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Privacy Policy

Introduction

This Offroadland / PLAYLY OÜ Inc. Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “Offroadland / PLAYLY OÜ Inc.” refers to Offroadland / PLAYLY OÜ Harju maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 2a, 11415 We may also refer to Offroadland / PLAYLY OÜ Inc. as “we” or “us”.

This Privacy Notice applies whenever you play the games that link to this Notice, or otherwise access any of our other products and social games for the web, mobile, or any other applicable platforms and/or devices (the “Service”).

By using the Service, you understand and do not object to the collection, disclosure, storage, and use of personal data as described in this Privacy Notice. If you do not want Offroadland / PLAYLY OÜ Inc. to collect, store, use, or share the personal data you provide in the ways described in this Privacy Notice, you should not play Offroadland / PLAYLY OÜ Inc.’s games or use our Service.

1. Personal Data We Collect

Offroadland / PLAYLY OÜ Inc. collects personal data to fulfill one or more of its functions and activities, as described in this Privacy Notice.

A.     Personal Data That You Share With Us

When you use our Service (whether through a social network or through Offroadland / PLAYLY OÜ Inc. directly), you may give us information directly (like when you contact Customer Support) such as:

  • your name;
  • your e-mail address;
  • other information that helps us make sure it’s you accessing your account, information necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online survey or a feedback form).

When you use our Service, you can choose to create a player profile that other Offroadland / PLAYLY OÜ Inc. players can see. In your profile, you can include information like:

  • game username(s);
  • links to your profiles on various social networks;
  • details about the games you play and your game status.

You can also provide us with personal data directly in a number of other ways, including:

  • in response to surveys or other research we conduct;
  • to participate in contests and sweepstakes;
  • via social media;
  • by participating in group communications or chats;
  • at conferences, conventions, and other events.

B.     Personal Data That We Get From Others

We may collect or receive information about you from other sources like third-party applications, such as an app store, third-party login service, and social networks on which you play our games. We use this information along with information you provide us with directly in a number of ways as described in this Privacy Notice, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

If you play Offroadland / PLAYLY OÜ Inc.’s games or access any part of our Service on connected third-party applications or connect our Service to any third-party applications, including social networks like Facebook, Offroadland / PLAYLY OÜ Inc. may receive certain information about you from the provider of the third-party application. The information we receive depends on the Offroadland / PLAYLY OÜ Inc. game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

For example, Offroadland / PLAYLY OÜ Inc. may collect and store some or all of the following information shared by the third-party application:

  • your profile name;
  • your profile picture or its URL;
  • your game-specific social network ID number (like your Facebook game-scoped ID), which may be linked to other information like your profile name and photo, and your friends’ identifiers;
  • the social network ID number and other public information of your friends, like their profile names and photos;
  • the login e-mail you provided to the third-party application;
  • your physical location (city) and that of the devices you use to access our Service;
  • your gender;
  • your birthday and/or age range;
  • information about your activities on or through the third-party application;
  • other information you have shared on the third-party application;
  • any other information that you or the provider of the third-party application share with Offroadland / PLAYLY OÜ Inc..

If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

C.     Cookies and Automated Information Collection

Like many websites, Offroadland / PLAYLY OÜ Inc., our service providers, and other parties may send cookies to your device when you access or view our website. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We use cookies for purposes such as improving the quality of our website, tailoring recommendations to interests, and making the Service easier to use. We will only use these cookies and the contained information if you agree to them via our cookie banner. You can revoke your decision at any time by clicking on “Cookie Settings” at the bottom of each page on our website.

If cookies do not contain an exact expiration date, they are stored only temporarily and are automatically deleted as soon as you close your browser or restart your device. Cookies with an expiration date will still be stored even when you close your browser or restart your device. Such cookies will not be deleted until the specified date unless you delete them manually.

Third-party advertisers on the Service may also use, place, or read cookies or other collected information from technologies such as software development kits (SDKs) on your device, and those practices are subject to their own policies. For more information on these third-party advertisers, please see the Third-Party Advertising Including Tailored Advertising and Analytics section below.

We, our service providers, and other parties may collect the following information via cookies and other technologies:

  • the type of device you are using;
  • your device’s operating system and version;
  • your mobile device’s identifiers, like your MAC address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
  • your browser type;
  • your browser language;
  • referring and exit pages and URLs;
  • platform type;
  • the number of clicks on a page or feature;
  • domain names;
  • landing pages;
  • pages viewed and the order of those pages;
  • the amount of time spent on particular pages;
  • game state and the date and time of activity on our websites or games.

In some cases, we will connect this information with your social network ID or Offroadland / PLAYLY OÜ Inc. User ID.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 (“Google”). Google Analytics uses the advertising and analytics cookies described above to analyse your use of our website on our behalf. The information generated by these cookies is transferred to a Google server and stored there. However, if you are based in the EU or a country of the European Economic Area, your IP address is shortened before the usage statistics are evaluated, so that no direct connection to your IP address can be made. For this purpose, we use the “anonymizeIp” function.

We have also concluded data processing agreements with Google. The purpose of the use of Google Analytics is to analyse the usage behavior of our websites. The information collected helps us to improve our websites and games. The legal basis is your consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. More information on Google Analytics can be found here https://support.google.com/analytics/answer/6004245

For more information on how to limit the types of cookies you allow, please see the Opting Out of Cookie Tracking section below.

D.     Information You Generate Using Our Communications Features

You may be able to take part in certain activities on our Service that let you communicate or share information with Offroadland / PLAYLY OÜ Inc. and other players. These include:

  • participating in player forums and message boards;
  • chatting with other players;
  • posting photos or drawings.

You may choose to disclose information about yourself in the course of contributing player-generated content to the Service, including in its chat rooms, blogs, message boards, player “profiles” for public view, or in similar forums through mobile services and/or through third-party sites or services, or posting public comments to other players’ profiles. You should consider any information that you disclose in any of these forums as “public”, and you should have no expectation of privacy or confidentiality.

Additionally, you should be aware that any personal data you submit, including videos and images, can be accessed, read, watched, collected, or otherwise used by other players of these forums, and could be used to send you unsolicited messages. Offroadland / PLAYLY OÜ Inc. is not responsible for the personal data you choose to make public in any of these forums.

We may use any information you share for any purpose as described in this Privacy Notice. Note that you should consider any information you post or otherwise share with other players through a Service or a third-party site or service as “public” and you should have no expectation that it be kept private. Please also see Offroadland / PLAYLY OÜ Inc.’s Terms of Service for further information and guidelines about posting content through our Service.

E.     Payment Information

Offroadland / PLAYLY OÜ Inc. may obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple, or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies.

Moreover, Offroadland / PLAYLY OÜ Inc. does not collect or store credit card numbers.

2.  How We Use Personal Data

Offroadland / PLAYLY OÜ Inc. uses personal data for a variety of business purposes as described in this Privacy Notice, including to fulfill our contractual obligations, complete transactions you request, comply with law, and for other legitimate business purposes, such as to:

  • create your game accounts and allow you to play our games;
  • operate, improve, and optimize our Service and our players’ experiences, including by measuring interest in and engagement with our Service;
  • process payment information to facilitate your in-game purchases;
  • identify and suggest connections with other Offroadland / PLAYLY OÜ Inc. players and personalize our Service to you;
  • enable players to communicate with each other;
  • provide technical support and respond to player inquiries;
  • authenticate and/or verify individual identities;
  • protect the safety and well-being of our players;
  • protect Offroadland / PLAYLY OÜ Inc.’s rights and property in connection with our Service;
  • address technical issues and maintain and/or enhance network and information security;
  • conduct audits, ensure internal quality control, and take safety precautions;
  • prevent and/or prosecute fraud or potentially illegal activities and enforce our Terms of Service;
  • manage and deliver contextual and behavioral advertising;
  • notify players of in-game updates, new products, content, or promotional offers;
  • administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • comply with our legal obligations, resolve any disputes we may have with you or other players, collect any money owed to us, and to enforce our agreements;
  • conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data is not personal data and we may use and share such data for any legally permissible purposes.

Your interactions with our Service may be tracked across platforms and/or devices.

In addition to the above, if you have provided your e-mail address to Offroadland / PLAYLY OÜ Inc., we may use it to communicate with you in a number of ways, including to respond to customer support inquiries; keep you and others informed of your in-game activity, comments from friends, in-game status and promotions; and tell you about gift and neighbor requests. We may also send promotional messages (“Promotional Communications”) directly or in partnership with other parties. For more information on how you can opt out of Promotional Communications, please see the Your Rights section below.

We may use technologies considered automated decision-making or profiling, but we will not do so in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.

We may also use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.

3. How We Share Personal Data

We may share personal data about you between and among Offroadland / PLAYLY OÜ Inc.’s affiliated companies including our ultimate parent company, Playtika Holding Corp., and its subsidiaries.

Additionally, we may disclose or publish aggregated and analytical information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 25 and 30 who live Chicago) and other non-personal data about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

In addition, we may share your information (which may include personal data) with third parties (in other words, parties other than Offroadland / PLAYLY OÜ Inc.) or allow third parties to collect this information from our Service as described in this Privacy Notice.

A. Service Providers

Offroadland / PLAYLY OÜ Inc. uses its affiliated companies (Playtika Holding Corp. and its subsidiaries) and other unaffiliated companies (“Service Providers”) to support the Service, like analyzing data, optimizing gameplay and enhancing player experience, e-mail delivery, hosting services, managing and delivering contextual and tailored advertisements.

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B.     Friends and Other Offroadland / PLAYLY OÜ Inc. Players

In most Offroadland / PLAYLY OÜ Inc. games, if you play or register through a social network (for example, Facebook Connect), your social network friends may see your profile name, profile photo, and descriptions of your game activity. If you use our Service in response to an invitation from another player, that player may see certain information about you and your in-game activities, including when you join and the level(s) you reach within the game.

Correspondingly, in many Offroadland / PLAYLY OÜ Inc. games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any Offroadland / PLAYLY OÜ Inc. games you have played), communicate with you within our Service, and view your game profile, which may include your social network name or a “game name” and your chosen profile picture.

Other players may also be able to send you game requests or even friend requests through the related social networks or Offroadland / PLAYLY OÜ Inc.’s communication channels.

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C.     Third-Party Advertising Including Tailored Advertising and Analytics

We may have advertising on our Service so we can continue to offer our Service for free. We may also advertise outside of our Services in third-party apps or other services.

When advertisers or ad networks place ads in and outside of our Service, they may collect or we may share the following types of information from within our Service:

  • performance data (like the number of clicks on an advertisement);
  • aggregated and/or de-identified information about you and other players that is not intended to specifically identify you (like players between the ages of 21 and 25 who live in San Francisco);
  • certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and device identifiers);
  • your social network ID;
  • other contextual data about your gameplay (for example, your level and session length).

The information collected may be used to:

  • measure how effective ads are;
  • offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising);
  • undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).

Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time. We recommend that you also review our advertising partners’ privacy policies for more information. A list of our advertising partners and their privacy policies can be found here.

Please note, after clicking on a third-party advertisement in our games, you may no longer be on a service hosted by Offroadland / PLAYLY OÜ Inc. or the social network through which you are playing Offroadland / PLAYLY OÜ Inc.’s games. Receiving personalized in-application advertisements from third parties in our games is subject to your consent. You can always revoke your consent. For more information on how to revoke your consent, please see the Opting Out of Third-Party Tailored Advertising section below.

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D.     Sale or Merger

In the event that Offroadland / PLAYLY OÜ Inc. undertakes efforts to engage in a business transition (like a merger, acquisition by another company, or sale of all or part its assets, like selling a game), we may disclose or transfer relevant information we have, including personal data, to the successor organization in the transition. We will make reasonable efforts as described in this Privacy Notice to let you and other players know of the business transition before transferring personal data.

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E. Legal Compliance

We may share personal data in the following circumstances:

  • when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant, or subpoena);
  • to satisfy any laws or regulations;
  • where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
  • when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, us, another person, or the public generally;
  • to protect the rights or property of Offroadland / PLAYLY OÜ Inc. and other applicable third parties, including to enforce our Terms of Service.

4.  Your Rights

Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Offroadland / PLAYLY OÜ Inc. processes about you, for example:

  • for information;
  • for access;
  • for correction (or rectification) of personal data that you think is incorrect;
  • for erasure (or deletion);
  • for an electronic copy (or portability);
  • to object to certain processing, including to opt out of targeted advertising.

Offroadland / PLAYLY OÜ Inc. allows all players to submit the requests by sending an e-mail to privacy@Offroadland / PLAYLY OÜ Inc..net or through the support section within the game you play.

A.     Manage Information We Get From Third Parties

To manage the information Offroadland / PLAYLY OÜ Inc. receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon etc. you will need to follow the instructions for each such third-party application for updating your information and changing your privacy settings.

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B.     Opting Out of Promotional Emails From Offroadland / PLAYLY OÜ Inc.

If you want to stop receiving promotional emails from Offroadland / PLAYLY OÜ Inc., you can click on the “Unsubscribe” link in any promotional e-mail from Offroadland / PLAYLY OÜ Inc.. Please note that it may take us some time for your opt-out to become effective.

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C.     Opting Out of Facebook Messages

If you want to stop receiving messages through our game pages on Facebook, you may click on the “Settings” icon at the top of such message, and by clicking ”Manage Messages” you may turn off all messages from such game.

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D.     Opting Out of Push Notifications

When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings” page.

Additionally, in most of our games, you may find an option under Settings to request that we stop sending you notifications.

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E.     Opting Out of Third-Party Tailored Advertising

In some games that serve third-party ads we provide you with a toggle button enabling you to disable third-party tailored ads.

For more information about tailored advertising (and your choices to prevent third parties from delivering tailored web and mobile web advertising) you can visit www.aboutads.info. To opt out, for businesses that participate in the Digital Advertising Alliance, you can exercise that option at www.networkadvertising.org/choices and www.aboutads.info/choices.

If you live in the EU, you can get information and exercise your choices at www.youronlinechoices.com.

These opt-out tools are provided by third parties, not Offroadland / PLAYLY OÜ Inc.. Offroadland / PLAYLY OÜ Inc. does not control, operate, or endorse these tools or the choices that advertisers and others provide through these tools. They are listed here only as a convenience for players.

In addition, if you do not want to receive third-party tailored in-application advertisements, you may opt out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Offroadland / PLAYLY OÜ Inc.. Offroadland / PLAYLY OÜ Inc. does not control, operate, or endorse these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive advertisements from third parties within Offroadland / PLAYLY OÜ Inc.’s games even if you opt out of tailored advertising, but they will not be based on your activity across unrelated websites or apps.

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F.     Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

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G.     Do Not Track

Note that Offroadland / PLAYLY OÜ Inc. does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

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5.  Children’s Privacy

You may not use the Services if you are under 18 years of age, in which case you must not create an account, access, use, or download such games and/or submit any personal data through the Service or Offroadland / PLAYLY OÜ Inc..

Offroadland / PLAYLY OÜ Inc. is committed to complying with laws protecting children. If you believe that your child has submitted personal data to Offroadland / PLAYLY OÜ Inc. without your consent, please contact us at privacy@Offroadland / PLAYLY OÜ Inc..net. Offroadland / PLAYLY OÜ Inc. will take reasonable steps to delete such information as soon as possible.

6. International Transfers, Retention, Security, Links, Updates, and How to Contact Us

A. International Transfers

When you use our Service, your personal data may be sent, accessed, used, and/or stored outside of the country or region where you live, including for example, to the United States and Israel. We may transfer personal data to our parent company and affiliated companies, vendors, business partners, and others as described in this Privacy Notice, and by using the Service you consent to such transfers.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise ensure that such transfers meet applicable local legal requirements.

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B. Retention  

We will retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

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C. Security

We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.

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D. Links to Other Sites/Apps

Our Service may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps is subject to the privacy policy on such website or app and Offroadland / PLAYLY OÜ Inc. is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.

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E. Updates

Offroadland / PLAYLY OÜ Inc. reserves the right to amend the Privacy Notice from time to time, and Offroadland / PLAYLY OÜ Inc. encourages you to consult the Privacy Notice regularly for changes.

If we make material changes to our Privacy Notice, we will tell you and other players by placing a notice on Offroadland / PLAYLY OÜ Inc..com or its equivalent in-game, or other appropriate channels prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Offroadland / PLAYLY OÜ Inc. websites. 

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F.  How to Contact Us

If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact Offroadland / PLAYLY OÜ Inc.’s DPO at privacy@playly.co

If you want to exercise your rights you can submit a ticket via the applicable support channel of the game or by sending an e-mail.

Additionally, if you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live.