Introduction
PEBBLE MEDIA INC ("Company", "we", "us", "our"), its subsidiaries and affiliates, is the author and publisher of gaming applications and associated online platforms, including but not limited to websites, games, and online services created or operated from time to time.
This Privacy Policy applies to all games and services provided by the Company and explains how your data, including personal information, is collected and processed when you use our mobile applications (the "App").
Personal Information means any information, data, details, or records that relate to and can be used to identify, recognize, locate or contact a natural person — either directly or indirectly in combination with other information.
The App is a free-to-play game (with optional in-game purchases). To maintain high quality and a great game experience, we process information from and about you to improve the entire experience and support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, provide additional notice or require a renewed consent.
Information We Collect
When you access or use the App, we automatically collect the following categories of information:
Log Information
We log information about your use of the App, including the type of device you use, features accessed, access times, IP address, demographics, mobile and computer operating systems, browser type, and information collected via cookies.
Device Information
We collect information about the device used to access the App, including manufacturer, model, operating system, time zone, and language settings.
Device Identifiers
We collect online identifiers including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID.
Usage Information
We collect information relating to your use of the App, including game progress, scores, achievements, and interactions with other players.
Consumption Information
We collect information about your consumption habits, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.
Personal Information
We collect personal information you provide via the App, including through associated forms — such as name, address, email address, bank details, date of birth, contact number, user IDs, passwords, photographs, and other data regarding your usage of the App.
Information from Other Sources
If you log into the App using a third-party site or platform such as Facebook, Apple Game Center, or Google Sign-In, we access information from that platform — such as your screen name, profile information, and friend lists — subject to authorization procedures determined by that third party and your consent.
You can learn more about how these platforms process your personal data in their respective privacy policies:
By logging in via a third-party platform, you represent that your access complies with that platform's terms and policies, and that you are above the minimum age limit prescribed by the applicable legislation.
Use of Information
We use information about you for the following purposes, in accordance with the legal bases described:
Performance of Contract (Article 6(1)(b) GDPR)
- To provide and deliver the products and services you request
- To provide and maintain the App and game experience
- To send technical notices, updates, security alerts, and administrative messages
- To provide better usability and troubleshooting
- To understand which parts of the App are visited and how frequently
- To market products and services based on legitimate business interest
Legitimate Interests (Article 6(1)(f) GDPR)
- To provide news and information about the App we think will interest you
- To personalize and improve the App and provide tailored content
- To monitor and analyze trends, usage, and activities in connection with the App
Consent (Article 6(1)(a) GDPR)
- To share advertising IDs with ad network partners for personalized (behavioral) advertising in the App
- To assist partners and third parties to provide services and process payments through the App
Storage of Information
PEBBLE MEDIA INC will store your personal data for as long as necessary to provide you with the App or otherwise fulfil the purposes described in this Policy, unless further storage is required to establish, exercise, or defend a legal claim or to comply with applicable law including accounting rules.
Your personal data is deleted or anonymized as soon as it no longer serves one of the above-mentioned purposes, unless a longer retention period is required by law or for directly related legitimate business purposes — including any ongoing services availed through the App, investigations under law, or contractual arrangements between the parties.
We may keep records of all communications — including voice calls and digital chats — received from and made to users for the purpose of administration, research and development, training, and business intelligence.
Sharing of Information
We disclose information about you to the following categories of recipients based on legal bases under Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR:
- Social networks (see Social Sharing Features section)
- Third parties where required by applicable law, rule, regulation, or legal process
- Third parties in connection with a merger, sale, financing, or acquisition of our business
- Statutory, government, regulatory, or administrative authorities where your actions are inconsistent with our policies, or where disclosure is necessary to protect the rights, property and safety of PEBBLE MEDIA INC or others
- Other players in order to provide certain in-app features such as leaderboards, if you log in via a third-party service
Advertising Networks
If you have given your consent under Article 6(1)(a) of the GDPR, we share your device identifiers with the following advertising network companies for the purpose of serving behavioral advertisements within the App:
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning processing carried out by such third parties, please review their individual privacy policies.
Data Processors
In connection with our processing, we use the following data processors — including server hosting providers, analytics providers, and user login services:
Social Sharing Features
The App offers or may offer social sharing features and integrated tools (such as the Facebook "Like" button), which let you share actions you take in the App with other media. You must be over the minimum age limit prescribed by legislation in your jurisdiction to use any social sharing features integrated in the App.
The use of such features enables sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.
Children
Use of the App is limited to users aged 13 years and above, except in the European Economic Area, where the App is limited to users aged 16 years and above. If the permissible age in your jurisdiction is higher than the applicable minimum age stated above, that higher age shall apply.
If you are accepting this Privacy Policy and using the App, you warrant that you are 13 years of age or older (or above the applicable minimum age in your jurisdiction). Access or use by minors is presumed to be under the supervision and control of parents or legal guardians who have accepted this Privacy Policy.
We reserve the right to refuse or restrict access to the App if we learn of any incompetency to use the App. If you have questions about our privacy practices related to children under the applicable minimum age, please contact us at apps@pebblemedia.net.
Transfer to Third Countries
In connection with our processing, we may in certain circumstances transfer your personal data to recipients outside the EEA. We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure their level of data protection is in agreement with this Privacy Policy and applicable law.
Transfers will only occur based on the following safeguards:
- The entity is certified to comply with the EU–US Privacy Shield Framework
- We have entered into standard data protection clauses adopted by the European Commission
- Standard contractual clauses (SCCs) approved by relevant data protection authorities
- The recipient country is recognized as providing an adequate level of data protection
- Binding corporate rules (BCRs) where applicable
- Additional technical and organizational measures to secure data during and after transfer
Data Disclosure & Transfer
We may share your personal data within the Company and with the following parties on a need-to-know basis for the purposes mentioned in this Privacy Policy:
- Employees, affiliates and related parties
- Business partners and service providers
- Authorized third-party agents and contractors
- Payment facilitators and banks
- Group companies or affiliates
We will not sell or rent your information for commercial purposes contrary to the commitments made in this Privacy Policy. In case of restructuring or reorganization of the Company, personal information may be transferred to a successor entity as a result of a merger, reorganization, or consolidation.
We may share your information without prior written consent with judicial authorities, administrative bodies, or government agencies mandated under law to obtain information for verification, prevention, detection, investigation, or prosecution of offences, or where disclosure is necessary for compliance with a legal obligation.
Use of Cookies
Our App uses cookies to improve your online experience. Cookies are small pieces of information stored on your device to allow the App to recognize you when you visit. They collect statistical data about your browsing actions and patterns without identifying you as an individual.
We use both session cookies (stored only during a single browser session and deleted when you close your browser) and persistent cookies (which remain on your device for an extended period to remember you and track your interests).
Our services gather certain information automatically and store it in log files, including IP addresses, browser type, ISP, referring/exit pages, operating system, and date/time stamps. This information is used to administer and improve performance, diagnose server problems, and ensure security.
We may allow other companies to serve advertisements to you. In the course of serving advertisements or optimizing services, we may allow authorized third parties to place or recognize a unique cookie on your browser.
By continuing to use our App, you are agreeing to the use of cookies and similar technologies for the purposes described here. You can disable cookies via browser settings, though some features may be limited.
Security
PEBBLE MEDIA INC takes reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no method of electronic transmission or storage is fully secure, and we cannot guarantee absolute security.
Push Notifications
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications, and other related messages, if you have agreed to such notifications.
You can deactivate these notifications at any time by changing your notification settings on your device.
Does PEBBLE MEDIA INC Sell Personal Data?
PEBBLE MEDIA INC does not, and will not, provide your personal data in direct exchange for money. In the literal sense, PEBBLE MEDIA INC does not sell your data.
However, we have disclosed some categories of personal data to third parties for business purposes as explained under "Use of Information." To the extent this practice is interpreted to constitute a "sale" under the CCPA, please contact us at apps@pebblemedia.net to exercise your right to withdraw consent on sharing your personal data with third parties.
Your Rights — EEA Residents
We process and answer your requests without undue delay. In cases of complexity, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
Right to Access GDPR
Request access to the data we process on you, including purposes, categories, recipients, and storage periods. You may also obtain a copy of the personal data undergoing processing.
Right to Object GDPR
Object to processing based on legitimate interests (Article 6(1)(f) GDPR) or for direct marketing purposes at any time. We will cease processing unless compelling legitimate grounds override your interests.
Right to Rectification GDPR
Have inaccurate personal data rectified.
Right to Restriction GDPR
Obtain restriction of processing in certain circumstances. Where restriction applies, we only process your data with your consent or for the establishment, exercise, or defense of a legal claim.
Right to Withdraw Consent GDPR
Withdraw consent at any time. Withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal.
Right to Data Portability GDPR
Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller where processing is based on consent or contract performance.
Your Rights — California Residents
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you in writing. Any disclosures will cover the 12-month period preceding the request's receipt.
Right to Opt Out CCPA
Each California resident can request any business to stop sharing personal information with third parties.
Right to Be Informed CCPA
You have a right to be informed about what categories of personal data we collect and the purpose of collection. This information is freely available in this Privacy Policy.
Right to Disclosure CCPA
Request disclosure of personal data collected in the past 12 months, including categories, sources, purposes, and third parties with whom it was shared. You may make this request for free, twice per year.
Right to Deletion CCPA
Request deletion of personal data collected in the past 12 months. Some data may be retained where required by law or necessary to provide services, detect security issues, or comply with legal obligations.
Right to Equal Services CCPA
We will not discriminate against you for exercising your CCPA rights — including denying the App, charging different prices, or providing different quality of service.
Data Deletion Request CCPA
Contact us at apps@pebblemedia.net to request erasure of your personal data when it is no longer necessary for us to retain it, unless retention is required by applicable laws.
To exercise any of your rights, contact us at apps@pebblemedia.net. We will verify your identity before processing your request using matching data in our systems.
Contact
For any questions, requests, or concerns related to this Privacy Policy, please reach out to us directly: