By accessing ACFFG Site the ACFFG mobile application (e.g., ACFFG iOS, ACFFG Android) (“ACFFG App”) and collectively the “ACFFG Services”, which are provided by ACFFG LTD, with a mailing address of 1st Floor, Limassol, 3037 Cyprus,  (“ACFFG”), you expressly consent to the collection, use and disclosure of your Personal Data (defined below) in accordance with this Privacy Policy. As described more fully below, the ACFFG App is a gaming application that may utilize your personal data. You also consent to ACFFG’s cookie policies, as described herein.

Types Of Data We Collect.

We collect personal data and non-personal data about you. “Personal Data” means any data that allows someone to identify or contact you.

The following provides examples of the types of data that we collect, and how we collect them. Note that not all of the ACFFG Services collect all of the data listed below:

  • Account Credentials. We may require you to provide an email address and password to use the ACFFG App or other ACFFG Services. We may also ask you to provide your phone number for account authentication purposes.
  • Device Information. We may collect certain software and hardware information about your Device. For example, we may collect an ID that is unique to the device or browser on which you install and/or access the ACFFG Services (“Device ID” and “Device,” respectively).
  • Location and Distance Information. When you use the ACFFG App, we will collect your location to determine your distance from other users (“Distance Information”) through the GPS, Wi-Fi, and/or cellular technology in your Device. Your last known location may be stored for the purpose of calculating Distance Information between you and other users.
  • Log Files. We may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them) to provide you with a more personal and interactive experience on the ACFFG Services and to improve our marketing efforts, including through the use of targeted advertising. Persistent cookies we place may be removed by following instructions provided by your browser. If you choose to disable cookies, some areas or features of the ACFFG Services may not work properly.
  • Messages. When you send a message (which may include photos, location, audio, or video to our customer care) we may retain the message for archival purposes or as otherwise allowed by law.
  • Profile Information. We may collect Personal Data from you. For example, in the ACFFG App, we may collect your name, age or date of birth, geo-location data, email address, and any other information that you voluntarily add to your message on the ACFFG email support or that is generated through your use of the ACFFG Services.
  • Purchases. We collect information necessary to complete purchases. This may include, among other things, your name, credit card information, billing information, address, telephone number, and email address.

ACFFG does not receive or process credit card information directly. We currently use Stripe or Google Play for purchases on Android devices and Apple for purchases on Apple devices. Please review their privacy policies at https://stripe.com/us/privacy, https://www.google.com/policies/privacy/, and https://www.apple.com/privacy, respectively, to better understand their practices. The ACFFG Services may include links to purchase ACFFG merchandise from our third party service provider. If you purchase such merchandise, the third party service provider’s terms of use and privacy policy apply. We currently use Amazon for ACFFG gear purchases. Please review their conditions of use at https://www.amazon.com/gp/help/customer/display.html?nodeId=201909000 and privacy notice at https://www.amazon.com/gp/help/customer/display.html?nodeId=468496 to better understand their practices.

Note that our third party service providers may provide certain information to us (e.g., your name, phone number, partial credit card number, and email address).

  • Feedback/Support. If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other Personal Data, as well as any other content that you send to us in order to reply and address any issue. If you contact us for support, we may also collect and retain certain technical diagnostic data, such as your phone model.
  • Mailing List. When you sign up for the ACFFG Services, we may collect your email address to send you ACFFG news, ACFFG Services updates, the latest information on products and services, and third party offers.
  • Surveys. When you participate in a survey, we may collect additional information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless noted otherwise, we use Survey Monkey for surveys.
  • Partner Promotion. We may collect information that you provide as part of a Partner Promotion (defined below).
  • Third Party Platforms. If you use or connect to the ACFFG Site or download the ACFFG Services through a third party platform, such as Facebook, you allow us to access and/or collect certain information from your third party platform profile/account. We may also access information contained in cookies placed on your Device by the third party platform. Note that we may share this information with the third party platform for their use.
  • Third Party Tracking. Our advertisers and partners may also use their own cookies or other tracking technology which may collect information about you within the ACFFG Services. We do not control use of these tracking technologies.

Use And Processing Of Your Personal Data.

In addition to the uses described above, we use your Personal Data in the following ways:

  • Identify You. To identify you as a user on the ACFFG Services.
  • Provide Products and Services. To provide the products and services you request, including the ACFFG Services.
  • Improve Services. To improve the ACFFG Services.
  • Communicate with you. To respond to your inquiries related to support, employment opportunities, or other requests, and to send Promotional Emails to those users that request or authorize them.
  • Partner Promotions. To conduct a Partner Promotion that you request.
  • Marketing and Advertising. For marketing and promotional purposes, including to inform you of products, services or offers of ACFFG, our related companies or business partners that may be of interest to you.
  • Administration. For internal administrative purposes, as well as to administer or manage our relationship with you, including to communicate with you regarding your use of ACFFG Services.
  • Employment. If you apply for employment with ACFFG or currently work for ACFFG, to manage your employment application, assess your qualifications, and manage your employment with us (applies solely to the ACFFG Site).

Sharing Of Personal Data.

In addition to the specific situations discussed above, we disclose Personal Data in the following situations:

  • Location Information. The ACFFG App may allow advertising partners to determine your location.
  • Third Party Tracking Companies. We may share your hashed Device ID, Profile Information, Distance Information, and demographic information with our advertising and analytics partners. These third parties may also collect information directly from you as described in this Privacy Policy. The privacy policy of these third party companies applies to their collection, use and disclosure of your information. For example, one of our many partners is Google Analytics which collects information anonymously and report website trends without identifying individual visitors.
  • Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the ACFFG Services; conduct quality assurance testing; provide technical support; and/or to provide other services to ACFFG. Except as otherwise stated in this Privacy Policy, these third party service providers are required by contract not to use your Personal Data other than to provide the services requested by ACFFG.
  • Sharing of Information with Advertisers. if you have given your consent, you acknowledge that ACFFG shares 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:

Adcolony     https://www.adcolony.com/privacy-policy/

Amazon    https://sellercentral.amazon.com/gp/help/external/521?language=en-US&ref=mpbc_1161272_cont_521

Applovin    https://www.applovin.com/privacy/

Appodeal    https://www.appodeal.com/privacy-policy

Appsflyer    https://www.appsflyer.com/privacy-policy/

Chartboost     https://answers.chartboost.com/hc/en-us/articles/200780269

Facebook Ads     https://www.facebook.com/about/privacy/

Flurry    https://policies.yahoo.com/us/en/yahoo/privacy/products/developer/index.ht

Fyber    https://www.fyber.com/legal/privacy-policy/

Google    https://policies.google.com/privacy?hl=en

InMobi     http://inmobi.com/privacy-policy/

MobFox    https://www.mobfox.com/privacy-policy/

Mobvista     https://www.mobvista.com/en/privacy/

MoPub    https://www.mopub.com/legal/supply-side-policy/

OpenX    https://www.openx.com/legal/ad-exchange-supply-policies/

Smaato    https://www.smaato.com/privacy/

Startapp    https://www.startapp.com/policy/privacy-policy/

Supersonic/IronSource     https://www.ironsrc.com/privacy-policy/

Tapjoy     https://home.tapjoy.com/legal/#privacy-policy

Unity    https://unity3d.com/legal/monetization-services-terms-of-service

Vungle     https://vungle.com/privacy/

  • Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
  • Affiliates and Acquisitions. We may share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under common control. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
  • Other Disclosures. ACFFG may disclose Personal Data in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.

Your Choices.

You can make the following choices regarding your Personal Data:

  • Promotional Emails. You may choose during the registration process to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials related to ACFFG and/or the ACFFG Services, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications, and our applications may deliver notifications directly to your mobile device in the ACFFG App.
  • Behavioral Advertising On Websites: Our websites may participate in third party behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by ACFFG. If you do not want third parties who collect information about your use of our website or applications to tailor any of the advertising that you see, you can opt-out at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.
  • Behavioral Advertising Within The ACFFG App. If you are using the ACFFG Services on an Apple iOS device, you may opt out of behavioral targeting by going into Settings > Privacy > Advertising on your iOS device, or visiting Apple’s website for more information. To opt out on an Android device, open the “Google Settings,” click on “Ads” and enable “Opt out of interest based ads.”
  • Behavioral Advertising Outside Of The ACFFG App. ACFFG works with advertisers who wish to distribute relevant and interesting ads to ACFFG users while the users are on other apps or websites not operated by ACFFG. If you don’t want advertisements sent to you on those apps or websites because of your affiliation with ACFFG, you may change the Behavioral Advertising settings on your device (discussed above) and/or opt out through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.
  • Effect Of Opting Out Of Behavioral Advertising. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the ACFFG Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.
  • Changes To Your Personal Data. ACFFG relies on you to update and correct your Personal Data. Please note that ACFFG may keep historical information and content in our backup files and archives as permitted by law and to the extent we anticipate that the information may be required in connection with the original purpose of the collection, or as otherwise permitted or required by law.
  • Deletion Of Your Personal Data. Typically we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the operation of the ACFFG Services or permitted by law. You may, however, request that we delete your Personal Data. All requests must be directed to the contact in the “Contact Information” section of the ACFFG Services. We may also decide to delete your data at any time if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete Personal Data, it will be removed from our active database, but in some circumstances, it may remain in certain archives where it is not practical or possible to delete it. In addition, we may keep your Personal Data and usage history (which includes a history of text or photos that have been censored, banned) as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
  • Revocation Of Consent. The ACFFG Services relies on the processing of Personal Data that you have provided. If you revoke your consent for the processing of Personal Data, then we will no longer be able to provide the ACFFG Services. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
  • Access To Your Personal Data. If required by law, upon request, ACFFG will grant a user reasonable access to the Personal Data that ACFFG holds about the user. All requests must be directed to the contact in the “Contact Information” section of the ACFFG Services.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While ACFFG uses reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, ACFFG cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access to your Personal Data, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Miscellaneous Information

The following additional information relates to our privacy practices:

  • Permissible Age. The ACFFG Services are intended for users 18 years of age and older only (twenty-one (21) years of age in places where eighteen (18) years is not the age of majority). If you are aware that a child or minor has submitted Personal Data on the ACFFG Services, please contact us using the information provided below so that we can take appropriate action.
  • Transmission Of Data To Other Countries. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding Personal Data may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach. By submitting your Personal Data, you agree to this transfer, storage and/or processing, including all associated risks.
  • Third Party Applications/Websites. We have no control over, do not review, and cannot be responsible for other websites or applications. If you click on a link to another website or third party application, the terms of this Privacy Policy do not apply.
  • Contact Information. ACFFG welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following:

3037 Limassol – Cyprus

ACFFG will also initiate an investigation if you contact us with a complaint against our privacy practices or a concern that our practices do not conform to the requirements in your jurisdiction. We will attempt, where practical, to ensure ongoing compliance with any legal obligations.

  • Changes To This Privacy Policy. If we make a material change to this policy we will, at a minimum, attempt to notify you of that change either by sending an e-mail to the last e-mail address that you provided to us (if any) or by notifying you when you log into the ACFFG Services. Continued use of the ACFFG Services indicates your agreement that any information relating to you, regardless of when it was collected, will be governed by ACFFG’s current policy.

Push notifications

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

Your rights for users locates within a GDPR country

In case you wish to use any of the rights described below, you may contact us at any time by emailing us at privacy@games.com.

ACFFG processes and answers your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by European Laws.

You have the right to request access

Being located in a GDPR country you  have the right to request access into the data that ACFFG is processing on you, including information about:

• the purposes of the processing

• the categories of personal data concerned

• the recipients or categories of recipient to whom the personal data have been or

will be disclosed

• the envisaged period for which the personal data will be stored

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

You have the right to object

This right allows you to object to ACFFG processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of interest rule. In this case, ACFFG will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. ACFFG will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.

You have the right to rectification and erasure

In accordance with European laws ou have the right to have inaccurate personal data rectified.

Furthermore, you have the right to have your personal data erased where one of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,

• if you have withdrawn your consent and there are no other legal grounds for the processing,

• if you have objected to the processing and there are no overriding legitimate grounds for the processing,

• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,

• the personal data have been unlawfully processed or

• the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

You have the right to restriction

You have the right to obtain restriction of processing in certain circumstances.

In any such case, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest

You have the right to withdraw consent

By virtue of applicable European legal requirements ACFFG has asked for your consent to our undertaking processing of your data. It is important to inform you that you have the right to withdraw your consent at any time.

If you withdraw your consent, ACFFG will cease processing of the data for which you have withdrawn consent, unless ACFFG has a legal obligation to keep some or parts of your data.

Please note that if you withdraw your consent, your user license to use the App will cease automatically.

The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

You have the right to data portability

By virtue of applicable European legal requirements you have the right to receive the personal data you have provided to ACFFG with which ACFFG processes in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller if the processing is based on consent or contract performance.

Last Revised: May 22, 2018