Privacy Policy
action simulation (collectively, “Company,” “we,” “our,” or “us”) respects your right to privacy under global privacy laws and in particular the General Data Protection Regulation («GDPR«). This Privacy Policy explains who we are, how we collect, share, use and disclose personal information about you, and how you can exercise your privacy rights or contact us about any questions you may have.
Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable law.
For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact us via e-mail at actionsimulation42@gmail.com
FOR US CITIZENS ONLY: BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION.
The following links will take you directly to the corresponding sections of this Privacy Policy:
Contents
Privacy Policy
1. Who We Are And Contact Options
2. What Our Privacy Policy Covers
3. Personal Data We Collect From You
3.1 Personal Data That You Provide Voluntarily
3.2 Personal data We Collect Automatically And Device Information
3.2.1 Cookies, Similar Technology And Device Information
3.2.2 Analytics
3.3 What Personal Data Do We Collect When You Install And Play Our Apps And Why?
3.3.1 Download Our Apps And Create An Account
3.3.2 Use of Our Apps
3.3.3 InApp Purchase
3.3.4 Connecting Our App With Third Party Platforms
3.3.5 View Personalized Advertisements Or Content Within Our Apps Or Those Of Our Partners
3.4 Personal Data We Do Not Collect
4. How We Use Your Personal data
5. How We Disclose Or Share Your Personal data
5.3 Links To Other Sites And Social Media Services
6. Our Legal Basis For Processing Your Personal Data
7. How Do We Keep Your Personal Data Secure?
8. Your Rights
9. Managing Additional Data Use
9.1 Managing Cookies
9.2 DNT-Signals
10. International Data Transfers
11. Data Retention
12. Updates To This Privacy Policy
1. CALIFORNIA PRIVACY RIGHTS 15
1.1 Information We Collect; How We Collect It; How We Use It
1.2 Disclosure of Personal Information
1.3 Rights to Your Information
1.4 California “Shine the Light”
2.1 Rights to Your Information
2.2 How to Exercise Your Rights; Verifying Your Identity
2.3 Response Time; Your Right to Appeal
2.4 Sensitive Data
Controller
We are the data controller for processing under this Privacy Policy and in relation to the Services:
Action simulation
69 Oxford way united kingdom .
If you have any questions or concerns about this Privacy Policy our use of your personal data, please email us at actionsimulation42@gmail.com.
This Privacy Policy applies to the personal data that we obtain in various online contexts including when you:
- Access or use our Services; or
- Communicate with us over email or text message, or otherwise via the Services.
We may provide different or additional privacy notices in connection with certain activities, programs, and offerings, for example, if you submit a job application through the Services. Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal data.
Unless explicitly defined otherwise, we use the term “personal information” or “personal data” – at times referred to herein as “Data“ – to refer to information as defined under the General Data Protection Regulation or such other applicable privacy laws.
The personal data that we collect from or about you when you visit our Services broadly falls into the following categories and types of personal data:
3.1 Personal Data That You Provide Voluntarily
We collect personal data that you provide voluntarily through our Services, for example when sending emails to us via the provided email address. The personal data we collect about you include some or all of the following:
- First and last name;
- Contact information, including email address and telephone number(s);
- Information pertinent to fulfilling our Services to you; and
- Any other personal data that you voluntarily choose to provide to us.
If you send support requests or other communication to our Support team by email, via integrated chat within our Apps or via messages within social media platforms, we collect and process the Data from your request and Data from your account, such as your Player ID, game data, device data and technical data. We collect this Data to appropriately respond to your requests.
If we ask you to provide any other personal data not described above, the personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal data.
3.2 Personal data We Collect Automatically And Device Information
When you visit our Services or interact with advertisements on our Service, we or third parties we work with collect certain information using technologies such as Cookies and other tracking technologies described below.
3.2.1 Cookies, Similar Technology And Device Information
Cookies are pieces of information that may be placed on your device by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. In our App properties we use a technology similar to that of Cookies, the so-called Mobile Advertising Identifier (also «MAID»). MAIDs are provided by your mobile device, and access to them may be subject to policies of the provider of your mobile device’s operating system. You can also manage the way your mobile device makes use of MAIDs centrally on your device. We use the term «Cookies» broadly in this Privacy Policy and include MAIDs and similar identifier technology (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices). personal data described herein may be collected in association with Cookies or on its own.
Such data includes the address of the websites you visited before and after you visited our Services, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Services you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may also use Cookies to customize your visit to the Services and for other purposes to make your visit more convenient or to enable us to enhance the Services. For more information about the Cookies we store and retrieve, please visit our Privacy Preference Center by clicking on the cookie icon in the lower left corner of our Website. [For additional information about our use of Cookies on the Services.
Use of Cookies may require your consent under either the national implementations of the e-Privacy Directive or the GPDR, in such cases we will seek your consent prior to any processing.
We work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Services. One such provider is Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics uses Cookies to help analyze how users use the Website. The information generated by these Cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Services, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
About the Privacy policy in Google Play User Data policy
Applicable only and in addition to the provisions outlined above for residents of the United States. CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020, provides you with specific rights regarding your personal information. This section describes the rights that California consumers have and explains how to exercise those rights. For the purposes of this section, personal information does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA. To be clear, these rights are granted only to the extent that you are a California consumer and we are acting as a “business” under the CCPA with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA.
1.1 Information We Collect; How We Collect It; How We Use It
General information regarding our collection, use, and disclosure of personal information is set forth in the Privacy Policy above. To help consumers make informed privacy decisions, the CCPA defines personal information by discrete categories. Information about our data practices pertaining to these categories of personal information can be found below (some types of personal information may apply to multiple categories).
In the past 12 months, we have collected the categories of personal information described in the “Personal Information We Collect From You” section above for the business or commercial purpose(s) indicated above. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.
3.2 Disclosure of Personal Information
Company may disclose your personal information to a third party for a business purpose, or sell or share your personal information, subject to your right to opt out (see Personal Information Sales Opt-Out and Opt-In Rights, below). The information above under Personal Information We Collect From You; How We Collect Your Personal Information; How We Use Your Personal Information describes the entities with which we may disclose your personal information.
3.3 Rights to Your Information
(a) Right to Know
As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information . Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:
- The categories of personal information we collected about you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (see Right to Data Portability below).
(b) Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we maybe retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
(c) Right to Data Portability
You have the right to request a copy of personal information we have collected and maintained about you . The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.
(d) Right to Correct
You have the right to request the correction of any personal information we maintain about you.
(e) Right to Opt Out of Selling or Sharing Your Personal Information
You have the right to opt out of the sale or sharing of your personal information, along with the right to opt in to the sale of such information. We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the «right to opt-in») from either the consumer who is less than 16 (but greater than 13) years of age, or the parent or guardian of a consumer less than 13 years of age. To our knowledge, we do not sell or share the personal information of minors under 16 years of age.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page: «Do Not Sell or Share My Personal Information / Opt-out.» Alternatively, you may submit an opt-out request by visiting: the Privacy Centre in our App. We will also treat Global Privacy Control browser signals as valid opt-out requests. In order to facilitate your request, we may require you to provide us with the Mobile Advertising ID for your device.
(f) Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights, including but not limited to, by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
(g) Exercising Your Rights
To exercise the rights described above, please contact us by using the following methods:
- Emailing us at actionsimulation42@gmail.com
- Visiting our Opt-out page in the privacy center linked within the user settings menu in our Apps
After submitting a rights request, excluding opt-out requests, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.
Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf.
We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.
3.4 California “Shine the Light”
In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at actionsimulation42@gmail.com. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at actionsimulation42@gmail.com
OTHER STATE PRIVACY RIGHTS
Residents of Virginia, Connecticut, Utah and other states with applicable privacy laws (“States”) have certain rights with respect to their personal information. These rights are established through the Virginia Consumer Data Protection Act (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and other applicable Lws (collectively, the “State Laws”). The rights available to residents of these States are explained below.
The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the details of our Privacy Policy above.
4.1 Rights to Your Information
In addition to the rights set forth in our Privacy Policy, the State Laws provide you with the following rights, except where indicated otherwise below:
(a) Right to know.
You have the right to know whether we process your personal information and to access such personal information.
(b) Right to data portability.
You have the right to obtain a copy of your personal information that you previously provided to us or that we have obtained in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. Subject to certain exceptions, you may request such personal information free of charge as permitted under State Laws.
(c) Right to delete.
Certain users have the right to delete personal information that you have provided to us or that we have obtained about you; requests from Utah residents cover only personal information that you have provided directly to us. Please note that we may deny requests to delete if the requested deletion falls under an exception as set forth the applicable State Laws. Additionally, if you request deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the applicable State Laws.
(d) Right to opt out.
Certain users have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling that produces legal or similarly significant effects concerning you. Utah residents may opt out of the processing for the purposes described in (i) and (ii) of this paragraph.
As of the latest date of the Privacy Policy:
- We do process personal information for the purposes of targeted advertising;
- We do sell your personal information in exchange for monetary consideration; and
- We do not engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you.
If you wish to opt out of the processing of your personal information for any of the above purposes, and your state of residence provides for such opt-out right, please view our privacy center in the user profile settings menu of our Apps.
(e) Right to correct.
Certain users have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it.
(f) Right to nondiscrimination.
You have the right not to receive discriminatory treatment by us for the exercise of your Virginia privacy rights. Unless permitted by applicable State Law, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
4.2 How to Exercise Your Rights; Verifying Your Identity
To exercise any of your State Law privacy rights, or if you have any questions about your privacy rights, you may contact us by:
- Emailing us at actionsimulation42@gmail.com
- Visiting our Privacy Center in the user profile settings menu of our Apps.
After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.
Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.
4.3 Response Time; Your Right to Appeal
We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the certain State Laws allow an extension of our time to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.
If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so. and, for Virginia and Connecticut residents, provide instructions for how to appeal the decision. Residents of those will have the right to appeal within a reasonable period of time after you have received our decision. Within the time provided by your State 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 we deny your appeal, we will provide you with a method for contacting the your state’s regulatory authority to submit a complaint.
Certain State Laws require companies to obtain a consumer’s affirmative consent before processing “sensitive data,” which may include, depending on the specific statute, information that reveals:
- Geolocation data
- Racial or ethnic origin
- Religious beliefs
- A mental or physical health condition or diagnosis
- Sex life or sexual orientation
- Citizenship or citizenship status
- Genetic data
- Biometric data
- Personal data regarding a known child
- Contents of email
- Social Security or other ID
We will not process any such sensitive data of certain state residents without first obtaining your consent if required by State Laws.