take reasonable steps to protect your information from unauthorized access, loss, misuse, or alteration by third parties. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee the absolute security of your data.
Data Retention
We retain your personal data only for as long as necessary to provide our services or as required by law. We may also retain data to comply with legal obligations, resolve disputes, and enforce agreements.
Our Policy Regarding Children
We do not knowingly collect personal data from children under the age of 16. If you are under 16, please do not provide any personal information. If we learn that we have collected personal data from a child under 16, we will delete that information promptly.
Transfer of Personal Data Outside Your Country
We may transfer your data to affiliated entities or third parties outside your country of residence, including the United States. These countries may not have the same level of data protection laws, but we take steps to ensure adequate safeguards are in place.
Lawful Basis for Processing
We process your personal data primarily for contract performance, to provide our services, and in certain cases, where required by law. We may also process your data for fraud prevention, service improvement, and marketing where these activities align with our legitimate interests, provided they do not override your privacy rights.
EU-U.S. Privacy Shield
Clark Bros and its affiliated studios comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. To learn more, visit the Privacy Shield List.
California Residents Rights (CCPA)
California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, request deletion of information, and opt-out of the sale of personal information. If you are a California resident, you may submit a request to [email protected].
Changes to This Privacy Policy
We may update this policy from time to time to reflect changes to our data practices. We will notify you of significant changes by posting the updated policy in our services. Please check periodically for updates.