Privacy Policy | Grumpy Rhino Games

GRUMPY RHINO GAMES PRIVACY POLICY

1. INTRODUCTION TO OUR PRIVACY POLICY

We are Grumpy Rhino Games Limited. Our registered office is at Exmouth House, 3/11 Pine Street, Farringdon, London EC1R 0JH. Our company number is 09650330. This policy refers to us as “Grumpy Rhino”, "we", "us" or "our".

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This policy, our relevant end-user licence agreements (our “EULA”) and any additional terms of use incorporated by reference into the EULA, (together our “Terms of Use”) applies to your use of:

Idle Armies, Idle Empires, Idle Apocalypse, Idle Mastermind, NecroMerger - Idle Merge Game and other mobile, desktop or laptop application software we provide (together the “Apps” and each an “App”), once you have downloaded or streamed a copy of an App onto your device (“Device”); and
our Websites, including www.grumpyrhinogames.com (our “Websites”),

unless the Websites / Apps state that separate terms or policies apply.

Our Websites / Apps are not intended for children and we do not knowingly collect data relating to children.

2. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues or other competent supervisory authority.

3. AGREEMENT TO TERMS

By downloading, installing, accessing, using, and/or playing our Apps, or interacting with our Websites, you agree to the terms set out in this policy and, for our Apps, to our EULA.

If you do not agree with any term provided in this policy, you must not provide us with any personal information; you must immediately leave and discontinue use of our Websites; you must not download, install, access, use, and/or play our Apps; and we request that you promptly erase all of our Apps from your Device.

4. CHANGES TO THIS PRIVACY POLICY

This policy was last updated on 26th of August 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start an App or log onto one of the Websites. Any such new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of an App or the Websites.

5. TYPES OF DATA WE MAY COLLECT

We collect information from a number of different sources, but most of it comes directly from you when interact with our Apps and Websites. We may collect, use, store or transfer the following categories of data:

Identity Data: includes first name, last name, username or similar identifier.
Contact Data: includes email address.
Transaction Data: includes details about in-App purchases on Google Play.
Profile Data: includes any username, gameplay information, in-App purchase history, preferences, and feedback.
Location Data: includes country and city of residence.

We may also collect, use, store or transfer Aggregated Data such as statistical or demographic data for any purpose.

Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any “special categories” of personal data about you (this includes details about your race or ethnicity, religious beliefs, political opinions or your health).

6. BASIS FOR PROCESSING

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

where you have consented before the processing;
where we need to perform a contract we are about to enter or have entered with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us using the details in Section 1 or through the mechanisms in our Apps, Websites or marketing communications. We will get your express consent before we share your personal data with any third party for marketing purposes.

If you agree to us sending “push” notifications to your Device but then change your mind you can deactivate push notification by:

changing the settings within the relevant App; and/or
changing the notification settings in accordance with the instructions of the operating system running on your Device.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

ONBOARDING NEW USERS

Including:
- installing Apps;
- registering you as a new App user; and
- enabling Website and App functionality, such as in-app purchases, Game Center Features, Google Play Games or the Apple Game Center
Types of data: Identity and Contact
Basis for processing: Your consent

MANAGING OUR RELATIONSHIP

Including:
- notifying you of changes to an App or Website;
- responding to your questions or requests, whether through a “Contact Us” feature on our App or Websites or otherwise; and
- responding to you through our social media channels.
Types of Data: Identity, Contact, Profile, and Location (depending on nature of question / request)
Basis for processing:
- Your consent
- Performance of a contract with you
- Necessary for our legitimate interests (depending on nature of question / request)
- Necessary to comply with legal obligations

USER VERIFICATIONS

Including:
- verifying your identity when you sign in to an App or interact with our Apps and Websites;
- verifying clicks and/or installs in respect of our Apps and Websites; and
- verifying your identity for the purpose of dealing with inappropriate interactions and/or fraudulent use of our Apps and Websites
Types of Data: Identity, Contact and Profile
Basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

SYSTEM ADMINISTRATION

Including:
- administering and protecting our business, Apps and Websites;
- troubleshooting;
- data analysis;
- measuring traffic and usage;
- system testing; and
- ensuring the proper functioning of our Apps and Websites
Types of Data: Identity, Contact and Profile
Basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

APP / WEBSITE DEVELOPMENT

Including:
- developing and improving our Apps and Websites;
- analysing and fixing problems;
- developing new offerings;
- providing better and more personalised content; and
- simplifying and improving the user experience.
Types of Data: Identity, Contact, Profile, and Location
Basis for processing: Necessary for our legitimate interests (for developing and improving our Apps and Websites)

ADVERTISING

Including:
- promoting our Apps and Websites;
- delivering content and advertisements;
- recommending goods or services which may interest you;
- measuring and analysing the effectiveness of the advertising we serve you;
- processing click stream data such as server addresses and domain names;
- enabling ad serving features, such as, frequency capping (limiting the number of times a specific advertisement is presented to the same Device);
- personalising your experience by showing advertisements for products and services that are more likely to appeal to you (e.g. behavioural advertising);
- monitoring trends so we can improve our Apps and Websites;
- collecting, using, and providing access to your advertising identifiers in accordance with the applicable platform provider's policies; and
- identifying when you install an App as a result of advertisements and/or campaigns that we launch on other services, including in social networks or platforms (e.g. on Facebook or otherwise) and the source-ad which led to such installation
- See Sections 14, 15 and 16 below for further detail.
Types of Data: Identity, Contact, Profile, and Location
Basis for processing:
- Your consent
- Necessary for our legitimate interests (to develop our products/Apps or Websites and grow our business)

Recording information we collect via cookies and other similar technologies (see Section 15 below for further details)
Types of Data: Identity, Contact, Profile, and Location
Basis for processing:
- Your consent
- Performance of a contract with you
- Necessary for our legitimate interests (to develop or secure our products/Apps or Websites and grow our business)

THIRD PARTY DATA

To process information we collect about you from third party companies including:
- publishing partners / platforms;
- advertising partners / platforms; and
- data aggregators.
Types of Data: Identity, Contact, Profile, and Location
Basis for processing:
- Your consent
- Performance of a contract with you
- Necessary for our legitimate interests (to analyse how customers use our products/Apps or Websites and to develop them and grow our business)

LAW

As required by any applicable law
Types of Data: Any
Basis for processing: Necessary to comply with legal obligations

FURTHER COLLECTIONS

As otherwise explained at the time the relevant data is collected
Types of Data: Any
Basis for processing:
- Your consent
- Necessary for our legitimate interests
- As otherwise explained at the time of collection

7. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. DATA SECURITY

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Apps or Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Websites or Apps may include social networking, chat room or forum features. Please ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

9. DATA RETENTION

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Section 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use an App for a period of three years then we will treat the account as expired and your personal data may be deleted.

10. YOUR LEGAL RIGHTS

You have certain rights under data protection laws in relation to your personal data. In particular, you have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us using the details in Section 1.

To stop all collection of information from:

a Website, leave and discontinue use of the Website; and
an App, uninstall the App.

Your rights can be summarised as follows:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. WEBSITE SECURITY MEASURES

This Section applies only to our Websites. Please note:

we do not use vulnerability scanning, malware scanning, or scanning to PCI standards;
we do not allow third party behavioural tracking;
we have not enabled Google AdSense but may do so in the future; and
we honour “Do Not Track” (DNT) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.

12. RISK OF INTERCEPTION

Please keep in mind that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using any Apps or Websites, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us and that any personal information, general information, or other data or information received from you pursuant to your use of our Apps or Websites is provided to us at your own risk.

13. SHARING INFORMATION WITH THIRD PARTIES

Grumpy Rhino will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will release such information upon receipt of a court order, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United Kingdom.

We fully cooperate with law enforcement agencies in identifying those who use our Apps or Websites for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined at our sole discretion.

We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our Service Partners may use your personal information to operate our Websites and Apps. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the Apps or Websites, executing services (such as advertising of our own Apps and Websites), or helping us analyse collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. The use of your personal information by our Service Partners is governed by the privacy policies of those Service Partners and is not subject to our control.

The following is a list of our Service Partners and links to their privacy policies:

Advertising: AdMob https://policies.google.com/privacy?hl=en-US;
Advertising: Chartboost https://answers.chartboost.com/en-us/articles/200780269;
Advertising: Facebook Ads https://www.facebook.com/legal/FB_Work_Privacy;
Advertising: IronSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/;
Advertising: Tapjoy, Inc. https://www.tapjoy.com/legal/general/privacy-policy/;
Advertising: Unity Technologies https://unity3d.com/legal/privacy-policy;
Website Hosting: Wix.com https://www.wix.com/about/privacy;
User Analytics: AppsFlyer https://www.appsflyer.com/legal/privacy-policy/.

Please note that when you purchase items via our Apps (such as those you can purchase in the Apple Store, on Google Play or on Amazon) we do not collect or store any payment information from you. If you would like to know what data is collected or how payment information is processed, please familiarise yourself with the relevant app store’s privacy policy.

We may also share your personal data with third parties who we acquire, sell, transfer or merge parts of our business or our assets with. If such a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.

14. ADVERTISEMENTS

In addition to advertising our own Apps and Websites, we accept advertisements, in various formats from third party ad networks that may be displayed in our Apps.

These third party ad networks may collect and use information about your interaction with our Apps and Websites in connection with:

marketing;
sales and advertising activities;
geographic tracking and carrier network preferences; and information, such as Identity and Profile Data logged from your Device to ensure that appropriate advertising is presented within our Apps and Websites; and
calculate or control the number of views of an ad, deliver advertisements relating to your interests, and measure the effectiveness of advertisements campaigns.

Note that if you click on any of these advertisements, the advertisers may use cookies and other web-tracking technologies on your Device to collect data regarding:

advertisement performance;
your interaction with such advertisements and our Apps and Websites; and
your interests in order to serve you advertisements, including targeted advertisements.

This data may include your personal information such as device and network information, unique identifiers, gender, age, and geo-location. 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.

15. COOKIES

We may use cookies to distinguish you from other users of our Apps and Websites and to remember your preferences. This helps us to provide you with a good experience when you browse any of our Apps and Websites and also allows us to improve our Apps and Websites.

You can turn off all cookies, in case you prefer not to receive them. You can also have your Device warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the Apps’ or Websites’ functionality and you may lose access to some of their features.

16. OTHER AD IDENTIFIERS AND TRACKING TECHNOLOGIES

In addition to cookies, in order to provide our Apps and Websites, we use ad identifiers and similar technologies. These are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising, which are uniquely associated with your Device. These technologies allow companies (including marketers and advertisers) to recognise your Device when you use websites and applications.

We use ad identifiers and similar technologies to provide our Apps and Websites to you and in order to collect data from your Device. These technologies allow us and our third party advertising partners to:

recognise you and your Device;
provide interest-based advertising to you;
allow our Apps and Websites to interact with a third party social network or platform (where you have chosen to allow such interaction); and
enable us and third parties to provide you with more customised services, for example to provide our Apps and Websites in the correct language.

You can choose to prevent your Device's ad identifier being used for interest-based advertising, or you can reset your Device's ad identifier, by changing the settings of your Device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your Device's settings.

If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for users in the USA), http://www.youronlinechoices.com/ (for users in Europe) or http://youradchoices.ca/choices (for users in Canada). You can also click on the AdChoices logo within an advertisement (where available). If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Apps and Websites.

Please note that adjusting your preferences as described in this Section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests.