This Privacy Notice (the “Notice“) describes the ways your personal data is collected and used on our mobile applications (each an “App”). It also describes the rights and options available to you with respect to your information.

We collect information associated with your device

We collect your mobile device’s online identifiers, such as advertiser ID (IDFA on iOS device) and Android ID (for Android devices). We also collect the device type and operating system, its locale (language), your time zone settings on the device, the screen resolution on your device, the IP address that your device uses for Internet connectivity and the country, city and region corresponding to that IP address. We refer to all of this as “Device Information“. You do not have a legal duty to provide the information. However, the App cannot operate without collecting this information

We also collect analytical

When you use the App, we will record and collect certain information in relation to your use of the App: time and date of access, game events and actions you took while using the App, such as game levels attempted, bets made, offers presented and accepted and game achievements. We refer to this as “Analytical Information“. The overall personal data outlined above will be referred to as the “Information“.

To provide you the App’s features, functionality and game experience.

We use Device Information, Analytical Information, Purchase Information, Player Profile and Facebook Information to provide you the App’s features, functionality and game experience, including in-app notifications, promotions and offers.

For technical troubleshooting of the App and to provide user support

We use Device Information, Analytical Information, Purchase Information and Facebook Information for technical troubleshooting of the App and to provide user support.

To respond to your inquiry

We will use your Inquiry Information to contact you about your inquiry and handle your inquiry. To address your inquiry, we will also use your Device Information, Facebook Information, Purchase Information and Analytical Information, depending on the nature of your inquiry.

WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS

We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent. These are also the categories of third parties with whom Spiral has disclosed personal information in the preceding 12 months.

We do not sell your information

Note that we do not sell your personal data to any third party and have not done so in the preceding 12 months.

SECURITY AND DATA RETENTION

We will retain your personal information for as long as we need it to operate the App, and thereafter as needed for record-keeping matters. We retain personal data for the duration needed to support our ordinary business activities operating the App. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.

We implement measures to secure your Information

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

We have no control over third-party content presented on the App and are not responsible for the privacy policies of such third parties

Portions of the App link to or present content from third parties, including ads. We have no control over this third-party content and are not responsible for the privacy policies of such third parties. We do not endorse any products offered by third parties and we urge our users to exercise discretion in their reliance on third party content.

Legal bases for processing your information

Our legal bases for processing information to provide you the App’s features, functionality and game experience, is its necessity for the fulfillment of our contract with you under the Terms.

Our legal basis for processing information for technical troubleshooting of the App, for user support, and for inquiriesis our legitimate interests in operating the App and our business.

Our legal basis for processing Survey Information is your consent when you participate in the survey.

Our legal basis for processing Player Profile information and publicly sharing it with other users is our legitimate interests in enhancing the social-sharing component of the App’s business.

Right to Restrict

processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten.

Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

You must be 18 years of age or older in order to use the Service.

The Service is not intended for minors under the age of 18. IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE IN ANY WAY.