2. Types of the Collected Personal Information and How We Collect It
2.1 Personal Information regarding the current, prospective, and former clients, customers, users, visitors, and guests may be collected. The types of Personal Information Fomo may collect may vary upon the Service that User gets or relationship between Fomo and User.
2.2 By downloading, accessing and/or playing (if applicable) the games or using the Services, User consents to the collection of information about User by Fomo. The types of Personal Information Fomo may collect (directly from User or from Third-parties) and the privacy practices varies on the nature of the relationship that User have and the requirements of applicable law. Please find below which type of Personal Information we collect and the ways of collection.
· Information Directly Collected from User
Some games or parts of Fomo’s Services may use a more traditional registration or account set-up process that User directly provides information:
Ø User first and last name, email address, player/user name, password, age or birthday, sex and other information that helps Fomo to make sure it’s the User itself that is accessing the account or helps Fomo to improve its services
Fomo may also require from User to create player profile, in such cases, User profile may include below mentioned information:
Ø User first and last name, email address, User identification number and/or user name, User profile picture or his/her URL, player ID, location, sex, age-range, the login e-mail, detail about the games User plays, mobile phone number (if provided by User), locale, language of User application, time zone numbers for User friends who are also connected to the Services.
· Information User Generates Using Fomo Services
Information that User provides Fomo with when User fills in forms, and/or questions or complete surveys when using any of the Services, when User creates an account with Fomo or if User invites his/her friends to use the games and Services; (such as gender, name, date of birth place, nickname, nationality); the content of messages sent using the chat and messaging systems; posted photos, drawings, or other user-generated content; public posts or comments on other players’ profiles or gameboards.
Please note that, Fomo is entitled to access such record, and/or store archives of these communications, photos, drawings, and other contents generated by User in order to satisfy legal compliance and provide the safety of other users/players generated content on Fomo servers to make use of them to protect the safety and well-being of Fomo’s players as well as to conduct researches in order to improve, personalize, and optimize Fomo’s Services and games.
· Information collected when User make any purchases
In case of any purchase in-game virtual currency or items in a Services, third-party payment processor may collect the billing and financial information such as User’s postal address, e-mail address, and financial information.
Please note that the information that Fomo collects receives depends on Services that User is provided with.
· Information About User That Fomo Get Connected from Third-Party Applications, Including Social Networks
If User gets any Services of Fomo on connected third-party applications or connect Fomo Services to any third-party applications, including social networks like Facebook, Fomo may receive certain information about User from the provider of the third-party application. The information Fomo receives depends on the Service, the third-party application, privacy settings. In such case Fomo may collect below information;
Ø User first and last name, email address, User identification number and/or user name, User profile picture or his/her URL, player ID, location, sex, age-range, the login e-mail, user identification number (like Facebook ID number), which may be linked to publicly-available information like name and profile photo; friends’ user ID numbers and other public data; detail about the games User plays, mobile phone number (if provided by User), locale, language of User application, time zone numbers for User friends who are also connected to the Services; User personal comments which may include Personal Information; Personal Information to be published on the fan pages, forums, sites or to be provided via contest; information about User’s activities on or through the connected third-party application;
· Cookies and Other Automated Information Collection
Fomo collects information about User’s devices by using cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize User and/or User device(s) on, off, and across different Services and devices. User always have option to opt out from such use and control it where needed.
Ø Protocol (IP) address, cookie identifiers, mobile advertising identifiers, User mobile device’s identifiers like User Identifier For Advertising , Advertising ID, Game Center ID, the type of computer or mobile device User is using, User device's operating system, version, model, hardware type and other device identifiers that are automatically assigned to User computer or device when User access the Internet, browser type and language, hardware type, operating system, internet service provider, pages that User visit before and after using the Services, the date and time of User visit, the amount of time User spend on each page, information about the links User click and pages User view within the Services and other actions taken through use of the Services such as preferences; information Fomo collect via cookies and widgets that allows Fomo to collect data, such as User device's model, operating system and screen size, IP, game center IP, preferences and other information about how User use the Services;
Ø domain names;
Ø performance and game contextual data like User games session activity;
Ø aggregated and/or de-identified information that is not intended to specifically identify a user; and
Ø technical information such as device identifier,
Ø details about how User uses and interacts with the Services (for example, information about how and when User play the games or visit the websites(s),
Ø information that User provides Fomo when User fills in forms, and/or questions or complete surveys when using any of the Services, when User creates an account with Fomo or if User invites his/her friends to use the games and Services; (such as gender, name, date of birth place, nickname, nationality etc. )
Ø User interactions with Fomo on the social media channels;
Ø the name User have associated with its device; country; telephone number (if User provides it); specific geolocation (with User’s permission); mobile contacts; and/or information about the Fomo games and other third-party apps on User’s device. (if Fomo Services obtained via mobile device)
· Other Sources
Ø information that Fomo collects about User from the other group companies or other third party companies who have obtained User’s consent or have another legal right to share such information with Fomo (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained). This may include attributes about User and User interests, as well as other games and services that User uses, demographic and general location information.
· California “Do Not Sell My Info.”
Fomo does not sell any Personal Information or any data related to its users.
3.1 The primary goal of processing the Personal Information is to provide a better gaming experience, improve the Services, and conduct marketing and research activities and create reports for internal use. The Personal Information may be stored anywhere in the world including but not limited to Turkey either physically or electronically.
3.2 Personal Information may be collected and processed for below mentioned purposes;
Ø the managing the account and relationship with Fomo and improving the experience during the use of the Services;
Ø research, surveying, and engaging with User, for example by sending communications (including by email);
Ø to enable users/players to interact and communicate with each other;
Ø marketing and promotion of Services, to create reports, analysis or similar services for use by Fomo;
Ø business intelligence, preventing cheating, crime or fraud;
Ø to deliver advertising and marketing and promotional information to User;
Ø to notify User about products and services or upcoming special offers/events that may be interest of User;
Ø to operate, improve and optimize the Services; to create game accounts and allow users to play the games; to personalize the Services, understand the users and their preferences to enhance user experience and enjoyment using the Services;
Ø to send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages; to enable players to communicate with each other in games or on the social media accounts;
Ø to prevent potentially prohibited or illegal activities and protect of the players; to ensure internal quality control;
Ø to provide technical support and respond to player inquiries;
Ø to provide services via mobile devices; for third party payment requirements;
Ø for serving cookies, pixel tags, analytics information and interest-based or targeted advertising;
Ø To comply with Fomo’s legal obligations, resolve any dispute that Fomo may come across and to protect the rights of Fomo.
4. Using and Sharing Personal Information
4.1 The Personal Information shared by the User shall in no case be used for the interest of other third Parties either directly or indirectly and shall be disclosed except as provided below. Please note that Fomo may share Users Personal Information to provide the Services with Third-party Service Providers; to comply with legal obligations; to protect and defend its rights and property or with User’s consent.
· Service Providers
We may share the information we receive from the User with Service Providers. The types of Service Providers (processors) to whom we entrust Personal Information include Service Providers for: (i) provision of IT and related services; (ii) provision of information and services User have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Fomo may also share information with platform partners for SDK Advertising and S2K Tag Advertising with AdColony, Inc., Admob, Inc. , AppLovin Limited, Chartboost, Inc., Pubnative GmbH, Inmobi Pte. Ltd., ironSource Mobile Ltd. Mopub Inc. Tapjoy, Inc. Unity Ads Vungle, Inc., Facebook Analytics for Apps (Facebook, Inc.), Google Analytics for Firebase (Google Inc.), Google Analytics (Google Inc.), Amazon Web Services (AWS) and Adjust GmbH. In order to provide safety to User’s Personal Information, Fomo takes reasonable precautions information (as required by applicable data protection laws) while sharing such information with such Service Providers.
· Displaying to Friends and Other Users
Fomo Services encourages it players to interact with each other if User plays the games or access the Services. If through a social network or register through a social network (i.e Facebook), User’s social network friends who also plays Fomo games or access Services will see User’s name, photo, player profile.
In addition, in Services offered by Fomo, other players, regardless of whether they are User’s social network friends, will be able to see User’s player profile; view descriptions of User’s in-game activity; communicate with User within the Services; and send User’s game requests or friend requests through Fomo games, Services or the related social network.
· Marketing - Interest-based or Targeted Advertising and Third-party Marketing.
In some occasions Fomo may use advertising tools and mechanisms in order to offer several features and Services gratis. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Mostly such offerings are hosted by third party wall providers and not held by Fomo itself. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party providers. Fomo does not actively shares Personal information with such third-party offer wall providers.
In order to carry out such advertising tools Fomo may share or such third-party provider may directly collect below Personal Information within Services:
Ø performance data (like the number of clicks on an advertisement);
Ø certain technical information (for example, IP addresses, non-persistent device identifiers such as Advertising ID and de-identified persistent device identifiers such as a hashed Android ID);
Ø User’s social network ID;
Ø other contextual data about User’s game play (for example, level and session length); and
Ø pseudonymous data, not directly identifying information (e.g., OS name and versions, device models, time stamp).
Ø In addition to serving Users with relevant ads, the information collected may be used to:
Ø calculate the effectiveness of the ads
Ø offer User targeted advertising (both on and off the Services) in order to personalize User experience by showing advertisements for products and services that are more likely to appeal by User (a practice known as interest-based advertising or behavioral advertising); and/or
Ø undertake web analytics to analyze traffic and other player activity to improve User’s experience.
· Disclosures to Protect Fomo or Others (i.e as Required by Law and Similar Disclosures).
Personal Information may be used accessed, preserve, and disclosed if Fomo believe doing so is required or appropriate:
Ø To satisfy and comply with applicable laws or regulations
Ø To fulfil to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
Ø To prevent illegal activities such as committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions which are carried out via using Services.
Ø Occurrence of emergency that poses a threat to the health and/or safety of the User, another person, or the public generally.
· Merger, Sale, or Other Asset Transfers.
5. Transfer Abroad
As part of the Services and games Fomo may transfer several Personal Information abroad to its business partners and service providers from time to time for the legitimate business purposes.
Fomo store Personal Information about Users and visitors to the sites on servers located in the Amazon Servers, and Fomo may also store this Personal Information on servers and equipment in other countries and may change such location from time to time. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, or one of its business partners or service providers. This staff may be engaged in, among other things, (i) the processing of transactions and User’s payment details, or (ii) the provision of support services. If Fomo transfers User’s Personal Information internationally, Fomo will take reasonable steps to ensure that Personal Information is treated securely, lawfully, and in accordance with this Policy.
6. User Rights and Shine the Light
6.1 User have certain rights in connection with Personal Information and how Fomo handle it. User can exercise these rights at any time by contacting us. In that vein, regardless of where User is located (applicable for European Union and Switzerland as well) User is entitled and have right to:
· access and require information regarding the types of personal information of Users is processed and to ask detailed information,
· learn the purpose of Personal Information processing and whether such Personal Information are used for such purpose,
· know the parties to which such Personal Information is transferred within the country or abroad,
· ask the correction of Personal Information in order to be true actual and updated,
· demand the deletion of User’s Personal Information,
· object to the processing of Personal Information about himself/herself, which is processed on the grounds of legitimate interests,
· opt-out of marketing communications,
· demand from Fomo to inform other third parties regarding the correction, deletion destruction of such Personal Information,
· object the results against to User which occurred through analysis of such Personal Information via exclusively automatic systems,
· to withdraw its consent at any time, in case of processing Personal Information with User’s request,
· demand compensation in case of any damages due to the processing of Personal Information in violation of applicable law,
· request a restriction of the processing of User Personal Information, such as when User is disputing the accuracy of User data held by Fomo.
6.2 To exercise User rights to access or deletion, please submit a request through contact details stated below. Fomo shall finalize the requests of the User in reasonable time in accordance with the applicable data protection laws and manner and yet no later than 30 (thirty) days. If the use of right by the User requires additional cost, then Fomo may be entitled to demand such costs from User.
6.3 For the use of rights conferred to User, User may also be required to take additional steps, such as deletion of Services or, suspension of User’ Accounts or the connection with several application or social network. For the use of the rights by User, Fomo may demand from the User the verification of its identity.
6.4 Accessing and Deleting Personal Information Held by Fomo
User can request a copy of or deletion of its game account data by contacting us. To review and update personal information associated with User profile in certain games, visit the “settings” page in that game.
For deletion requests, Foo will take reasonable measures to delete Personal Information from Fomo’s records. Fomo will keep certain records (e.g., personal information relating to payments or customer service matters) for legitimate purposes.
6.5 Managing Personal Information Fomo Receives from Third-Party Applications / Platforms And From User’s Mobile Device
To manage the information Fomo receives from third-party applications or platforms and from User’s mobile device, User can use the tools and settings provided by the third-party application and its own mobile device.
In order to manage the information that Fomo collects from third party applications, User has to follow the instructions of such third parties to update and changes the privacy settings
User can manage many aspects of the collection and use from its mobile device by visiting the “settings” page of its mobile device or web browser. Such procedures may vary depending on the device and the browser.
7. Opt Out
7.1 Opting out Fomo Notifications
· User may opt out in any time in accordance with his/her sole discretion, clicking on the opt out link provided in all marketing mailings, by turning off notifications from mobile device or SNS settings or by sending an e-mail to firstname.lastname@example.org without incurring any costs.
· If User wants to stop receiving promotional e-mails from Fomo, User may click on the “unsubscribe” link at the bottom of any promotional email from Fomo or may visit Email Settings page.
· Please note that if User opt ins or out of receiving marketing communications from Fomo, Fomo may still communicate with User from time to time that Fomo needs provide User with information about the Service that User using, if Fomo needs to request information from User with respect to a transaction initiated by User, or for other legitimate non-marketing reasons.
· If User wants to stop receiving push notifications, which are messages an app sends User via mobile device even when the app is not on, User can turn of push notifications by visiting his/her mobile device’s “Settings”. Many of the Services also offers the ability to turn off push notifications in the “Settings” section of related Services
7.2 Opting Out of Third-Party Behavioral Advertising
For the notification by personalized advertising from third-party partners, User can opt in or opt out of third-party customized advertising through the device Settings and other third-party opt-in or opt-out tools. If User does not want to receive tailored in-application advertisements from third parties that relate to his/her interests on his/her mobile device, User may adjust the ad tracking settings on his/her device (such as turning on Limit Ad Tracking). User can also reset the “Advertising Identifier” (such as an IDFA) from User’s mobile device’s settings which will prevent continued use of existing behavioral data tied to User’s previous “Advertising Identifier”. Further, depending on the platform provider (such as Apple or Google), User may be able to download apps that offer to provide User with control regarding the collection and use of cross-app data for tailored advertising. All the opt-in or opt-out tools described in this provision are provided by third parties, not by Fomo. Fomo does not control or operate these tools or the choices that advertisers and others provide through these tools.
8. Protection and Retention of Personal Information
8.1 In order to help ensure a secure and safe experience, Fomo is continuously developing and implementing administrative, technical and physical security measures to protect the Personal Information from unauthorized access or against loss, misuse or alteration. The Personal Information that User provide to Fomo is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption.
8.2 If User has an account registered directly with Fomo, the credentials of such account is protected by the password created by the User itself. The protection of the password is on the shoulders of the User and user itself is liable for the unauthorized use of such password. User must not share such password and credentials and must keep its social network account information, including its social network account password, secure as well.
8.3 Fomo retains Personal Information if the account is active or as needed to provide User the Service. Fomo will take reasonable measures to delete Personal Information if User deletes its account. However, User acknowledges that Fomo may retain some information even after if User closes, have deleted, its account as necessary for legitimate business interests, such as to comply with legal obligations, resolve disputes.
8.4 The Personal Information is protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption. Yet Fomo cannot ensure or warrant the security of any information that User transmit to Fomo or through the Services.
9. Policies with respect to Children
Most of Fomo Services and games are not intended for children under the age of 13 and Fomo does not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use Fomo Services. Children are not permitted to use these Services, and Fomo does not collect any personal information from Children on purpose.
If the User is under 13 (or under 16 at some European Union Countries and territories) Fomo kindly ask from User not to send any data about oneself, including name, address, telephone number, or email address. If Fomo learns that personal data about a child under age 13 have been collected, such data will be deleted as quickly as possible.
10. Revisions and Updates