PRIVACY
POLICY
COMPLIANCE WITH DATA
PROTECTION REGULATIONS
WE ARE COMMITTED TO
COMPLYING WITH ALL APPLICABLE PRIVACY LAWS WORLDWIDE, WITH PARTICULAR ADHERENCE
TO THE FOLLOWING REGULATIONS: ARGENTINA: THE PERSONAL DATA PROTECTION ACT OF ARGENTINA,
AUSTRALIA: THE PRIVACY ACT 1988 OF AUSTRALIA, BRAZIL: THE LEI
GERAL DE PROTEÇÃO DE DADOS (LGPD) OF BRAZIL, CALIFORNIA: THE CALIFORNIA
CONSUMER PRIVACY ACT (CCPA), CANADA: THE PERSONAL INFORMATION PROTECTION
AND ELECTRONIC DOCUMENTS ACT (PIPEDA) OF CANADA, EUROPEAN UNION: THE
GENERAL DATA PROTECTION REGULATION (GDPR), INDIA: THE INDIAN INFORMATION
TECHNOLOGY ACT, 2000 AND IT RULES, 2011, ISRAEL: THE PROTECTION OF
PRIVACY LAW OF ISRAEL. NEW ZEALAND: THE PRIVACY ACT 2020 OF NEW ZEALAND,
PEOPLE’S REPUBLIC OF CHINA : THE PERSONAL INFORMATION PROTECTION LAW
(PIPL) OF THE PEOPLE’S REPUBLIC OF CHINA, WHICH ESTABLISHES COMPREHENSIVE
REQUIREMENTS FOR THE COLLECTION, PROCESSING, AND STORAGE OF PERSONAL
INFORMATION; THE CYBERSECURITY LAW OF THE PEOPLE’S REPUBLIC OF CHINA, WHICH
MANDATES STRINGENT DATA SECURITY MEASURES, INCLUDING DATA LOCALIZATION AND
PROTECTION AGAINST CYBER THREATS; THE DATA SECURITY LAW OF THE PEOPLE’S
REPUBLIC OF CHINA, WHICH SETS FORTH GUIDELINES FOR DATA CLASSIFICATION, STORAGE,
AND PROCESSING TO ENSURE NATIONAL SECURITY AND PUBLIC INTERESTS; THE MEASURES
FOR THE SECURITY ASSESSMENT OF CROSS-BORDER DATA TRANSFERS, WHICH REQUIRE
SECURITY ASSESSMENTS FOR ANY TRANSFER OF PERSONAL DATA OUTSIDE CHINA; AND OTHER
APPLICABLE PRIVACY LAWS AND REGULATIONS IN THE PEOPLE’S REPUBLIC OF CHINA,
INCLUDING SECTOR-SPECIFIC DATA PROTECTION GUIDELINES, REPUBLIC OF SOUTH
KOREA: THE PERSONAL INFORMATION
PROTECTION ACT (PIPA) OF THE REPUBLIC OF KOREA, SWITZERLAND: THE SWISS
FEDERAL DATA PROTECTION ACT (FADP), UNITED KINGDOM: THE E UK DATA
PROTECTION ACT 2018 (UK GDPR), URUGUAY: THE DATA PROTECTION ACT OF
URUGUAY.
We continuously monitor and update our practices
to ensure compliance with all global privacy standards.
Contact: gdpr@full-game-ahead.com
This Privacy Policy governs the data processing practices of the
following two companies: Full Game Ahead, located at 9th Floor, Amtel Building, 148 Des Voeux Road Central, Central, Hong
Kong, and Lagoon Software, located at D19 Mezza Business Hub, Mont Calme, 90905 Tamarin, Mauritius. These companies jointly
market products and services and are collectively referred to herein as “FGA.”
FGA is committed to protecting the privacy of users of its websites and
game applications. This Privacy Policy applies to both companies and outlines
their joint approach to data processing. The companies operate under contracts
that strictly regulate the exchange and processing of data between them.
FGA will process your personal data solely in accordance with the terms
of this Privacy Policy and for the purpose of providing the services for which
you have supplied your information.
WE COLLECT ONLY THE INFORMATION NECESSARY TO PROVIDE AND ENABLE THE USE
OF OUR SERVICES. ALL PERSONAL DATA IS PROCESSED SOLELY FOR THESE PURPOSES AND
IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR DATA IS STORED AND HANDLED WITH
THE HIGHEST LEVEL OF PRIVACY PROTECTION. WE ARE COMMITTED TO ENSURING THAT YOUR
PERSONAL DATA IS NOT MISUSED OR DISCLOSED FOR ANY PURPOSE OTHER THAN THE
DELIVERY OF OUR SERVICES. WE ALSO PROVIDE CLEAR AND TRANSPARENT INFORMATION
ABOUT HOW YOUR PERSONAL DATA IS COLLECTED, USED, AND STORED. ADDITIONALLY, YOU
HAVE THE RIGHT TO ACCESS, EDIT, OR DELETE YOUR PERSONAL DATA AT ANY TIME,
SUBJECT TO APPLICABLE LAWS AND REGULATIONS.
To learn more about our Privacy Policy and how we process the personal
identifying information collected from our visitors and users, please review
the details provided below.
1. HOW TO
EXERCISE YOUR RIGHTS
Your Rights Regarding Your Personal Information
You have the right to access, update, or correct your personal
information. You may exercise this right by editing your information directly
through the forms used to provide it to us, or by contacting us to request its
permanent deletion at the following email address: gdpr@full-game-ahead.com. You also have the right to object to the processing
of your personal data. If you choose to exercise this right, please contact us
at the same email address. Upon receipt of your objection or request for
deletion, we will destroy the relevant data within fifteen (15) days, subject
to applicable legal requirements.
Requests for Updates or Deletion
Only requests submitted via the email address provided above will be
considered; requests made via telephone or other communication methods will not
be processed.
Important Information
Please note that the removal of your personal data from our databases
will result in the loss of access to our services that require formal
identification. The collection and storage of personal information are
necessary for verifying your identity and enabling these services.
2. SCOPE OF THIS
PRIVACY POLICY
This Privacy Policy applies to how FGA processes
personal identifying information collected through its websites, Facebook®
pages, smartphone applications, and other platforms, including those operated
by Google® and Apple®. FGA will not share your personal data with any
third-party company unless a contract is in place that guarantees compliance
with applicable privacy regulations or the sharing of
your personal data is necessary for the proper delivery of services provided by
FGA. This Privacy Policy does not apply to the practices of companies that are
not owned or controlled by FGA, nor to individuals who are not employed or
managed by FGA. It also excludes third-party contributors with whom FGA has not
entered into a contract for data transmission, as well
as third-party websites accessible via links on FGA’s platforms.
3. USE OF
FACEBOOK/META USERS’ DATA WITHIN OUR GAME APPS
FGA DOES NOT STORE ANY FACEBOOK USER DATA IN ITS DATABASES.
In the Coin-Pusher.com®, Maze Fiesta®, Prize Fiesta®, and Prize Blast®
apps, users may have the option to log in using Facebook. This process utilizes
only the secure App-Scoped ID provided by Facebook, which cannot be used
outside these game apps. Users have the right to request the deletion of their
App-Scoped ID at any time by contacting us at the following email address: gdpr@full-game-ahead.com. Beyond the App-Scoped ID, FGA does not store or retain
any Facebook user data, including users’ or friends’ first names, last names,
or profile pictures. While users may load certain Facebook data on their device
through Prize Fiesta® and Prize Blast® to display interactions with their
Facebook friends, this data is deleted at the end of each session.
4. COLLECTION
AND USE OF PERSONAL DATA WITHIN GAME APPS
We have endeavored to make our policy on the
processing, use and security of your personal data (described in the following
points) as clear as possible. You are allowed to check the personal information
we hold on you, to make sure that it is correct and represents reality. Rest
assured that your personal information is always secure with us and protected.
We use your personal information for the purposes for which you have entrusted
it to us. We will never sell your personal information and we will only share
it with the companies contributing directly to the service to be provided. We use the personal data you share with us in
the following ways:
PROCESS 1:
Collection of Information During Registration for Promotional Gift Award
Programs
FGA collects certain personal data when you
participate in promotional lotteries (sweepstakes) available on Apple® versions
only, or when you register for loyalty programs on other platforms, including
Android. This data is used to fulfill your requests, provide the required
products and services, configure your account, and communicate with you about
our offerings. For the games Prize Fiesta® and Prize Blast®, you
may choose to register for promotions that allow you to receive gifts. When you
register for a sweepstakes or loyalty program organized by FGA, you expressly
consent to the collection of your personal data by checking a required consent
box. This consent is necessary for your information to be processed in
accordance with this Privacy Policy. During this process, FGA may request the
following personal data:
Requested fields |
Description of their use |
Email |
Contact information used to notify users of
their winnings in promotional lotteries or other promotional programs. |
Password |
Provides access to an account synchronized with the online version of
the games. |
Date of birth |
Confirmation of age and eligibility for participation in gift-winning
programs. |
Gender |
Customization of packaging for certain gifts sent (e.g.,
boy/girl/other packaging). |
Last name |
The delivery address, along with phone contact information required by
most carriers, is provided to the carrier in the event of a win. This
information is also used to confirm the eligibility of the participant’s
geographical location. |
First name |
|
Address |
|
Zip code |
|
Town/city |
|
Country |
|
Cell phone or landline number |
Email Confirmation and Use During Promotional
Registration
As part of this process, users will be required to
confirm their email address. To send confirmation emails, FGA partners with the
service provider Mailjet SAS, headquartered at 13-13
bis, rue de l’Aubrac – 75012 Paris. Mailjet SAS is compliant with the General Data Protection
Regulation (GDPR). Process 1 is conducted by customer service representatives
of Lagoon Software Ltd, who are trained in GDPR compliance and are
contractually obligated to adhere to the privacy standards established by these
regulations.
Participation in FGA Promotions
By participating in FGA promotions, you consent to
receive a maximum of three (3) additional emails per year containing updates
and news about FGA. You may opt out of receiving these emails at any time by: clicking on the unsubscribe link provided in each
newsletter, or requesting removal from our mailing list by emailing us at gdpr@full-game-ahead.com.
PROCESS 2:
Collection of Information for Promotional Gift Delivery
When a participant wins a gift in one of FGA’s
promotional game programs, as outlined in the program rules, they are required
to provide the following documents:
Requested documents |
Description of their use |
|
Electronic Copy of Proof of Identity (Scanned or Photographed) |
FGA requires an electronic copy of a valid government-issued
identification document to verify the identity of users receiving a
promotional gift. This is to ensure that the information provided in the
user’s profile matches the information on the proof of identity. |
|
Electronic Copy of Proof of Address (Scanned or Photographed) |
FGA requires an electronic copy of a document verifying the user’s
current address. This is necessary to confirm that the user resides at the
address provided in their profile and to avoid sending prizes to an outdated
or incorrect address. This verification also ensures the geographic
eligibility of the participant for the gift delivery. |
|
Signed Affidavit: Declaration of Admissibility, Compliance, Exemption
from Liability, and Consent for Advertising Purposes |
This affidavit serves two purposes: it secures the legal consent of
users regarding the terms and conditions of the gift delivery, including the
option to decline such terms as required by law in certain jurisdictions, and
it obtains advance permission to use photographs of winners posing with their
gifts for advertising or promotional purposes. Users may choose to provide
these photos after receiving their gift. |
|
This Process 2 is carried out by customer service
representatives of Lagoon Software Ltd, who are trained in GDPR compliance and
are contractually obligated to adhere to the privacy guidelines established by
these regulations.
PROCESS
3:
Customizing the Experience Based on User Preferences
Users may be provided the option to share information about their
preferences, enabling the App to tailor and enhance their experience. This
customization is solely intended to improve user satisfaction and engagement
within the App.
5. COLLECTION
AND USE OF NON-PERSONAL DATA WITHIN GAME APPS
FGA collects and automatically records non-personal
data through your browser or mobile device, including your IP address,
advertising ID, mobile device ID, game account number (iOS Game Center or
Android Game Service), and the source URL when you access our websites. This
non-personal data is collected solely for the purposes outlined below:
PROCESS 4:
Creation and Identification of an Account in the
Application
When you create an account in one of our applications
after downloading it from the App Store or Google Play Store, FGA uses certain
non-personal data to create your account. This data is then reused
to identify you during future visits, ensuring your account remains in the same
condition as you left it. The data used for this process may include: Your
mobile device ID, Your iOS Game Center account number, Your Android Game
Service account number, or a unique ID generated by Facebook (as described in
Article 3 of this Privacy Policy), depending on the connection method you
choose.
PROCESS 5:
Anonymous Data Collection for Advertising Campaign Performance Measurement
FGA may collect your advertising ID to optimize the effectiveness of our
user acquisition campaigns through online advertising. This ID is never stored
on our servers. Instead, it is transmitted exclusively to Singular (https://www.singular.net/), a trusted company that complies with the General
Data Protection Regulation (GDPR). Singular uses this data to generate
anonymous statistics about the performance of our campaigns. At no point is
your advertising ID linked to your personal data. If you prefer not to have
your advertising ID used for generating anonymous statistics, you can opt out
by contacting us at gdpr@full-game-ahead.com.
PROCESS
6:
Advertisement Data Sharing and Collection Policy
FGA provides users with the option to accept or decline the sharing of
their data. Before any data collection occurs, users are presented with a
pop-up within each app where they can opt in or out. If a user consents to data
sharing, our third-party mediation service may use tools such as Google
Analytics to collect non-personal information, including:
Device type, IP address, and In-app activities. This information is used
exclusively to measure and report anonymous statistics about user interactions
within our apps. At no point is this data linked to the user’s personal
identity. By consenting to this data sharing, users benefit from an improved
advertisement experience. Advertisements are selected and moderated based on an
algorithm that considers user interactions within the app to deliver more
relevant content.
6. SHARING AND
DISCLOSURE OF DATA
Access to your personal data is strictly limited to FGA’s authorized
staff and only when necessary for the effective delivery of our services. FGA
may also disclose your personal data to third parties acting on its behalf, but
solely for the purposes of delivering the services and products you have
requested, as outlined in Processes 1 through 6 in Articles 4 and 5 of this
Privacy Policy. FGA shares personal data exclusively for these purposes and
only with third parties whose privacy policies align with ours and who comply
with the requirements of the General Data Protection Regulation (GDPR). FGA may
also disclose your personal data in the following circumstances: when you have
expressly consented to the sharing of your data for specific purposes by selecting
the relevant option on the data collection form; when disclosure is required to
comply with subpoenas, court orders, or other legal obligations; when
disclosure is necessary to protect the safety of users of our services and
applications, or to safeguard FGA’s rights or property; or when your activities
on FGA’s websites or applications are found to violate the terms and conditions
of service or any other applicable rules for the use of specific products or
services.
7. STORAGE OF
PERSONAL DATA
Your personal data will only be retained for as long
as strictly necessary to manage the commercial relationship. However, data
required as evidence of a right or contract, or data stored in compliance with
legal obligations, may be retained in accordance with applicable legal
provisions for a maximum of 10 years. It is securely stored on our servers
using advanced technology designed to significantly reduce the risk of data
breaches or unauthorized access, including cyberattacks. All personal data is
exclusively stored on servers located within the European Union, ensuring
compliance with applicable data protection laws and regulations.
8. DATA ON
SOCIAL NETWORKS
FGA DOES NOT AUTOMATICALLY SAVE ANY PERSONAL DATA
COLLECTED FROM META® SOCIAL NETWORKS OR ANY OTHER SOCIAL NETWORK IN ITS
DATABASES. The information we may collect from social networks or online
websites is limited to publicly available personal information that you have
chosen to publish online. Each social network or online website has its own
privacy policy, which explains how it collects, uses, and shares your personal
information. We strongly encourage you to review these privacy policies carefully
to understand how your information is handled before using such websites or
platforms. When you access an FGA product or game through a social networking
site (SNS), such as Facebook® (hereinafter referred to as an “SNS”), you
authorize FGA to access certain personal and non-personal data provided to the
SNS, such as: Your username, Your first and last
names, Your profile photo, and User data related to the specific product or
game. By accessing an FGA product or game via an SNS, you consent to FGA
collecting, storing, and using all data you have agreed to share with FGA
through the SNS. The collection, storage, and use of this data are governed by
this Privacy Policy.
9. COOKIES
FGA uses cookies, tags, invisible pixels, and other similar technologies
solely to personalize your visit to our platforms. Information collected
through these technologies does not include personal details and is never
shared with third parties. Our cookies do not contain sensitive personal
information or data related to targeted advertising. As such, in accordance
with the General Data Protection Regulation (GDPR), their use does not require
prior consent.
10. CONSENT
If you do not consent to the collection, use, or disclosure of your
personal data as described in this Privacy Policy, please do not submit any
personal data to FGA. If you have previously submitted personal data to FGA and
no longer agree to its use or disclosure as set out herein, you may request the
deletion or restriction of your data by contacting us at gdpr@full-game-ahead.com.
11. AMENDMENTS
OF THE
PRIVACY POLICY
THE MOST RECENT VERSION OF THIS PRIVACY POLICY WAS UPDATED AND PUBLISHED
ONLINE ON NOVEMBER 29, 2024. FGA is committed to maintaining transparency in
updates and will never amend this policy in a way that reduces the protection
of your personal data without obtaining your consent. Any changes to this
Privacy Policy will be published on our website at https://www.full-game-ahead.com/privacypolicy. If we have your email
address, we may notify you directly of significant changes or updates. FGA reserves the right to amend this Privacy
Policy at its sole discretion and without prior notice. We encourage you to
review this policy periodically to remain informed about any updates. By
continuing to use FGA’s websites or services after changes have been made, you
indicate your acceptance of the revised Privacy Policy. This Privacy Policy is
not intended to create any contractual obligations or guarantees. FGA makes
every reasonable effort to comply with the terms of this Privacy Policy and
will take prompt corrective action in the event of non-compliance. However, FGA
cannot guarantee error-free performance. FGA is not liable for incidental,
consequential, or punitive damages arising from this Privacy Policy. This
Privacy Policy is governed by the applicable laws of the United States of
America and/or the European Union.
12. COMPLIANCE
WITH THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a legal representative or represent an
accredited government organization, you may request to contact our Data
Protection Officer (DPO). To do so, please provide a detailed explanation of
your request and send it to gdpr@full-game-ahead.com. FGA has conducted a comprehensive mapping of its
personal data processing activities. Measures have been implemented to ensure
that all internal processes comply with the requirements of the General Data
Protection Regulation (GDPR). An external audit has been conducted to evaluate
all personal data processing activities. The audit confirmed that none of FGA’s
processing activities pose a threat to the privacy of individuals and that all
such activities are lawful and necessary for the fulfillment of FGA’s business
operations. FGA’s internal processes are designed to ensure a high level of
security and to protect the privacy of all individuals whose data is processed.
Additionally, all processing activities are thoroughly documented and
maintained in records available for review by competent authorities upon
request.
13. QUESTIONS
AND SUGGESTIONS
If you have any questions or suggestions regarding
this Privacy Policy or your personal data, please contact us via email at gdpr@full-game-ahead.com.
LAGOON SOFTWARE
19D Mezza Business Hub
Domaine de Mont Calme
90905 Tamarin
Mauritius Island
FULL GAME AHEAD
C/O Profit Accounting
9th Floor
Amtel Building
148 Des Voeux Road Central
Central
Hong Kong
Contact: gdpr@full-game-ahead.com