1. OVERVIEW
This Privacy Policy explains how we collect, use, disclose, and protect information when you use our mobile application (the “App”) and any related services, features, and content (together, the “Services”). It also describes your choices and rights regarding your personal information.
By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Services. CCPA specifications are detailed under Section 16.
2. WHO ARE WE AND HOW TO CONTACT US
Controller: If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we act as the data controller for personal information processed in connection with the Services.
Contact: If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact us at: games.galaxy.studio@gmail.com.
3. INFORMATION WE COLLECT
We collect information in the categories below. The specific information we collect depends on how you use the Services and the permissions you grant.
A. Information You Provide
Contact and support information: such as your name and email address, and any information you choose to include in communications with us (for example, when you request support or report an issue).
Correspondence history: we may keep records of communications to provide support, improve our services, and protect our legitimate interests (for example, to address disputes).
B. Information Collected Automatically
Device and technical data: such as device type, device identifiers, operating system and version, language settings, IP address, cookie or similar identifiers, and advertising identifiers (for example, Google Advertising ID).
Usage and interaction data: such as features used, screens viewed, timestamps, clicks, and diagnostic or performance information.
Approximate location information (where enabled): derived from IP address or device-level settings (depending on your choices and device permissions).
C. Installed Application Information (Launcher Functionality)
If you enable launcher-related features, we may collect and process information regarding applications installed on your device. This information may be used to:
enable core launcher functionality (for example, organizing or redesigning home screens and improving app management),
optimize performance and compatibility,
understand trends and user preferences to improve the Services.
Where required, we process installed app information based on your consent and the permissions you grant, and/or our legitimate interests in providing and improving launcher functionality.
D. Permission-Based Data (If You Grant Permission)
Some features may request access to device permissions. Depending on your device and settings, this can include:
Telephony-related permissions (for example, access related to call functions, call history, or contacts),
Storage permissions (access to device storage to support certain features),
Network-related permissions (information related to network settings and connectivity).
You can control permissions through your device settings. If you decline certain permissions, some features may not function.
E. Third-Party SDK and Advertising Data
We may use third-party software development kits (SDKs) and partners for advertising, analytics, and measurement. Depending on integration and your settings, these partners (and/or we) may process information such as: advertising ID, IP address, usage events and interaction data, attribution/measurement signals (such as campaign performance).
This data may support personalized ads, ad measurement, and fraud prevention.
F. Information from Third Parties
We may receive information from third parties such as analytics providers, advertising networks, or social media platforms (where applicable), including information about ad engagement, aggregated reports, or demographic estimates, subject to partner policies and your settings.
4. HOW WE USE INFORMATION (PURPOSES)
4. We use information for the following purposes:
5. LEGAL BASES FOR PROCESSING
If GDPR (or other applicable privacy laws) applies, we process personal data under one or more of the following lawful bases, depending on the context:
6. SHARING INFORMATION
We share information only as needed, including:
6.1. Vendors and Service Providers
We share information with vendors that help us operate and improve the Services (for example, hosting, customer support tools, analytics, infrastructure, and security). These providers are required to protect information and use it only to provide services to us.
6.2. Advertising and Measurement Partners
We may share device identifiers, advertising IDs, and usage data with advertising partners and measurement providers to display ads, measure performance, and support personalization (where permitted). You can typically limit ad personalization through your device settings.
6.3. Affiliates and Business Partners (If Applicable)
We may share information with affiliated entities or partners where necessary to provide joint offerings or support the Services, subject to appropriate protections.
6.4. Legal and Safety Disclosures
We may disclose information if we believe in good faith that disclosure is necessary to:
6.5. Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction, subject to appropriate protections.
7. COOKIES AND SIMILAR TECHNOLOGIES
We and our trusted partners use cookies and other technologies (e.g. web beacons, pixels, etc.) in our related Services, including when you visit our site or access our Services. Like many other vendors, we gather some information automatically, such as your usage data, by ourselves or by using third party service and store it in log files
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include improving the Services, allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and other information that is used on the webpages that you visit, making the interaction between you and our Services quicker and easier and customize and improve the Services. You can find more information about cookies at www.allaboutcookies.org. You may disable and remove some cookies through your device or browser settings. However, if you choose to disable cookies, some features of our Services may not operate properly and your online experience may be limited.
8. INTERNATIONAL DATA TRANSFERS
Your information may be processed in countries other than your country of residence, which may have different data protection laws.
Where required, we use appropriate safeguards for cross-border transfers, such as Standard Contractual Clauses or other lawful transfer mechanisms recognized by applicable law.
9. DATA RETENTION
We keep personal information only for as long as necessary for the purposes described in this Privacy Policy, including to:
Retention periods vary depending on the type of data, the reason it was collected, and legal requirements. When information is no longer needed, we delete, deidentify, or anonymize it as appropriate.
10. SECURITY
We use technical, administrative, and organizational measures designed to protect information, such as encryption (where appropriate), access controls, secure infrastructure, and periodic reviews.
However, no system is completely secure. We cannot guarantee absolute security of information.
11. Jurisdiction specific notices
12. YOUR RIGHTS AND CHOICES
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:
Right to be informed, right to know | You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy. |
|---|---|
Right to access | You have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it. |
Right to correction | You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. |
Right to be forgotten, right to deletion | You have the right to request the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. Depending on your territory, we may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, other legitimate interests such as record keeping with regards to our engagements, completing transactions, providing a service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising free speech, ensuring the right of another consumer to exercise their free speech rights, or exercising another right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. |
Right to portability | You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. |
Right to opt out under the EU, and specifically in the US the right to opt out from: (i) selling Personal Data; (ii) right to opt out from targeted advertising; and (iii) right to opt out from profiling and automated decision making | Sale of Personal Data for targeted advertising, monetary gain or profiling, or share or sale of personal information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. You can reset your advertising ID by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and selecting "Reset advertising ID". |
Right to appeal or complaint | If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK. Additional information for the appeal procedure under certain state laws, please see section “Jurisdiction-specific Notices”. |
Non-discrimination | Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users. |
You may exercise any or your right above by sending us your request to games.galaxy.studio@gmail.com.
13. LINKS TO THIRD-PARTY SERVICES
The Services may include links to third-party websites or services. This Privacy Policy does not apply to third parties, and we are not responsible for their practices. We encourage you to review their privacy policies.
14. MINORS’ PRIVACY
We offer users a range of apps. Some are primarily intended for children under the age of 16, while others are designed for users of all ages. We generally do not process children's personal data on the basis of consent. If we do, and we discover that we have collected personal data from a child under 16, we will either delete that data or promptly seek parental consent for the collection.
15. CHANGES TO THIS PRIVACY
We may update this Privacy Policy from time to time. We will post the updated version in the App or otherwise make it available. If changes are material, we may provide additional notice as required by law. Your continued use of the Services after an update means you accept the updated Privacy Policy.
16. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents, pursuant to the California Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the California Privacy Rights Act, effective January 1, 2023.
This section does not address or apply to publicly available or to Personal Information that is otherwise exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. While our processing of Personal Information varies based upon our relationship and interactions with you, the below identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories third parties to whom we disclosed Personal Information for a business or commercial purpose
Categories of personal information | Do we collect this data? | Third-Party |
|---|---|---|
Identifiers | Yes: Online Identifier; Internet Protocol address | Affiliates Advisors and agents Advertising networks Data Analytics providers Social networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
F. Internet or other similar network activity. | Yes: information on a consumer’s interaction with a website | Affiliates Advisors and agents Advertising networks Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
G. Geolocation Data | Yes: approximate location derived from IP address | Affiliates Advisors and agents Regulators, government entities, and law enforcement (if required to do so by law or court order) Others as required by law |
Sources of Personal Information. We generally collect Personal Information from the following categories of sources: directly and indirectly from you; affiliates; business partners; vendors and service providers; operations systems and platforms, and marketing and data analytics providers.
Purposes of Collection, Use, and Disclosure. As described above, we may collect, use, disclose and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
Sales and Sharing of Personal Information. CCPA defines a "sale" as disclosing or making Personal Information available to a third party in exchange for monetary or other valuable consideration. CCPA also defines “sharing” as disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising.
While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” (as such terms are defined under the CCPA) the following categories of Personal Information in the following limited circumstances:
California Consumer Rights
California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
You may have the right to opt-out of the “sale” or “sharing” of your Personal Information. You can opt out of the sale/sharing of your personal information by email us at games.galaxy.studio@gmail.com
Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see "Submitting Requests" for instructions on how to exercise your rights.
Incentives and Discrimination
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information.
Discrimination: if consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.
California’s Shine-The-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to games.galaxy.studio@gmail.com. In your request, please attest to the fact that you are a California resident. Your right to obtain information regarding any of your personal information we have shared with third parties for their own marketing use was included here solely in order to satisfy legal and regulatory notice requirements, we do not share any of your personal information with third parties for their own marketing use.
ADDITIONAL NOTICE FOR US RESIDENTS
Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures.
"Personal Data" under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)
“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data.
We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.
Categories of Personal Data & Categories of third parties with whom Personal Data is shared:
Under the paragraph “Data We Collect and Purpose of Collection and Use” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used.
Additionally, under the paragraph “Sharing Data with Third Parties” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent.
“Sale” of Personal Data:
Under US privacy laws, in principal, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment however, subject to the definition of the term “Sale” under US privacy laws, we may “sell” the following categories of Personal Data when we use cookies or other third-party advertising services:
Identifiers – online identifiers such as IP and Cookie ID;
Internet and electronic network activity information – such as your engagement with our Website and ads.
Geolocation data - derived from IP (country level).
Consumer Rights:
Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
The paragraph “Your Rights Under Privacy Protection Laws” provides additional information regarding your principal rights.
Exercising Your Privacy Rights:
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: games.galaxy.studio@gmail.com
When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.
To exercise your right to opt-out of the “sale”, you may use the cookies preference management tool on our Website to change your preferences and opt-out of cookies.
Authorized agents may initiate a request on behalf of another individual by contacting us at games.galaxy.studio@gmail.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction (including - Colorado AG at https://coag.gov/file-complaint/; Connecticut Attorney General at: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318; Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform).