Policy

Privacy Policy

Offcenter Media is dedicated to protecting the privacy rights of our Users (“User,” “your,” or “you”) whose information is collected, processed, and stored while using our Platforms. 

This Privacy Policy (the “Privacy Policy”) describes how we collect, store, use, disclose, safeguard, and manage your data, including data that you provide or we collect when you use our gaming platforms (individually the “Platform”

and collectively the “Platforms”) through our mobile applications (“App” when it is a single gaming application and “Apps” for multiple gaming applications) (collectively, the “Services”). The capitalized terms have the same meaning as ascribed in our Terms of Service, as applicable, unless otherwise noted here.

 

The meaning of certain terms used in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), unless otherwise stated. When we refer to the GDPR we are referring to the General Data Protection Regulation of the UK as well, unless we otherwise

specify. All definitions set out in Art. 4 of the GDPR apply to this Privacy Policy.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE TREAT IT. PLEASE DO NOT USE OUR SERVICES IF YOU DISAGREE WITH THIS PRIVACY POLICY. WE RESERVE THE RIGHT NOT TO PROVIDE OUR SERVICES TO YOU IF YOU DO NOT AGREE WITH THE PROCESSING OF YOUR PERSONAL DATA AS SET OUT IN THIS PRIVACY POLICY.

 

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND

US AN EMAIL AT newconnectionapp.app@gmail.com. IF APPLICABLE, YOU SHALL HAVE THE OPTION AT ANY TIME TO WITHDRAW YOUR CONSENT TO COLLECT, STORE, AND/OR PROCESS YOUR PERSONAL INFORMATION.SUCH WITHDRAWAL OF CONSENT SHOULD BE SENT TO US THROUGH OUR APP OR VIA EMAIL TO newconnectionapp.app@gmail.com.

 

This Privacy Policy may be updated from time to time, therefore it is advisable to review it frequently. We will notify you of material changes to this Privacy Policy via a notice on our home page. Your continued use of our Platform or Services means that you

accept any changes made. If you disagree with the processing of data described in this Privacy Policy, you may not be able to continue to use the Platforms or Services provided.

WHO WE ARE

We are the controller of your personal data when processing it: Offcenter Media, Kenya, Nairobi - 00101-102841

 

If you want to contact us in regards to any data protection request, we encourage you to use the “Contact us” option available in the game(s). Alternatively, you can reach out to our Data Protection Officer at any time by sending an email to newconnectionapp.app@gmail.com

TERRITORIAL RESTRICTION

If you are a resident of the United States (“US”), the laws of the State of Delaware, United States shall apply. If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform. You must comply with our Terms of Use and Terms of Service, as applicable.

Some terms we use in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), a data protection law of the European Union. Unless we specify otherwise, when we refer to the GDPR we are referring to the UK General Data Protection Regulation as well since both laws are very similar.Art. 4 of the GDPR gives detailed definitions of the terms we apply in this Privacy Policy.

WHAT DATA DO WE COLLECT?

The types of data we collect depend on the Services you use, and the applicable laws.

Data provided by you

§ Player name (real or alias)

§ Contact information (name, email address)

§ Profile information (such as profile photo)

§ Your in-game messages (e.g., your support tickets and chat logs)

§ Other information you choose to share (e.g., data to identify your lost account)

Data collected automatically

§ Your game account details and game progress

§ Your Mobile device identifiers and IP address

§ Your device data (e.g., the device name, operating system, and language)

§ Data we collect using cookies and similar technologies (see more below)

§ Approximate location (as suggested by your IP address)

§ Your gameplay data and/or interactions with other players inside the Service

§ Application performance and debugging information

Data collected from our partners

We also use third-party partners, such as social networking sites, advertising networks like Appodeal, and data analytics providers like Adjust.

§ Data made available by you via your privacy settings in third-party services like Facebook, Google and Apple

§ Demographic data (e.g.,to determine the approximate location of your IP address)

§ Data to fight fraud related to refunds or advertising

§ Data from the platforms that the games run on (such as purchase data for verifying payments)

§ Additional information (e.g., advertising and analytics data) to improve the relevance of our ads and services we provide. In addition to Google Ads, Appodeal ads are also included in the app. For more information, review the Appodeal Privacy Policy.

WHY DO WE COLLECT YOUR DATA

You personal data maybe processed for the following purposes:

Offer our Services

§ To create accounts and make our Service available to you

§ Verify and confirm payments

§ Process your requests

A contract between you and us or our Affiliate can be used to offer you our Services. The basis for processing your personal data is our legitimate interest to offer you our Services (Art. 6 (1)(b) and/or (f) of the GDPR).

Without this data we would not be able to enter into, or fulfill our obligations under, a contract with you.

Offering Additional Services

§ Maintain and update player profiles

§ Enable social features in our Services

§ Enable personalization and customization in our Services

§ Provide player support

§ Provide offers within our Services

§ Communicate with you regarding service updates, security alerts, and support messages

§ Enable communication within the player community

Offering Additional Services is based on the legitimate interest of ours and our Affiliate to offer you interesting features and a good user experience. Due to this, the legal basis for processing your data is Art. 6(1)(f) of the GDPR.

Show personalized advertisements

§ Make advertisements more relevant to you

§ Serve, measure and improve the effectiveness of advertising

Processing your personal data to show personalized advertisements, and measure and improve their effectiveness, is based on your consent. The legal basis for processing this data is Art. 6(1)(a) of the GDPR. For information on how to opt-out of personalized advertisements, see section 'Your Rights and Options' below.

Provide a safe, fair experience and take legal matters into account

We strive to maintain the highest standard of safety and fairness in all our features. To maintain these standards and fight fraud, we use the data to

§ Analyze and monitor the social features

§ Take action against any fraudulent activity

§ Verify your identity, if needed, to comply with your data subject requests

§ Maintain proof of our compliance with applicable laws (e.g., the GDPR)

§ Sufficiently defend ourselves against any legal claims

Ensuring that our Services are safe and fair is a legitimate interest of ours and our Affiliate, enabling us to offer interesting features and a good user experience. This includes complying with

applicable laws and being able to sufficiently defend ourselves and our Affiliate against legal

claims, given this can have legally binding effects on us as a company. The legal basis for processing your data is Art. 6(1)(f) of the GDPR. Additionally, the processing of your personal data for

verification purposes, compliance or legal defense is based on Art. 6(1)(c) of the GDPR, since we can be obliged by law to process the data.

WHO CAN SEE YOUR DATA?

Apart from Offcenter Media, some of your data may be available to others in the following situations:

OTHER PLAYERS

Through our Social features, other players may be able to view your profile, in-game

achievements and any other details that you made public. If you share personal information, post an image or video, or provide other content in public forums (such as on message boards, leaderboards, in chat rooms, comment fields, or on profile pages) other people can view, collect and use that information. If your user name or ID contains your real name, then you acknowledge that your name will be made publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may then be able to identify you, use the information to send you messages, or copy any of the images, video or content you have shared. You are

strongly encouraged not to share your personal information in public forums or in your username or ID. You are responsible for any information or content you publicly post using our Services.

OTHER COMPANIES AND AUTHORITIES

In case of any fraud or illegal activity, your data may be shared with other organizations and/or public authorities in response to lawful requests.

Data disclosure will be conducted in accordance with the law and protection of the rights and safety of our players shall be ensured.

YOUR RIGHTS AND OPTIONS

Push Notifications

You may opt-out from receiving our push-notifications by changing the settings on your mobile device.

Opt-out of targeted advertising

You can opt-out of interest-based advertising by following the privacy settings of your Android, iOS or Amazon device and selecting "Limit Ad Tracking." You can also opt-out by turning off

“personalized ads” on Apple iOS, "Opt-out of Interest Based Ads" on Android or by disabling Interest based Ads on Amazon.

You can choose to agree or disagree with the sharing of your personal data to receive targeted ads:

§ iOS: Choose from the consent pop-up at the start of the game (if you haven’t already generally disabled tracking in your system settings).

§ Android: Opt out of ad tracking by going to Settings > Ads > Opt out of Ads Personalization

§ Fire OS: Opt out of ad tracking by going to Settings > Security & Privacy > Advertising ID > Interest-Based Ads

If you would like more information about our advertising practices and your ability to prevent these companies from receiving your information, you can visit Apple/Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, other aspects of our mobile games may not work correctly.

Your Rights

Under the GDPR you have certain rights regarding the processing of your personal data. Under the GDPR you have the following rights:

§ Right of information: You have the right to be provided information regarding the processing of your personal data, in accordance with Art. 13 and 14 of the GDPR.

§ Right of access: You have the right to obtain confirmation as to whether we are processing your personal data, and, if this should be the case, access to that personal data in accordance with Art. 15 of the GDPR.

§ Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data regarding you in accordance with Art. 16 of the GDPR.

§ Right to erasure (“right to be forgotten”): You have the right to obtain erasure of your personal data in accordance with Art. 17 of the GDPR.

§ Right to restriction: Under certain circumstances you have the right to obtain a restriction of the processing of your personal data, in accordance with Art. 18 of the GDPR.

§ Right to data portability: Under certain circumstances you have the right to receive the personal data you provided us, in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller, in accordance with Art. 20 of the GDPR.

§ Right to object: Under certain circumstances you have the right to object to the processing of your personal data, in accordance with Art. 21of the UK GDPR. This includes but is not limited to the right to object in cases where we process your personal data on the legal basis of Art. 6(1)(f) of the GDPR.

§ Right to lodge a complaint: You have the right to lodge a complaint with a supervisory

authority, in particular in the Member State of the EU of your habitual residence, place of work or the place of the alleged infringement, if you feel the processing of your personal data violates the GDPR, as set out in Art. 77 of the GDPR. If you are in the EU, you can contact the Swedish Data Protection Authority(IMY) here.

If you are in the UK, you can contact the Information Commissioner's Office(ICO) here.

§ Right to withdraw consent: If the processing of your personal data is based on your consent, as set out in Art. 6(1)(a) of the GDPR or Art. 9(2)(a) of the GDPR, you may withdraw your consent at any time in accordance with Art. 7(3) of the GDPR. Such
withdrawal does not affect the lawfulness of the processing prior to its withdrawal.

§ Right not to be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, as set out in Art. 22(1) of the GDPR.

If you wish to exercise any of the rights mentioned below :

§ Right of Access/right of disclosure/right to know

§ Right to erasure/right to deletion (the right to be forgotten)

§ Right to withdraw consent

Please contact our support team through the in-game Help Center. For all your data-related requests, please follow the following steps: Contact us / Help Center > Other issue > My Data. Apart from the self-service mechanisms, the Offcenter Media Group offers a channel to contact the Data Protection Team and exercise the rest of your data subject rights via email (newconnectionapp.app@gmail.com).

If you wish to exercise any of the rights mentioned above, please contact our support team through the in-game Help Center. For all your data related request, please follow the steps: Contact us / Help Center > Other issue > My Data

We may take additional steps to verify your identity before fulfilling your request.

COOKIES AND SIMILAR TECHNOLOGIES

Our services, and those of our partners, use cookies and similar technologies to enhance our product. Please note that our partners may operate under their own privacy policies.

We collect and store your information using cookies and similar tracking technologies in order to

§ Detect and prevent fraud;

§ Enable users to sync devices seamlessly

§ Carry out analytics and personalization

§ Limit the number of times players are shown the same advertisement across all known or inferred devices

§ Show personalized advertising on each device

Google, as a third-party vendor, uses Cookies to show advertisements to Users on our Platforms,

Website, and Apps. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions on our Platforms, Website, and Apps. We currently use Google Analytics to collect and process usage data from our career website, Platforms and Apps. To learn more about Google Analytics and how to opt-out, please visit :

https://policies.google.com/privacy/google-partners.

We have implemented advertising features in our Apps and on our Platforms, including Google’s

“DoubleClick” platform integration. We use these Cookies and similar technologies to compile data concerning User interactions with ad impressions and other ad service functions.

HOW DO WE PROTECT YOUR DATA

Security Safeguards

Our priority is to provide a safe and transparent gaming environment for our players.In order to maintain this, we ensure that our security system is constantly evolving to meet the highest standard

possible. We take all necessary technical and organizational measures to protect your data from unauthorized access or misuse.

Data retention

We'll keep your information for as long as necessary to provide you with the Services, fulfill our legal obligations, and/or exercise, defend or establish our rights.

If you wish to delete your account then please follow Contact us / Help Center > Other issue > My Data > Delete My Data. We will maintain your account for the length of time for which we reasonably expect you to re-engage with our Services. After such a period, we will delete your personal information, including your personal identifiable information, and you may no longer be able to access your account.

COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

Protecting children's privacy online is extremely important to Offcenter Media. The Word Run App is intended for general audience and does not knowingly collect any Personal Information as the term is defined under the Children’s Online Privacy Protection Act (“COPPA”). The COPPA is a federal legislation that applies to entities that collect and store Personal Information from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, Apps, and Platform are not meant for use by children under the age of 13.

When Users identify themselves as children (i.e. under the age of 13 or under the minimum age in the relevant territory), consistent with applicable law we will: (1) not provide a path for them to input Personal Information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services (such as chat functionality); and/or (4) obtain consent from parents for the collection, use, and

sharing of their children's Personal Information.

 

Through our Apps your child will be able to receive local in-app notifications which do not collect any Personal Information.

 

Please note that, if you grant consent for your child to use Offcenter Media's Platform on our Website or on the Apps, this may include such general audience communication services as email, instant messaging, and online groups, and your child will be able to communicate with, and disclose Personal Information to, other Users of all ages.

 

If you are a parent and wish to revoke your previously provided consent, review information

collected from your child or have that information deleted, please contact the Offcenter Media support by writing an email to newconnectionapp.app@gmail.com. 

 

Information collected is secured in a manner consistent with this Privacy Policy. If we make material changes to how we use, collect, or share your child's Personal Information, we will notify parents by email, or by providing a notification on the Platform, in order to obtain verifiable parental consent for the new uses of your child's Personal Information. 

 

We encourage you to talk with your children about communicating with strangers and disclosing Personal Information online. Under no circumstances do we condition a child's participation in an activity—like contests—on the child's disclosure of more Personal Information than is reasonably necessary to participate in the activity. On certain Apps, we may not permit children to participate at all, regardless of whether they have parental consent. If you would like to know more about our practices, and specifically our practices in relation to COPPA compliance, please email us at newconnectionapp.app@gmail.com.

 

THESE TERMS ARE IN ADDITION TO THE TERMS AND CONDITIONS IN OUR

GENERIC TERMS OF USE. PLEASE READ OUR PRIVACY POLICY AND TERMS OF USE. BY REGISTERING ON OUR WEBSITE TO PLAY OUR GAMES AND/OR BY PLAYING OUR GAMES, YOU AGREE TO THE TERMS AND CONDITIONS IN OUR

PRIVACY POLICY, TERMS OF USE, AND THE APPLICABLE SPECIFIC USER TERMS OF USE. READ ALL TERMS CAREFULLY. IF YOU DO NOT WANT TO BE BOUND BY OUR TERMS AND CONDITIONS, DO NOT REGISTER OR PLAY OUR GAMES. YOU

ARE ALSO BOUND BY THE TERMS AND CONDITIONS AND PRIVACY POLICIES OF OUR PARTNERS, WHOSE GAMES ARE FOUND ON OR ASSOCIATED WITH OUR WEB SITE.

 

PLEASE NOTE: IF YOU USE AND NAVIGATE THROUGH OUR PLATFORMS OR OUR WEBSITE AND/OR DOWNLOAD OR USE OUR APPS, OR ACCESS OUR PLATFORMS OR USE OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE TERMS AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO

NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE, PLEASE DO NOT

NAVIGATE, ACCESS, DOWNLOAD, OR USE OUR PLATFORMS, WEBSITE, AND/OR THE APPS.