Lutsgames Privacy Policy
Last Updated: December 5, 2019
Welcome to the Lutsgames’ Privacy Policy. In this privacy policy, we seek to clearly explain to you how we collect, use, process, and share your information. Please read this privacy policy carefully; it will help you make informed decisions about sharing your personal information with us. If you have any questions or concerns about this policy or our practices with regards to your personal information please contact us at lutz.schoenfelder@gmail.com.
TABLE OF CONTENTS
1. ABOUT THIS POLICY
2. AGREEMENT TO TERMS OF PRIVACY POLICY AND END USER LICENSE AGREEMENT
3. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY
4. ONLINE ACTIVITIES DISCLAIMER
5. TYPES OF INFORMATION WE MAY COLLECT
6. HOW WE USE INFORMATION ABOUT YOU
7. NOTICE ABOUT CHILDREN
8. WEBSITE SECURITY MEASURES
9. RISK OF INTERCEPTION
10. SHARING INFORMATION WITH THIRD PARTIES
11. ADVERTISEMENTS
12. LINKS TO THIRD PARTIES
13. AD IDENTIFIERS, COOKIES, AND OTHER TRACKING TECHNOLOGIES
14. OPT-OUT RIGHTS
15. DELETING OR MODIFYING PERSONAL INFORMATION
16. QUESTIONS OR COMMENTS
1. ABOUT THIS POLICY
This privacy policy (the “Policy”) applies to our website (“Website”), our games (“Game(s)”), our advertising activities on all platforms as described below, and other services that we may provide to you from time to time. Some of our Games may have different privacy policies, and the privacy policies for to those Games will be available in those apps. In this policy we refer to our Website, Games, advertising activities, and other services collectively as our “Services.”
The Policy is an agreement between Lutsgames and you, as the user of our Services (“you”). The Policy tells you when this agreement is effective, what information we collect from you, how we might use it, how you can review or change the personal information you provided to us, how we may change this policy, and the steps we take to ensure that your personal information is protected.
2. AGREEMENT TO TERMS OF PRIVACY POLICY AND END USER LICENSE AGREEMENT
IMPORTANT: By downloading, installing, accessing, using, and/or playing our Games, or interacting with our Website or other Services, you agree to the terms set forth in this Policy and to our end user license agreement (posted and including the collection and processing of your personal information). If you do not agree with any term provided herein, you must not provide us with any personal information; you must immediately leave and discontinue use of the Website; you must not download, install, access, use, and/or play the Games; and we request that you promptly erase all of our Games from your mobile device.
3. EFFECTIVE DATE OF AND CHANGES TO PRIVACY POLICY
This Policy is effective as of December 5, 2019, and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on this website or we otherwise notify you of the changes. We reserve the right to change this Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this Policy periodically as its terms may change from time to time. Your continued use of the Services after we post any such modifications will constitute your acknowledgment of the modified policy and your agreement to abide and be bound by the modified policy. We will also revise the “last updated” date found at the beginning of this Policy when we post changes to it.
4. ONLINE ACTIVITIES DISCLAIMER
The Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Tech Tree Game’s control, and is not to be applied in any way contrary to applicable law or governmental regulation.
5. TYPES OF INFORMATION WE MAY COLLECT
Overview:
We collect information from a number of different sources, but most of it comes directly from you when interact with our Games, Website, advertising, or other Services. Broadly, the information we collect about you relates to the type of device you are using and how you play our Games (such as levels attempted and purchases made). We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
Further Details:
Website. You are not required to provide any personally identifiable information to us to visit the Website unless you choose to access features on the Website that require such information, for example, using the “Contact Us” page of the Website.
PURCHASES. Note that when you purchase items via our Games (such as those you can purchase in the Apple Store, on Google Play, or on Facebook) we do not collect or store any payment information from you. If you would like to know what data is collected or how payment information is processed, please familiarize yourself with the app store’s privacy policy.
SPECIFIC TYPES OF INFORAMATION. Depending on which of our Services you interact with we may collect and process the following kinds of information:
· personal identifiers (such as advertising identifiers when available on a device) and device identifiers (such as IP address, carrier user ID, Media Access Control (MAC) address or social network ID). We may collect, use, and provide access to your advertising identifier in accordance with the applicable platform provider's policies. We are also able to identify when you install a Game as a result of advertisements and/or campaigns that we launch on other services, including in social networks or platforms (e.g. on Facebook or otherwise) and the source-ad which led to such installation, and when a you view or click on such advertisements;
· click stream data such as server address and domain name;
· location data from GPS-enabled devices (to the extent that you explicitly allowed it) provided by the devices’ interaction with the Games or association with your IP address. In addition, third parties may track and collect information regarding your online activities over time and across different online platforms (such as websites, applications, etc.). For more information regarding your ability to stop such tracking and collection, please see below;
· your account number(s) on Google Play Games or Apple Game Center, if enabled;
· if you contact us or respond to messages or communications that we send to you, we may collect your name and email address, as well as keep a record of that correspondence;
· your interactions with us through social media channels;
· information we collect via cookies and other similar technologies, as explained further below; and
· information we collect about you from third party companies including but not limited to publishing partners, platforms, advertising platforms and partners, and data aggregators, which may include attributes about you and your interests, as well as other games and services you use, and demographic and general location information. We will use this information as described in this policy subject to any limitations in the privacy policy of the company that collected the information from you.
GENERAL INFORMATION. We may also collect, process, and share some technical, statistical, and behavioral information in an aggregated or anonymized manner. That means this information does not reveal your specific identity but may include device and usage information. In addition to the types of information listed above, this information may include but is not limited to device type, type and version of operating system, network provider, browser identifiers, type of browser, screen resolution, session information, click stream data, SDK version, API key, browser cookies, application version, in-app purchases and data regarding receipt validation, network status, locale and time zone, clicks on advertisements, certain information about the advertisements you reviewed, your activities in the Game (including without limitation any information relating to your activity in connection with the advertising displayed therein), and gameplay details such as time spent playing, levels achieved, tools and in-app functionalities used, screens accessed, user retention, performance errors and problems, Game’s stability, crashes, functioning, etc.
6. HOW WE USE INFORMATION ABOUT YOU
Overview:
We will primarily use the personal information you provide and any general information we receive from you to provide and optimize products and services to you.
Further Details:
We may use such information:
· for statistical, analytical and research purposes for development and improvement of our Services (for example, analyzing and fixing of problems, developing new offerings, providing better content, simplifying and improving your experience including based on preferences shown by usage);
· to measure traffic and usage;
· to promote our Services;
· to enable certain ad serving features, such as, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), etc.;
· to enable certain functionalities available within the Games, for example in-app purchases;
· to ensure proper functioning of the Games and Services;
· to respond to questions or requests which were provided using a “Contact Us” feature;
· to enable you to use Game Center Features, if available;
· for authentication purposes including to verify your identity when you sign in to a Game or interact with our Services, to verify clicks and/or installs, and to verify a user’s identity for the purpose of dealing with inappropriate interactions and/or fraudulent use of our Services;
· to measure reach and effectiveness of advertisement campaigns, to offer targeted advertising, to personalize experience by showing advertisements for products and services that are more likely to appeal to you (i.e. behavioral advertising).
· to send push notifications to your device after you agree to accept push notifications from us or third parties. You can deactivate push notification by changing the settings within the Game and/or changing the notification settings in accordance with the instructions of the operating system running on your device;
· as required or permitted by any applicable law (see below regarding Release of Information for Security); and
· for any other purpose explained at the time collected.
7. NOTICE ABOUT CHILDREN
Lutsgames is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.
Please note that we provide general audience Services, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a user of our Services is under age 13, we will promptly delete any personal information regarding that user.
8. WEBSITE SECURITY MEASURES
This section applies only to the Website. Please note:
· We do not use vulnerability scanning, malware scanning, or scanning to PCI standards.
· We have not enabled Google AdSense but may do so in the future.
· We honor “Do Not Track” (DNT) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.
9. RISK OF INTERCEPTION
Please keep in mind that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While Lutsgames strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using any Service, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us and that any personal information, general information, or other data or information received from you pursuant to your use of the Services is provided to us at your own risk, which you expressly assume.
10. SHARING INFORMATION WITH THIRD PARTIES
Overview:
We only share your information with your consent, for security purposes (to comply with laws and protect rights), or to fulfill business obligations. Please also refer the section of this policy regarding advertising.
Further Details:
SECURITY. Lutsgames will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will release such information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation
We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this Policy to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.
FULFILL BUSINESS OBLIGATIONS. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our Service Partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the Website, executing services (such as advertising), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We encourage our Service Partners to adopt and post privacy policies. However, the use of your personal information by our Service Partners is governed by the privacy policies of those Service Partners and is not subject to our control.
The following is a list of our Service Partners and links to their privacy policies:
CONSENT. We may disclose your personal information for any other purpose with your consent.
11. ADVERTISEMENTS
In addition to ads for our Services, we accept advertisements, in various formats (such as banners, interstitials, rewarded videos, etc.) from third-party ad networks that may be displayed in our Games. These third-party ad networks may collect and use information about your interaction with our Services in connection with such marketing, sales and advertising activities; geographic tracking and carrier network preferences; and information, such as age and gender logged from your device to ensure that appropriate advertising is presented within the Game and calculate or control the number of views of an ad, and/or deliver advertisements relating to your interests, and measure the effectiveness of advertisements campaigns.
Note that if you click on any of these advertisements, the advertisers may use cookies and other web-tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) on your device to collect data regarding advertisement performance, your interaction with such advertisements and our Services, and your interests in order to serve you advertisements, including targeted advertisements, and for the legitimate business interests of such third-party ad networks. This data may include your personal information such as device and network information, unique identifiers, gender, age, and geo-location. We recommend that you review the terms of use and privacy policy of any third-party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.
The following is a list of our advertising partners and links to their privacy policies:
PARTNER LINK TO PRIVACY POLICY
12. LINKS TO THIRD PARTIES
We may insert links to third parties on the Website and in our Games. This Policy does not apply to such third-party websites. These links take you outside our Services and are beyond our control. This includes links from partners that may use Tech tree Game’s logos as part of a co-branding agreement. The sites those links take you to have their own separate privacy policy and although we seek to protect the integrity of our Website, Lutsgames is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.
13. AD IDENTIFIERS, COOKIES, AND OTHER TRACKING TECHNOLOGIES
Overview:
To provide our Games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. Please read this section to understand our use of these technologies and how you can manage your preferences.
Further Details:
WHAT THEY ARE. Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
A cookie is a small string of information that a website you visit transfers to your device for identification purposes. Cookies can be used to follow your online activity on the website and that information helps us to understand your preferences and improve your experience. Cookies are also used for such activities as remembering your user name and password, if such feature is available and you choose to use it.
HOW WE USE THEM. Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
· recognize you and your device;
· provide interest-based advertising to you;
· allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
· enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.
TURNING OFF COOKIES. You can turn off all cookies, in case you prefer not to receive them. You can also have your device warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the Services’ functionality and you may lose access to some of its features.
ADJUSTING INTEREST BASED ADVERTISING PREFERENCES. You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings.
If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices(for Canadian users). You can also click on the AdChoices logo within an advertisement (where available). If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.
Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).
14. OPT-OUT RIGHTS
To stop all collection of information from the Website, leave and discontinue use of the Website. You can also easily stop all collection of information through a Game by uninstalling the Game.
15. DELETING OR MODIFYING PERSONAL INFORMATION
If you would like to access, modify, or delete any information that can personally identify you, please email your request to , and we will respond promptly.
16. QUESTIONS OR COMMENTS.
If you have any questions or comments relating to our website or the privacy policy, send an e-mail to lutz.schoenfelder@gmail.com. Our Data Protection Officer can also be contacted at lutz.schoenfelder@gmail.com.
PLEASE READ THESE LICENCE TERMS CAREFULLY
BY CLICKING ON THE “I AGREE” BUTTON IN GAME, YOU AGREE TO THESE TERMS WHICH WILL BIND YOU.
IF YOU DO NOT AGREE TO THESE TERMS, YOU SHOULD NOT PRESS THE "I AGREE" BUTTON IN GAME AND YOU CANNOT PLAY THE GAME.
Who we are and what this agreement does
We Lutsgames, license you to use:
Lutsgames mobile applications software (“Apps”) and any updates or supplements to it.
The related electronic documentation (“Documentation”).
as permitted in these terms.
Your privacy
We only use any personal data we collect through your use of the App in the ways set out in our privacy policy
Please be aware that internet transmissions are never completely private or secure and that any message or information you send using the App may be read or intercepted by others.
Google Play and Apple’s App Store terms also apply
The ways in which you can use the App and Documentation may also be controlled by Google Play’s/Apple App Store’s rules and policies (Google Play) (Apple) and Google Play’s/Apple App Store’s rules and policies will apply instead of these terms where there are differences between the two.
Support for the App and how to tell us about problems
Support. If you want to learn more about the App or have any problems using it please email our support resources at
How we will communicate with you. If we have to contact you we will do so by email, using the contact details you have provided to us.
How you may use the App, including how many devices you may use it on
In return for your agreeing to comply with these terms you may:
Download or stream a copy of the App onto your personal device (but not onto the device that does not belong to you) and view, use and display the App on such devices for your personal purposes only.
Use any Documentation to support your permitted use of the App.
Receive and use any free supplementary software code or update of the App incorporating “patches” and corrections of errors as we may provide to you.
You must be 18 to accept these terms and buy the app
You must be 18 or over to accept these terms and buy the App.
You may not transfer the App to someone else
We are giving you personally the right to use the App as set out above. You may not otherwise transfer the App to someone else, whether for money, for anything else or for free. If you sell any device on which the App is installed, you must remove the App from it.
Changes to these terms
We may need to change these terms to reflect changes in law or best practice or to deal with additional features which we introduce.
Where we make a change to these terms we will do so by way of an update to the App. You may be required to accept the updated terms before being permitted to continue to use the App.
Update to the App
From time to time we may automatically update the App to improve performance, enhance functionality, reflect changes to the operating system or address security issues. Alternatively we may ask you to update the App for these reasons.
If someone else owns the phone or device you are using
If you download the App onto any phone or other device not owned by you, you must have the owner’s permission to do so. You will be responsible for complying with these terms, whether or not you own the phone or other device.
We may collect technical data about your device
By using the App, you agree to us collecting and using technical information about the devices you use the App on and related software, hardware and peripherals to improve our products.
We are not responsible for other websites you link to
The App may contain links to other independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any).
You will need to make your own independent judgement about whether to use any such independent sites, including whether to buy any products or services offered by them.
Licence restrictions
You agree that you will:
not rent, lease, sub-license, loan, provide, or otherwise make available, the App in any form, in whole or in part to any person without prior written consent from us;
not copy the App or Documentation, except as part of the normal use of the App or where it is necessary for the purpose of back-up or operational security;
not translate, merge, adapt, vary, alter or modify, the whole or any part of the App or Documentation nor permit the App or any part of it to be combined with, or become incorporated in, any other programs, except as necessary to use the App on devices as permitted in these terms;
not disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of the App nor attempt to do any such things, except to the extent that (by virtue of sections 50B and 296A of the Copyright, Designs and Patents Act 1988) such actions cannot be prohibited because they are necessary to decompile the App to obtain the information necessary to create an independent program that can be operated with the App or with another program (Permitted Objective), and provided that the information obtained by you during such activities:
is not disclosed or communicated without the Licensor’s prior written consent to any third party to whom it is not necessary to disclose or communicate it in order to achieve the Permitted Objective; and
is not used to create any software that is substantially similar in its expression to the App;
is kept secure; and
is used only for the Permitted Objective;
Comply with all applicable technology control or export laws and regulations that apply to the technology used or supported by the App or any Service.
Acceptable use restrictions
You must:
not use the App in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these terms, or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, such as viruses, or harmful data, into the App or any operating system;
not infringe our intellectual property rights or those of any third party in relation to your use of the App (to the extent that such use is not licensed by these terms);
not transmit any material that is defamatory, offensive or otherwise objectionable in relation to your use of the App; and
not use the App in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users.
Furthermore, while we appreciate that accidental clicking of advertisement banners may happen, we suggest that unless you have a legitimate interest in the content which is being advertised within an advertisement that is placed within our Apps, you do not click on such advertisement.
Intellectual property rights
All intellectual property rights in the App and the Documentation are licensed (not sold) to you. You have no intellectual property rights in, or to, the App or the Documentation other than the right to use them in accordance with these terms.
Our responsibility for loss or damage suffered by you
We are not liable for business losses. The App is for domestic and private use. If you use the App for any commercial, business or resale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
Limitations to the App. The App is provided for general information and entertainment purposes only. It does not offer advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of information obtained from the App. Although we make reasonable efforts to update the information provided by the App, we make no representations, warranties or guarantees, whether express or implied, that such information is accurate, complete or up to date.
Check that the App is suitable for you. The App has not been developed to meet your individual requirements. Please check that the facilities and functions of the App (as described on the Appstore site and in the Documentation) meet your requirements.
We are not responsible for events outside our control. If our support for the App is delayed by an event outside our control then we will contact you as soon as possible to let you know and we will take steps to minimize the effect of the delay. Provided we do this we will not be liable for delays caused by the event but if there is a risk of substantial delay you may contact us to end your contract with us and receive a refund for your inability to use the App.
We may end your rights to use the App if you break these terms
We may end your rights to use the App at any time by contacting you if you have broken these terms in a serious way. If what you have done can be put right we will give you a reasonable opportunity to do so.
If we end your rights to use the App and Services:
You must stop all activities authorised by these terms, including your use of the App.
You must delete or remove the App from all devices in your possession and immediately destroy all copies of the App which you have and confirm to us that you have done this.
We may transfer this agreement to someone else
We may transfer our rights and obligations under these terms to another organization. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.
You need our consent to transfer your rights to someone else
You may only transfer your rights or your obligations under these terms to another person if we agree in writing.
If a court finds part of this contract illegal, the rest will continue in force
Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.
Even if we delay in enforcing this contract, we can still enforce it later
Even if we delay in enforcing this contract, we can still enforce it later. If we do not insist immediately that you do anything you are required to do under these terms, or if we delay in taking steps against you in respect of your breaking this contract, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.