Privacy Policy
Last updated January 2022
We are Neon Play Limited, a company registered with Companies House in England and Wales under number 07187620, whose principal place of business is at Old Museum, Tetbury Road, Cirencester, England, GL7 1UP ("Neon Play"/"we"/"us"/"our").
We provide mobile games ("Games") that can be accessed through the website www.neonplay.com or through the Apple Game Store, or the Google Pay Store.
Because you use the Website www.neonplay.com (the "Website") and/or our Games, we process your personal information in accordance with this Privacy Policy (the "Policy"). This is part of the contractual framework you enter into while downloading and using the Games and/or the Websites (together as the "Services"). It specifies the legal basis upon which we process your personal information as data controller.
We are committed to protecting and respecting your privacy and your data rights. If you have any questions or comments about this Privacy Policy, you can contact the data protection officer (DPO) we designated for this purpose at gdpr@gdpr.neonplay.com
So, let’s describe what this Policy tells you. It explains:
- what information we may collect about you;
- what we may do with the information we collect about you;
- whether we share your information with anyone else;
- the types of cookies we use and how you can reject these cookies;
- where we store your information;
- how we keep your information secure; and
- the rights you have regarding the personal information you have provided to us
THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU
1. The information we collect to correspond with you
If you contact us (by phone, email, through the Website, a Game or Discord) as part of our contractual relationship, we can collect and store several pieces of information about you (name, address, telephone number and/or email address).
We use the data you provide to correspond with you and we keep it in case we need to contact you in the future in relation to the issue for which you contacted us.
We may keep a record of that for one year after our last contact with you. If you report a problem with the Website or a Game, we may keep that information for the same duration.
This information is intended for us only and will not, under any circumstances, be sold or leased to third parties. This data may, however, be communicated to third-party technical service providers, solely for the purpose explained above.
2. The information we collect to provide you the Services when you use our Games
When you play our Games, we collect IT tracking information from you, which may include:
- a pseudonymous identifier to identify you;
- any preferences that you have selected;
- performance related data (such as scores and achievements);
- device information (such as your operating system, locale, version, device model and capabilities/specifications of the device);
- session information (how long you play our Games for);
- connection type (for example, WiFi, 3G, 4G);
- which Games you are playing or have played previously and attempts within those Games;
- mac address;
- network service provider;
- approximate location (city and country based off of your IP address);
- IP address;
- locale information (such as country, time zone and language);
- device advertising identifier (this is a unique identifier, that identifies your device, but not related to any personally identifiable information);
- purchase information (to let us know what you purchased,no payment details are collected);
- date and time of your first launch of a Game
- advertising information (such as how many adverts you have seen while playing our Games)
We collect this personal information to:
- provide you the Services
- ensure that you are a real person and not a robot;
- help us identify any errors in our Games and make your experience better and more personal. By collecting analytical information about your continued participation in the Game, we can determine whether the change is worthwhile and whether it improves your overall experience with our Games.
- help us identify which group of users are most active in our Game. This includes but is not limited to: country, gender, age range (not an exact age, but a range. For example, 20 to 24 years old), device manufacturer and operating system information, etc.
We may retain this information for one year after our last contact with you.
This information is for our use only and will not be sold or rented to any third party. This data may, however, be communicated to or by third party technical service providers, solely for the purpose of providing the service.
3. The information used in relation to advertising
Our Games are primarily funded by advertising. To do this, we use several third-party advertising companies to provide you with applicable in-game advertisements.
We use a device ID called an IDFA for advertising purposes and allow third parties such as social networks (see comprehensive list in the table below) to drop a file called SDK on your device while using the Game, which enables them, if you agree, to display personalized advertising while you are using the Game.
Third party IDFAs/SDKs are deposited under the contract, but their use by third party publishers to provide targeted advertising is subject to consent.
Where we propose using your personal information for any other uses, we ensure that we notify and if needed, ask for your consent first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes described in this point.
a. Data may be collected by third-party displaying adds on our Games
| NAME OF THIRD PARTY | TERMS AND CONDITIONS / PRIVACY POLICY |
|---|---|
| AdColony | https://www.adcolony.com/privacy-policy/ |
| AdMix | https://admixplay.com/privacypolicy/ |
| Google AdMob | https://policies.google.com/technologies/ads |
| AppLovin | https://www.applovin.com/privacy/ |
| Chartboost | https://answers.chartboost.com/en-us/articles/200780269 |
| https://www.facebook.com/about/privacy | |
| IronSource | https://www.ironsrc.com/privacy/ |
| Tapjoy | https://tapjoy.com/legal/#privacy-policy |
| Tik Tok | https://www.tiktok.com/legal/privacy-policy |
| Unity Ads | https://unity3d.com/legal/privacy-policy/ |
| Vungle | https://vungle.com/privacy |
| Fyber | https://www.fyber.com/website-privacy-policy/ |
| Pangle | https://www.pangleglobal.com/privacy |
If you click on these ads, we are no longer responsible for the data you provide to these platforms. For this, we invite you to consult their privacy policies.
b. We also use third party identifiers to make user acquisition
| NAME OF THIRD PARTY | TERMS AND CONDITIONS / PRIVACY POLICY |
|---|---|
| AdColony | https://www.adcolony.com/privacy-policy/ |
| AppLovin | https://www.applovin.com/privacy/ |
| Bidshake | https://www.bidshake.com/privacy-policy |
| https://www.facebook.com/about/privacy | |
| Google Ads | https://policies.google.com/technologies/ads |
| Snapchat | https://www.snap.com/privacy/privacy-policy/ |
| Unity Ads | https://unity3d.com/legal/privacy-policy/ |
| Vungle | https://vungle.com/privacy |
4. The information collected and used from third parties for research
a. Mediation partners
When playing our Games, we may be provided data by the source of your installation and your native device game manager.
Analysis of how you interact with our Games will help us understand where to place advertising and determine the best location and timing for it.
These sources may include but are not limited to:
| NAME OF THIRD PARTY | TERMS AND CONDITIONS / PRIVACY POLICY |
|---|---|
| AdColony | https://www.adcolony.com/privacy-policy/ |
| AdMix | https://admixplay.com/privacypolicy/ |
| Bidshake | https://www.bidshake.com/privacy-policy |
| Chartboost | https://answers.chartboost.com/en-us/articles/200780269 |
| https://www.facebook.com/about/privacy | |
| Snapchat | https://www.snap.com/privacy/privacy-policy/ |
| IronSource | https://www.ironsrc.com/privacy/ |
| Google Ads | https://policies.google.com/technologies/ads |
| Singular | https://www7.singular.net/privacy-policy/ |
| Firebase | https://firebase.google.com/support/privacy/ |
| https://policies.google.com/privacy | |
| AppLovin | https://applovin.com/privacy/ |
| Tapjoy | https://tapjoy.com/legal/#privacy-policy |
| Unity | https://unity3d.com/legal/privacy-policy/ |
| Vungle | https://vungle.com/privacy |
| Fyber | https://www.fyber.com/website-privacy-policy/ |
| Tik Tok | https://www.tiktok.com/legal/privacy-policy |
THIS IS WHO ELSE WE SHARE YOUR INFORMATION WITH
We may disclose your personal information to third parties, but only in the ways that are described in this policy:
- if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request;
- to enforce or apply our terms of use/terms and conditions and other agreements or to investigate potential breaches; or
- to protect the rights, property or safety of our Services, or our users.
- if we are involved in a merger, acquisition, or sale of assets. If such an event occurs, we will either notify you directly, or place a notice on our website (https://www.neonplay.com) notifying you of such;
- we may disclose your information to our personnel, contractors, members of our group, our holding company, and any subsidiaries of such parties. These are defined in section 1159 of the Companies Act 2006.
THIS IS WHERE WE STORE YOUR INFORMATION
All information you provide to us is stored on Firebase (Google) and GameAnalytics. The destination of the data depends on the project and the Google Cloud settings, but we generally default to either the United States or Belgium.
In addition to their location, the data that we collect from you may be processed outside the European Economic Area (EEA):
- By other third parties acting, as AWS, as data processors (i.e. they are processing the data only for purposes that we determine), but we have ensured that there is an adequate level of protection for such data (Biding Corporate rules or standard contractual clauses);
- By third parties acting as data controller. They are listed in the tables above, and the links to their Privacy policies can lead you to more information.
We suggest that you refer to the privacy policies of those third parties (listed above in this policy).
If you’d like to find out more about the safeguards we have in place, please email gdpr@gdpr.neonplay.com
HERE ARE YOUR RIGHTS
You have the following rights over how we process your personal data. We endeavour to respond to any request within 1 calendar month. To issue a formal request, please email gdpr@gdpr.neonplay.com with your device advertising identifier.
You have:
- The right to opt-out and control your data for marketing purpose
- The right to request a copy of your data
- The right to correct your data
- The right to delete your data
- The right to obtain a programmatic machine readable copy of your data
- The right to make a complaint to a supervisory authority
THIRD PARTY PROPERTIES ACCESSED FROM THE WEBSITE AND/OR GAME
Our Services may contain links to external services which are owned and operated by third parties. If you follow a link to any of these online properties, please note that they have their own privacy policies which will govern use of any personal data that they process and for which we can not be held responsible.
NO MARKETING TO CHILDREN
We do not knowingly advertise to children under the age of 16 or collect their personal information.
In the unlikely event that we have (or you believe we have) collected information from a child, please contact us by emailing gdpr@gdpr.neonplay.com where we will take all necessary steps to purge the data from our systems.
INFORMATION SECURITY
We take security seriously. As such, we take all reasonable measures and precautions to ensure any data we hold is safe. These steps include:
- reducing the amount of personal data collected to a strict minimum
- limiting access to specific personnel
- encrypting any data in transit or storage locations.
Despite all of the precautions and preventive measures we take, no security system or precaution can be 100% secure.
CHANGES TO OUR POLICY
Any changes we may make to this Policy in the future will be posted on this page. Where it makes sense because the changes are material, we will notify you of the changes in any appropriate manner such as when you next interact with the Website or a Game.
CONTACTING US IS EASY
We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at gdpr@gdpr.neonplay.com.
We will respond to you in a timely manner but advise that it might take up to a week for a response, and up to 1 calendar month to process any data related requests.