Privacy Policy
This Privacy Notice (the “Notice“) describes the ways your personal data is collected and used on our
mobile applications (each an “App”). It also describes the rights and options available to you with respect
to your information.
We collect information associated with your device
We collect your mobile device’s online identifiers, such as advertiser ID (IDFA on iOS device) and Android
ID (for Android devices). We also collect the device type and operating system, its locale (language), your
time zone settings on the device, the screen resolution on your device, the IP address that your device uses
for Internet connectivity and the country, city and region corresponding to that IP address. We refer to all
of this as “Device Information“. You do not have a legal duty to provide the information. However, the App
cannot operate without collecting this information
We also collect analytical
When you use the App, we will record and collect certain information in relation to your use of the App:
time and date of access, game events and actions you took while using the App, such as game levels
attempted, bets made, offers presented and accepted and game achievements. We refer to this as “Analytical
Information“. The overall personal data outlined above will be referred to as the “Information“.
To provide you the App’s features, functionality and game experience.
We use Device Information, Analytical Information, Purchase Information, Player Profile and Facebook
Information to provide you the App’s features, functionality and game experience, including in-app
notifications, promotions and offers.
For technical troubleshooting of the App and to provide user support
We use Device Information, Analytical Information, Purchase Information and Facebook Information for
technical troubleshooting of the App and to provide user support.
To respond to your inquiry
We will use your Inquiry Information to contact you about your inquiry and handle your inquiry. To address
your inquiry, we will also use your Device Information, Facebook Information, Purchase Information and
Analytical Information, depending on the nature of your inquiry.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
We will not share your information with third-parties, except in the events listed below or when you
provide us your explicit and informed consent. These are also the categories of third parties with whom
Spiral has disclosed personal information in the preceding 12 months.
We do not sell your information
Note that we do not sell your personal data to any third party and have not done so in the preceding 12
months.
SECURITY AND DATA RETENTION
We will retain your personal information for as long as we need it to operate the App, and thereafter as
needed for record-keeping matters. We retain personal data for the duration needed to support our ordinary
business activities operating the App. Thereafter, we will still retain your personal information as
necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and
enforce our agreements.
We implement measures to secure your Information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of
information. However, these measures do not provide absolute information security. Therefore, although
efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the
Service will be immune from information security risks.
We have no control over third-party content presented on the App and are not responsible for the privacy
policies of such third parties
Portions of the App link to or present content from third parties, including ads. We have no control over
this third-party content and are not responsible for the privacy policies of such third parties. We do not
endorse any products offered by third parties and we urge our users to exercise discretion in their reliance
on third party content.
Legal bases for processing your information
Our legal bases for processing information to provide you the App’s features, functionality and game
experience, is its necessity for the fulfillment of our contract with you under the Terms.
Our legal basis for processing information for technical troubleshooting of the App, for user support, and
for inquiries our legitimate interests in operating the App and our business.
Our legal basis for processing Survey Information is your consent when you participate in the survey.
Our legal basis for processing Player Profile information and ../publicly sharing it with other users is
our
legitimate interests in enhancing the social-sharing component of the App’s business.
Right to Restrict
processing your personal data (except for storing it) if you contest the accuracy of your personal data,
for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you
opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the
personal data for the purposes outlined in this Policy, but you require them to establish, exercise or
defense relating to legal claims, or if you object to processing, pending the verification whether our
legitimate grounds for processing override yours.
Right to be Forgotten.
Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase
your personal data. However, we may still process your personal data if it is necessary to comply with a
legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or
defense of legal claims.
You must be 21+ years of age or older in order to use the Service.
The Service is not intended for minors under the age of 21+. IF YOU ARE UNDER THE AGE OF 21+ YOU MAY NOT
USE
THE SERVICE IN ANY WAY.
