Privacy policy overview
The sole intention of the privacy policy is to provide you with the answers pertaining to the
collection, sharing, usage, visibility, advertisement and your user rights. We collectively call this
as our Privacy Policy. Changes made to this policy will be updated here from time to time along
with a notification to our users. The update will be sent prior to the change date, your continued
use of the service post the effective date will be considered as acceptance of the new policy and
shall be governed by the new privacy policy.
Data collection
Personal information we collect include Email & Name (if relevant to show your scores or to
certify at the end of the game). We will collect profile information, your selections during the
game will be collected to compute your results. In case of support tickets raised, we will store
your messages sent to us. Data surrounding identity establishment and lost account retrieval
provided by you is one other aspect of personal information we may need.
Data collected automatically are as follows:
- Your account and game progress will be captured and stored to maintain the session
grid. Else you may have to start an exited game in the mid, from start.
- Your IP address and mobile device identifiers (such as your device ID, advertising ID,
MAC address, IMEI).
- Data about your device, such as device name and operating system, browser type and
language, internet service provider, and mobile carrier.
- Data we collect with cookies and similar technologies.
- General location data (as derived from IP address).
- Data about your use of the Service, such as gameplay data and your interactions with
other players inside the Service.
Data collected from partners are as follows:
- Data we receive if you link a third-party tool with the Service (such as Facebook, Google
or Apple’s Game Center).
- Demographic data (such as to determine the coarse location of your IP address).
- Data to fight fraud (such as refund abuse in games or click fraud in advertising, although
this does not apply to our games since they have no real or fictitious wallet or money
management system. The question of refund does not arise in our games. If at all there
is, then this proviso will apply).
- Data from platforms that the games run on.
- Data for advertising and analytics purposes, so we can provide you a better Service.
- Data that you have made available to us from a third-party service (such as Google or
Facebook) via your privacy settings. This data helps us customize your game.
Data usage
The collected data is used for multiple purpose not limited to Service, Support, Advertisements,
Safety and Analysis during troubleshooting.
Identity establishment:
To ascertain who has agreed to our terms of service and use, create an account to store your
choices made in the game and retrieve the same in the form of a score. In short, the entire game
revolves around the choices made by the user during the game. We process the data and
choices to arrive at a score at the end of the game. We also use the data to ensure we are
sending the right user communication to the right user.
Profile management:
To ensure we keep a track of the games played by you and provide a better and superior service
to you every time, we require your data. We update your profile with the latest games played and
the scores gained. We use your data to create leaderboards and competitions. Based on your
engagement levels we may choose to reach out to you with similar games or products which are
appreciated by you. We may use your data to communicate with other players, largely statistical
data to compare other user’s performance. Your data will be required to be verified time to time
to ensure that there is no unauthorised access on your profile or device. We will also need your
data to analyse your preferences with respect to advertising on the platform.
Advertisement management:
We intend to show you only relevant advertisements based on the data about you available with
us. To show you personalized advertisements in the Service as well as in other websites and
services (including e-mail) we have a legitimate interest to process necessary data to track the
content you access in connection with the Service and your online behaviour. Deliver, target and
improve our advertising and the Service.
Safety & Analysis management:
We are committed to ensuring the right demographic uses our content. All efforts are made at
Simpencil to ensure content authenticity and correctness and more importantly Globally
Consumable Content has remained our top-most priority. We use your data to ensure we are
serving appropriate content (or level of difficulty in our games) to the right age group. We need
this also identify fraudulent and misbehaving players on our platform who indulge in
unacceptable behaviour and digital vandalism. We need your data for analysing, correlating, and
aggregating statistics and other information to serve you better.
Data visibility
Besides Simpencil your data can be accessed by others in the following scenarios.
when relevant. Your scores will be used to compute percentile position of others in the game. In
the case of a leaderboard, your information will be seen by other players.
Your details will be shared with partners who work with Simpencil in the production, distribution
and collation purposes including advertisement management.
Your details will be shared with public authorities in order to combat fraud and illegal activities.
We may provide your data to other companies or authorities or to competent public regulatory
bodies or authorities in response to lawful requests. We may disclose your data with or without
your consent to comply with the law or to protect the rights, property or safety of us, our players,
or others.
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We will need your data for in-game advertising, social media posting on your behalf, connecting
you to other partners who operate under their own privacy policies and data controls. The
Service includes features, such as social media interaction tools and in-game advertising,
provided by our below listed partners who operate under their own privacy policies as data
controllers. These partners can use advertising identifiers, cookies, web beacons, and other
tracking technologies to collect or receive data about you and your device (such as your IP
address, mobile identifiers, page(s) visited, location, time of day). We may also combine and
share data we have collected about you with third-party advertising partners. Our statements
under this Privacy Policy do not apply to the features, technologies or practices of such third
parties, as we may not control those features and are not responsible for them. We encourage
you to check their privacy policies to learn more about their data processing practices.
The Service may use third parties such as network advertisers and ad exchanges to serve you
ads, including interest-based ads, on the Service or on third-party services after you leave the
Service, and we may use third-party analytics and other service providers to evaluate and
provide us and/or third parties with information about the use of the Service and viewing of ads
and of our content. “Interest-based ads” are behavioral ads targeted to you based on your
activities across third-party sites and across time, including retargeting of ads after you have left
the Service and are on a third-party service.
Our Service is global by nature and your data can therefore be transferred to anywhere in the
world. Because different countries may have different data protection laws than your own
country, we take steps to ensure adequate safeguards are in place to protect your data as
explained in this Privacy Policy. Adequate safeguards that our partners may use include
standard contractual clauses approved by EU Commission and the Privacy Shield certification in
case of transfers to the USA.
Please check the privacy guidelines of Facebook, Google Play and other frequently visited online
services to understand the potential use of your data from time to time.
User rights
You can make a written request to
contact@simpencil.com to provide you
a copy of the data we
have about you in the electronic format.
You also have the right to correct your data, have your data deleted, object to how we use or
share your data, and restrict how we use or share your data. You can always withdraw your
consent, for example by turning off GPS location sharing in your mobile device settings. You
have the right to complain to a data protection authority about our collection and use of your
personal information. For more information, please contact your local data protection authority.
We will respond to all requests in accordance with applicable laws. To protect your privacy, we
may also take additional steps to verify your identity before fulfilling your request, such as by
requesting you provide us a purchase receipt or other account information, asking you to link
your email address with your game account or asking you to answer questions regarding your
activities on our Services. Once you have verified your identity, you may also designate an
authorized agent to exercise your rights on your behalf by providing the agent’s contact information
to our customer support staff, as required by applicable law. You may have a right
not to receive discriminatory treatment as a result of your exercise of these rights.
To provide our Games and interest-based advertising, we use advertising identifiers, cookies and
similar technologies. This section describes our use of these technologies and how you can
manage your preferences.
Advertising identifiers, cookies and similar technologies are used by us to provide our Services to
you and in order to collect data from your device. These technologies allow us and our third-party
advertising partners to (i) recognise you and your device; (ii) provide interest-based advertising to
you; (iii) allow our Services to interact with a third party social network or platform (where you
have chosen to allow such interaction); (iv) allow our payment processors to process your
payment instructions; and (v) enable us and third parties to provide you with more customized
services, for example to provide our Services in the correct language (subject to availability).
Advertising identifiers are non-permanent, non-personal identifiers such as the Android
advertising ID and/or Apple’s ID for advertising (IDFA), which are uniquely associated with your
device. Similar technologies include cookies on Websites and tracking pixels within ads. These
technologies allow companies (including marketers and advertisers) to recognise your device
when you use websites and applications. If you wish to prevent your device’s advertising
identifier being used for interest-based advertising, please check the privacy settings of your
mobile device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads”
(Android). You can also choose to reset your device’s ad identifier from the device settings. In a
comparable way, you can also disable cookies from your browser’s settings if you do not want to
be tracked by websites. This Privacy Notice does not apply to, and we are not responsible for the
data collection practices of these third-party advertisers. Please see more information about
these partners under the “With whom do we share your personal information” heading above.
You may also see our own advertisements in other games and services. If you click such
advertisements and install our Game(s), we may share a device identifier with our partners to
verify installs. our personal information may be transferred to, and processed in, countries other
than the country in which you are resident. These countries may have data protection laws that
are different to the laws of your country. Specifically, our servers are located in India, US &
Singapore, and our third-party service providers and partners operate around the world. This
means that when we collect your personal information, we may process it in any of these
countries.
In case of Merger or Acquisition of our company, reorganization or bankruptcy, receivership,
purchase or sale of assets, or transition of services to another provider, your information may be
sold or transferred in parts during the transaction as permissible by the law.
We retain your data as long as necessary to operate our legitimate business and its needs.
When we ascertain that there is no longer any need to retain your information for the business,
we may choose to delete or anonymize it or store you information and isolate it from any further
processing until deletion is possible.
We do not collect information about anyone below the age of 13 or knowingly allow them to use
our services. If you are under 13 (or as applicable age-limit in your geo territory) please refrain
from sending us any personal information about yourself. In case we know about the same, we
will delete the information as quickly as possible. If you think we have information of anyone
under the age of 13, please contact us immediately.
Contact details
Your data is controlled by Simpencil Private Limited. Merchant ID: 378772903974534846
Once your data is removed, your social media linked to account will also be removed, your
account will not be accessible once your data is removed.