Privacy

As used in this Privacy Policy, "smuttlewerk," "we", "us" or "our" refers to smuttlewerk interactive UG (haftungsbeschränkt), registered at Donnersbergweg 1, 67059 Ludwigshafen, Germany, and all of its subsidiaries.

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the "EULA") governing the use of all "smuttlewerk interactive" branded software applications (the "Applications"), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or the www.smuttlewerk.com website (the "Website"). This Privacy Policy covers how we collect, use, disclose, transfer and store information received about you and/or information received about your computing device through your use of the Applications or the Website.

By agreeing to the EULA and/or using the Applications or the Website, you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may receive and/or you may be asked to provide your information (including personal information) anytime you are in contact with us or use any of the Applications or the Website. As described in greater detail below, we and our affiliates may share this information (including personal information) with each other and with third-party Partners (as defined below) and use it consistent with this Privacy Policy. We may also combine your information (including personal information) with other information to provide and improve products, services, content and advertising.

Our Information Collection Practices

We automatically obtain certain information about your computing device, including:

- IP address;
- Unique device identifiers, such as UDIDs;
- ZIP code;
- Language;
- Country code;
- Time zone;
- smuttlewerk interactive Applications installed; and
- Technical device data (e.g., device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, etc.).

Although some of this data (such as UDID) may uniquely identify your device, this data does not identify you personally.

When you use the Applications or the Website, we may collect additional non-personally identifiable information, which is data in a form that does not permit direct identification of you or any specific individual. Examples of non-personally identifiable information that we collect include:


- Which advertisements are shown;
- Length of time an advertisement is visible and the size of the advertisement;
- Advertisement response (if any), including clicks on ads;
- Angle of view;
- Application usage data, including in-game location;
- Website usage data; and
- Characteristics obtained by your continuous use.

We may also collect personally identifiable information about you (such as your name, email address, and phone number), as well as non-personally identifiable information (such as the type and model of your computing device), when you voluntarily register with smuttlewerk interactive, request information using the Website, or contact us directly.

When you want to share the content you created within the Application on Facebook, you allow smuttlewerk interactive to access certain information from your Facebook profile. The information you allow smuttlewerk interactive to access varies by Application, and it is affected by the privacy settings you and your friends establish at Facebook. You can control and find out more about these settings at Facebook. By using the Application to share content on Facebook, you are authorizing smuttlewerk interactive to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the Facebook could provide to smuttlewerk interactive through the Facebook Application Programming Interface ("API"). Your agreement takes place when you "accept" or "allow" (or similar terms) one of our applications on Facebook. smuttlewerk interactive may access and store some or all of the following information, as allowed by you, the Facebook and your preferences: (i) your basic information; (ii) your photos and videos. Application may further ask you to allow smuttlewerk interactive to (i) post on Facebook on your behalf (e.g. photos, (postards), videos and status updates) and to (ii) manage your notifications (access your notifications and mark them as read).Please keep in mind that smuttlewerk interactive will only do that if specifically directed by you and will not store any of the above information information on its servers. It will merely store the necessary information within the Application on your device, so that the Application will be able to communicate with Facebook directly and smuttlewerk interactive will not use your personal information any other purpose.

When you want to share the content you created within the Application on YouTube, you allow smuttlewerk interactive to access certain information from your YouTube profile. smuttlewerk interactive may access your user name and use your credentials to post on YouTube on your behalf. Please keep in mind that smuttlewerk interactive will only do that if specifically directed by you and will not store any of the above information information on its servers. It will merely store the necessary information within the Application on your device, so that the Application will be able to communicate with YouTube directly and smuttlewerk interactive will not use your personal information any other purpose.

Collection of Data Log files
Application might automatically send anonymized and obfuscated data log files to us that contain detailed data on your usage of the Application ( e.g. data log files containing chat history, where (i) such history cannot be attributed to any individual person; and (ii) any personal details (e.g. personal names, addresses, numbers, places, etc.) are obfuscated / deleted). Such data log files are used solely for the purpose of analysis, development and improvement of individual functions within the Application with the aim to make the Application more appealing to users. Such data log files do not enable us to identify any individuals directly. Any such collection of data log files shall be clearly disclosed within the description of the Application on the market and an implied but informed consent shall be deemed to be given to us by downloading and using the Application.

Our Use of Cookies and Related Technologies
The Applications, the Website, advertisements, and other online services may use UDIDs, cookies and other tracking technologies such as, but not limited to, pixel tags, tracking pixels and web beacons. These technologies are used for a variety of purposes related to our delivery of content and advertising to you, including:


- Enabling us to control the number of times you see a given ad;
- Enabling us to deliver ads that relate to your interests;
- Helping us better understand user behavior, such as how people interact with our Applications and which parts of our Website people have visited;
- Facilitating and measuring the effectiveness of advertisements displayed on the Applications or the Website;
- Allowing us to monitor Application activity, including, traffic, statistics, clicks on advertisements and/or other activities on the Applications; and
- Compiling anonymous statistics about users of the Applications and visitors to the Website.

We treat information collected through our use of tracking technologies as non-personal information and store it in log files. However, to the extent that UDIDs, Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information.

We generally do not combine or connect non-personal information with personal information, unless such connection is necessary to provide services to you. To the extent that your non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Our Use of Information
We use information we collect about you or your computing device to deliver services to you and to operate our business. Such uses may include:


- Developing, delivering and improving our products, services, content and advertising;
- Tailoring products, services and advertisements to your interests;
- Keeping you posted on smuttlewerk interactive?s latest product announcements and software updates;
- Improving our services and content;
- Understanding and analyzing trends in connection with usage of the Applications and the Website;
- Administering the Applications and the Website;
- Learning about user behavior within the Applications; and
- Gathering broad demographic information about our user base.

From time to time, we may use your personally identifiable information to send important notices to you, such as communications about purchases and changes to our terms, conditions and policies. We may also use your information, including personally identifiable information, for internal purposes such as auditing, data analysis and research to improve our products, services and customer communications.

Disclosure to Third Parties
We cannot provide all services needed for successful operation of the Applications or the Website by ourselves. Therefore we must share collected information with third parties, including third-party advertising companies that assist us in delivering advertising to you that allows us to continue offering the Applications for free or at a low cost.

We have therefore contracted with certain third-party advertising networks such as Apple (iAds), Google (AdMob), InMobi, MobClix, Millennial Media and TapJoy; statistical services providers such as Apsalar and Flurry; and other third-party service providers that support the Applications and the Website (collectively, "Partners"). Our Partners provide services such as advertising, marketing, hosting, information processing, order fulfillment, product delivery, customer data management and enhancement, statistical analysis, customer service, recommendations, customer research and analysis, satisfaction surveys and customer profiling. We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications or the Website.

We may share information (including personally identifiable information) that we have collected with our Partners. We may share information that can be used to personally identify you (e.g., your name, email address, phone number, or physical address) to Partners for the purpose of improving our products, services and advertising.

In addition, Partners may use their own tracking technologies (including without limitation cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about users of the Applications and visitors to the Website. Partners may share anonymous information that they collect with their clients, including the date and time a banner ad was shown, the specific ad shown, and the IP address or UDID of the computing device where the ad was displayed.

Unlike the tracking technologies used by us in content we control on the Website and in the Applications, we do not control or have access to the information collected by our Partners using their own tracking technologies. Their information gathering practices, including their policies regarding the use of cookies, Web beacons, and other tracking technologies, are governed by their own privacy policies, not this one.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

Some of the Applications allow you to submit content generated in or by the Applications to third-party sites like Facebook and YouTube. These submissions follow the data transfer protocols for such third parties, which are designed to enable content sharing with such third parties and generally prevent any storage of information necessary for access to such third party services by us. In addition, we may receive certain information (which may include your personally identifiable information) from such third parties through the use of Application Programming Interfaces provided by such third parties. These third-party sites are governed by their own privacy policies and end user agreements, and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites.

Third-Party Terms and Conditions
Please note that your access to and ability to use and interact with the Applications and the Website may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services, statistics services providers and payment providers. You recognize and agree that smuttlewerk interactive is not liable for any such third-party terms and conditions and their use of your personal data.

Protection of Personal Information
We have implemented reasonable security measures to protect the confidentiality of personal information that we receive from you. Although we use commercially reasonable efforts to assure that your data remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Integrity and Retention of Personal Information
We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Access to Personal Information
We make good faith efforts to provide you with access to the personal information you provide to us or that is associated with your account. You can also request that we correct or delete data, provided that we are not required to retain such data by law or for legitimate business purposes.

We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests can be made through the smuttlewerk interactive website.

Children
Our products and services are not directed to, and we do not knowingly collect personal information from, children under 13. If we learn that we have collected personal information of a child under 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us.

Third-Party Sites
The Applications, the Websites, products and services may contain links to third-party websites, products, or services. For example, the Applications may feature offers from third-party advertisers or the ability to engage in transactions with such entities. Please note that while using such third-party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party?s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. These other websites or services may place their own cookies or other files on your computing device, collect data or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.

We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.

Opt-Out
You are always free to opt-out from the future collection of your personal information by smuttlewerk interactive in accordance with this Privacy Policy by uninstalling all the Applications from each of your computing devices and discontinuing use of the Website.

Changes to Our Privacy Policy
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at http://www.smuttlewerk.com

Privacy Questions
If you have questions or concerns about smuttlewerk interactives Privacy Policy or data processing, please contact us through http://www.smuttlewerk.com

Updated May 2016