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