Privacy Policy

Introduction

Welcome to Primal Studio Ltd.'s Privacy Policy. This policy describes how Primal Studios Ltd. and its third-party marketing and advertising partners collect, use, process and share information about our service's users.

This Privacy Policy applies to all our games, whether played on mobile devices, PCs or on other platforms such as Facebook. The Privacy Policy also applies to our Marketing and Advertising activities on all supported platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our Products as our "Services".

By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you will have agreed to the collection and use of your information in accordance with this Privacy Policy., including consenting to Primal Studios Ltd.'s and our advertising partners' use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any other concerns and or doubts about providing information to Primal Studios Ltd. or it being used as described in this Privacy Policy, you should not use our games or other Services.

This Privacy Policy was last updated on the following date: 06.01.2018.

Playing our games

By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of information about you by Primal Studios Ltd. This data mostly comes directly from you or your device, such as device information, country and region, and game play information. We use this data to provide our games and Services to you, including for the purposes of optimization, preventing fraud, customizing in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites or other Services. Most of the information we collect about you relates to the type of device you use, how you play our games (such as purchases made and levels attempted) and may include information which you allow Primal Studios Ltd. to access when you connect to your social network accounts (Facebook for now) through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests. In more detail, depending on which of our Services you interact with we may collect and process the following types of information: details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services or details regarding profile visits, as further set out in playing socially); information that you provide Primal Studios Ltd. with when you fill in forms, answer questions or complete surveys when using any of our Services or if you invite your friends to use our games and Services; the content of messages sent using our chat and messaging systems; if you contact Primal Studios Ltd., for instance through our Primal Studios Ltd. Contact page on our website or respond to messages and communications that we send to you, we may keep a record of that correspondence; your interactions with Primal Studios Ltd. on our social media channels; information we collect via cookies and other similar technologies, as explained further below; information as further set out in this Privacy Policy, including playing socially, Marketing, and Advertising; information we collect about you from our other group companies or other third party companies who have obtained your consent or have another legal right to share such information with Primal Studios Ltd. (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this Privacy Policy and subject to any limitations in the privacy policy of the company that collected the information from you. If you choose not to connect using your Facebook account to our services, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including: the type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, a Primal Studios-specific player ID, and the country or region that you are playing in; and how you play our games and interact with our websites or other Services (such as which of our games you are playing, your progress through the games, session time and duration, number of attempts at each level and purchases made). In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by Primal Studios Ltd. We do not collect or retain credit card information. Our payment service providers will provide Primal Studios Ltd. with information about your purchases so that we know if a purchase has been successful. When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you. may from time to time ask you for your consent to collect other information from you or your device. For instance, we may invite you to allow Primal Studios Ltd. to access your contacts to enable Primal Studios Ltd. to invite them to play our games with you. If we do this or something similar, we will tell you what information we would like to collect, why we need it and what we'll use it for. We, our suppliers and group companies, may use this information: to enable Primal Studios Ltd. to provide our games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the games, and to provide you with player support if you need it; to enable Primal Studios Ltd. to optimize our games for you and for the device that you are using, as well as to deliver customized in game events, offers and promotions; for the other purposes as set out in this Privacy Policy, including for Marketing and Advertising purposes; and to enable Primal Studios Ltd. to comply with laws that apply to Primal Studios Ltd., to prevent fraud, to ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service (www.primalstudioz.com/terms). We may also share your information with third party publishers who develop and provide games and other Services to you on our behalf. We also analyze and use the information that we collect on an anonymized or aggregated basis for product development, to analyze the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole. A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy. Providing and optimizing our Services We use your information to enable Primal Studios Ltd. to provide our websites, advertising and other Services to you and to optimize all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players. Chat Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to Primal Studios Ltd. customer services or publicly on our forums. Your messages may be used and stored by Primal Studios Ltd.: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose. Customer Services We use your information, including data that you provide directly to Primal Studios Ltd. in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your relationship with Primal Studios Ltd. and improve your experience when you use our Services. One of our customer service channels is the Primal Studios Ltd. contact page on our website (https://www.primalstudioz.com/#contact). Analytics and Research We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by Primal Studios Ltd. for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content. Social and Community We have several social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels. Promotions and Competitions From time to time we may run promotions or competitions during which we may collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We may also publish the names and entries of competition entrants. Cheating, crime and fraud prevention We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as the police. Legal uses We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.

Visiting our websites

When you visit our website, such as www.primalstudioz.com, www.jellyjellies.com, and other websites and forums operated by Primal Studios Ltd. we collect information about you, such as details about how you use and interact with those Websites. We may use your collected information for several reasons, including for operating and optimizing the Websites, in connection with our advertising purposes, and for analysis or research. The information we collect and process about you when you visit our Websites includes: information that you provide Primal Studios Ltd. with when you fill in forms or contact us on our Websites; details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites); if you contact Primal Studios Ltd. or respond to messages and communications that we or other users of the Websites send to you, we may keep a record of that correspondence; your interactions with Primal Studios Ltd. on our social media channels; and information we collect via cookies (which are small text files placed on your device), and. Cookies allow Primal Studios Ltd. to collect data, such as your device's model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies below. We, our suppliers and group companies, may use this information: as necessary in order to provide the Websites and related services to you; for the purposes of contacting you, for example as part of customer service or to send you updates about the Websites; for the purposes of improving your experience when you use the Websites; for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes; for the purposes of marketing and promotion of Primal Studios Ltd.'s products, for example sending you communications (including by email) for these purposes on our, or a third party's behalf. For example, we might send you information about merchandise relating to our games. If you do not want Primal Studios Ltd. to use your data in this way please let Primal Studios Ltd. know by contacting Primal Studios Ltd. at info@primalstudioz.com; to create reports, analysis or similar services for use by Primal Studios Ltd. for the purposes of research or business intelligence, for example to track potential problems or trends with the Websites; for the purposes of preventing cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention; or as otherwise expressly set out in this Privacy Policy or as required by law.

Playing socially

You can choose to connect our Services with a third-party network (Facebook). If you do this, then your personal information (name) will be visible to other players and we'll also use it for the other purposes set out in this Privacy Policy, including Marketing and Advertising. Connecting with a third party network Where we make this available, you can choose to log in using a third party network (Facebook), such as Facebook or Google. If you do this, you will be able to use your Facebook account to log in on multiple devices and synchronize progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play, asking other players for lives and 1-2-1 messaging. Information we receive from Facebook If you log in using your Facebook account the information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information. We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can choose not to allow Primal Studios Ltd. to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with one of our games. If you provide Primal Studios Ltd. with your email address, we may from time to time use that email address to send you marketing emails about our other games and Services. You can opt out of this at any time - see Opting-out of direct marketing from Primal Studios Ltd. below. Logging in with Facebook will not allow Primal Studios Ltd. to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings. We would recommend that you read Facebook's Privacy Policy (www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.

Marketing

Primal Studios Ltd. uses collected information about you to send you marketing communications about other related Services and games made by Primal Studios Ltd. unless you had opt out of this as explained in "More Details" on our website: www.primalstudioz.com. An example of the above mentioned usage is sending emails, placing ads on third party websites, apps, and Internet-connected devices and serve ads within Primal Studios Ltd.'s Services. We may use the information that we hold about you to promote Primal Studios Ltd.'s own Services in a number of ways. This might include: advertising within third party websites, apps and Internet-connect devices; showing you promotions for other Primal Studios Ltd. games in the games you play; or sending you marketing materials by email. What information do we use for marketing? We use information about you to try to make sure you only see marketing from Primal Studios Ltd. that might be of interest to you. This includes using information that we may have about you, such as: ad identifiers and other non-personal information collected from your device. For more information, see Ad identifiers, cookies and similar technologies; the games you play and information about how you interact with our games and Services; your age, country or region, and gender; and other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with Primal Studios Ltd. Marketing partners When we market our games in media published by other companies, we use various third party marketing partners to assist Primal Studios Ltd. on our behalf, and we may share information which we have collected about you with such third parties for these purposes. Our marketing partners may help Primal Studios Ltd. to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Primal Studios Ltd.'s games or Services, they will serve you with a Primal Studios Ltd. ad while you are using other websites and services. By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies. This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners' privacy policies for more information. A list of our marketing partners and their privacy policies can be found here. Opting-out of direct marketing from Primal Studios Ltd. You can exercise choices over the direct marketing we send you in the following ways: you can withhold your consent for Primal Studios Ltd. to send you direct marketing emails by opting out when we collect your email address or by electing not to share your email address with Primal Studios Ltd. when you first sign in using your Facebook account; you can remove yourself from receiving email marketing from Primal Studios Ltd. at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or sending an email to info@primalstudioz.com.

Your rights

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting Primal Studios Ltd. via any of the methods set out in the Contact Primal Studios Ltd. section below. Those rights include: Right of access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact Primal Studios Ltd. letting Primal Studios Ltd. know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let Primal Studios Ltd. know at info@primalstudioz.com and we will correct it as soon as we can. Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Primal Studios Ltd. using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players' devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a Wi-Fi network. Facebook Account deactivation. If you have logged in using your Facebook account and you then disassociate it with one of our games, note that if you completely disassociated your Facebook account, all your progress in our games and any unspent virtual items, such as Gold Pieces or Boosters will be lost upon deletion of the game. You will not be able to restore these purchases in the future. Data portability. In some circumstances, you may have the right to request that data which you have provided to Primal Studios Ltd. Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by Primal Studios. Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below). Direct marketing opt out. You can exercise choices over the direct marketing we send you in the following ways: you can withhold your consent for Primal Studios Ltd. to send you direct marketing emails by opting out when we collect your email address or by electing not to share your email address with Primal Studios Ltd. when you first sign in using your Facebook account; you can remove yourself from receiving email marketing from Primal Studios Ltd. at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or sending an email to info@primalstudioz.com.

Children

There is a required minimum age you must be to play our games and use our Services, depending on where you live. For the full list of age restrictions by country, please see the table on our website under "More details". We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the ages set in the table on our website, or knowingly allow such individuals to use our Services. If you believe that we might have collected any information from or about a child under the age set out on our website in the table under "More details", then please Contact Primal Studios Ltd. The table below sets out what age you must be to play our games and use our Services, depending on what country you are in while using our games and Services. Our games are intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our games or use our Services if you are under the relevant age.

Country
Required minimum age to play our games and use our Services
Austria
14
Belgium
13
Bulgaria
13
Croatia
13
Republic of Cyprus
13
Denmark
13
Estonia
13
Finland
15
France
16
Germany
16
Greece
13
Hungary
16
Ireland
13
Italy
13
Latvia
13
Lithuania
16
Luxembourg
16
Malta
13
Netherlands
16
Rest of the world (excluding Korea)
13
Romania
13
Portugal
13
Slovakia
16
Slovenia
13
Sweden
13
Spain
13
United Kingdom
13
Poland
13

General

Our Privacy Policy contains further details about:

  • Measures we take to keep your information secure;
  • Who we share your information with and the reasons for sharing it with them;
  • How long we retain your information and where we store it;
  • The legal bases under which we process your data;
  • How long we retain your information and where we store it;
  • When and why we share your information with third parties, including transfers outside of the European Economic Area (the "EEA");
  • Changes or updates to our Privacy Policy.

Sharing In addition to the other disclosures described in this Privacy Policy, we will also share your information: where we have your consent to do so (including as set out in this Privacy Policy); as reasonably necessary to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you); where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors); where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it; as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Primal Studios Ltd., our users, or others; and if there is a sale of the assets of Primal Studios Ltd. or corporate restructuring, or as a result of a change of control of Primal Studios Ltd. or one of its group companies, or in preparation of any of these events. Any third party to which Primal Studios Ltd. transfers of sells Primal Studios Ltd.'s assets will have the right to continue to use the personal and other information that you provide to Primal Studios Ltd. in the manner set out in this Privacy Policy. We may also share your information with our service providers if necessary to enable them to provide services to Primal Studios Ltd. Security Primal Studios Ltd. takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online. Legal Bases In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following: Contractual Necessity. This covers data used by Primal Studios Ltd. in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, chat functionality and third party social network connectivity; Legitimate Interests. This covers data used by Primal Studios Ltd. for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimization of our games and other Services; Legal Obligation. This covers data used by Primal Studios Ltd. to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data; Consent. This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by Primal Studios Ltd. and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games; (ii) the storage of data on your device by Primal Studios Ltd. and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising above). You consent to this collection when you accept this Privacy Policy and you can withdraw your consent to this processing by following the steps at How to adjust your preferences for interest based advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish Primal Studios Ltd. to collect any personal data about you at all, you should cease playing our games and stop using our Services. Retention We will retain and use your information for as long as is required in order to comply with our legal obligations. Location of storage We store your information on servers in Ireland, owned by Gamesparks. International Transfer We may transfer your information to affiliated entities or third parties to jurisdictions outside Ireland. Please note that these countries outside of Ireland may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA. Changes to this Privacy Policy We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by Primal Studios Ltd.

Contact Primal Studios Ltd.

If you have any questions about this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting Primal Studios Ltd.:
via our customer services page at www.primalstudioz.com, via email to info@primalstudioz.com; or in writing to Primal Studios Ltd. of Ara Hill Top Building, Unit A-6, Pletterijweg Oost 1, Willemstad, Curaçao. Data Protection Officers can be contacted here: ryanbootsma@primalstudioz.com or info@primalstudioz.com.