Last updated: 11 May 2020
This Privacy Policy explains how your personal data is collected and processed by Wuli Creator ("Wuli Creator") when you use this mobile application (the "App").
The App is a free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent. We encourage you to review the Privacy Policy whenever you access the App to stay informed about how we process your personal data and how you can protect your privacy.
Collection of information
Information you provide to us
This Privacy Policy only concerns the App. If you submit any information to Wuli Creator through our website or other sites or services, please review the Wuli Creator Privacy Policy or such other privacy policy as applicable for information about how we collect, use and disclose such information.
Information we collect automatically through the app
When you access or use the App, we automatically collect general information about you, including:
Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times and your IP address.
Device Information: We collect information about the device you use to access the App, including information about the device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push- messages, mobile network information and time zone.
Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements and interactions with other players.
Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.
Information we collect from other sources
If you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.
If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.
Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
Log-, device-, usage-, and consumption information
are being processed:
to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
to provide and maintain the App and the game experience; and
to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
to provide news and information about the App that we think will be of interest to you;
to personalize and improve the App and provide tailored content and features;
to monitor and analyze trends, usage and activities in connection with the App; and
to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App.
Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").
to provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
Information from other sources
are being processed:
to provide and deliver the products and services you request and send you related information;
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
to link or combine information we get from others to help understand your needs and provide you with better service; and
to provide news and information about the App we think will be of interest to you;
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR.
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Storage of information
Wuli Creator will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with Wuli Creator has ceased.
Sharing of information
We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
Social networks, see more under "Social Sharing features";
Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Kiloo or others;
Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service, such as Facebook or Apple Game Center;
Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID).
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
MoPub, Inc. https://www.mopub.com/legal/privacy/
MoPub, Inc. Partners https://www.mopub.com/legal/partners/
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.
GameAnalytics ApS https://gameanalytics.com/privacy
Tenjin, Inc. https://www.tenjin.io/privacy
Facebook Analytics (Facebook, Inc.) https://www.facebook.com/about/privacy/
Social sharing features
The App offers social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.
Facebook: https://www.facebook.com/about/privacy/
Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
Children
You must be at least 16 years old to use the App. If you are accepting these Terms and using the App, you warrant that you state the correct age and you are 16 or more years old.
If you have additional questions about Wuli Creator's privacy practices related to children under the applicable minimum age, please contact us at wulicreator@gmail.com.
Transfer to third countries
In connection with the processing, we will in certain circumstances transfer your personal data to recipients in the U.S which has been declared an unsafe third country by the European Commission.
We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this privacy policy and applicable law.
Security
Wuli Creator takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Contact and complaints
Wuli Creator has the following contact information:
Wuli Creator
E-mail: wulicreator@gmail.com