Last Revised: December 2023
Icy Ghost Ltd. and its subsidiaries. (collectively, “Icy Ghost”, “we”, “our” or “us”) develops, publishes and operates games for mobile environments (“Games”), as well as mobile applications (“App”). We also operate the website www.icyghost.com and its subdomains.
This Privacy Notice applies whenever you visit our websites, play the games that link to this Notice, or otherwise access any of our other products and/or services, mobile applications, or any other applicable platforms and/or devices (the “Service”). By using the Service, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want us to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, please discontinue and avoid using our Services.
We collect four main categories of data, to fulfill one or more of its functions and activities, as described in this Privacy Notice.
A. Cookies and Automatically Collected Data
Cookies:
Icy Ghost, our service providers, and third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as improving the quality of our Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies.
For more information on how you can opt-out of or disable cookies, please see the Your Rights section below.
Other Technologies:
We, our service providers, and third parties may also employ other technologies including (i) web beacons, which may allow us to know if a certain page was visited or whether an email was opened; (ii) tracking pixels, which may allow us or our advertising partners to advertise more efficiently and effectively by recognizing your device(s) on, off, and across different services and devices and identifying the source of a new installation; and (iii) local shared objects, also known as flash cookies, which may help us to reduce fraud, remember your in-game preferences, and speed up load times.
We, our service providers, and third parties may use cookies and other technologies described to collect information about your device, browser, and/or activities, such as:
We might connect this information with your social network ID. We may use Google Analytics, Facebook Audience Insights, and/or other technologies that collect information about your behavior and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data by going to http://tool.google.com/dlpage/gaoptout.
B. Data That You Share with Us Directly
When you use our Service (including through a social network), you may voluntarily give us information directly in a number of ways, including:
The information you share with us may include, for example:
C. Personal Data That We Get from Others
We may collect or receive information about you from other sources like third-party applications, such as an app store, third-party login service, and social networks on which you play our games. We may use this information along with information you provide us directly in a number of ways as described in this Privacy Notice, for example, to serve you advertising tailored to your interests.
For example, we may collect and store some or all of the following information shared by the third-party application:
If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice. If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.
D. Data Generated While Playing Our Games
When playing our games, certain data is generated, such as information about game sessions (including timing, number and length), diagnostic data (i.e. crash data and game performance data), progress in the game (e.g, level and achievements), items collected, and other choices you make in the game (like the way you interact with certain features or pop-ups).
Also, When someone interacts with our Services, we may collect or generate technical data about them. We collect or generate such data either independently or, with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions), non-identifying data regarding a device, operating system, browser or App version, mobile carrier, local and language settings.
We do not use such data to learn a person’s true identity or contact details, but mainly to have a better understanding on how our users typically use and engage with our Services. The use of such data also helps us and our partners to deliver tailored advertisements and content, and to improve the overall performance and your user experience of our Services.
E. Payment Information
In-game purchases are made through a third party platform or store (for example, Apple, or Google). We will not collect or store your financial data, e.g. your credit card numbers or bank account. However, we may receive your non-financial Personal Data related to the purchase, such as your name, billing address, email address and the items purchased, in order to fulfill your purchase and for our accounting purposes.
We may use personal data for a variety of business purposes as described in this Privacy Notice, including to fulfill our contractual obligations, complete transactions you request, comply with law and regulatory obligations, and for other legitimate business purposes, such as to:
Your interactions with our Service may be tracked across platforms and/or devices.
We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates. The circumstances in which we share data are as followed:
A. Service Providers
We may engage selected third party companies, contractors and individuals to perform services complementary to our own (“Service Providers”) to support the Service, for example, to assist us with processing payments, analyzing data, optimizing game play and enhancing player experience, session recording, monitoring services, and managing and delivering contextual and tailored advertisements.
B. Friends and Other Icy Ghost Players
In some Icy Ghost games, if you play or register through a social network (for example, Facebook Connect), your social network friends may see your name, profile photo, and details about your gameplay (like your game progression, “game name” or rewards earned).
C. Advertising, Including Third-Party and Tailored Advertising
We may have advertising on our Service. When advertisers or ad networks place ads in our Service, they may collect, or we may share the following types of information from within our Service:
The information collected may be used to:
Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time. Please note, after clicking on a third-party advertisement, you may no longer be on a site hosted by Icy Ghost, or in an application owned by Icy Ghost.
D. Sale or Merger
In the event that Icy Ghost undertakes efforts to engage in a business transition (including but not limited to a merger with and/or acquisition by another company, or sale of all or part of its assets), we may disclose relevant information we have, including personal data, to the successor organization in the transition. We will make reasonable efforts as described in this Privacy Notice to let you know of the business transition before transferring personal data to the extent required by law.
E. Legal Compliance
We may share personal data in the following circumstances:
Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Icy Ghost processes about you, for example to request:
You may also have the right to object to certain processing, including to opt out of targeted advertising.
To submit a request, contact us via email at support@icyghost.com.
A. Manage Information We Get from Platforms
To manage the information we receive about you from a third-party platform where you play our games, like Facebook, Apple, etc. you will need to follow the instructions for the relevant third-party application(s) for updating your information and changing your privacy settings.
B. Opting Out of Facebook Messages
If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.
C. Opting Out of Push Notifications
When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings”.
D. Opting Out of Third-Party Tailored Advertising
Our games serve third-party tailored ads. We provide a toggle button to disable them. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to employees or Service Providers that we do not manage. Any information you provide to sites, applications or services advertised through our Services will be covered by the applicable privacy policies specified therein. Please be sure to read the privacy policies of any third-party applications, services and sites that you visit or provide permission to access your information. It is those third parties’ responsibility to protect any information you give them, so we will not be held liable for their use of your personally identifying information.
In addition, if you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the advertising identifier (like an IDFA) from your device’s Settings, which will prevent continued use of existing behavioral data tied to the previous advertising identifier.
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users), www.youronlinechoices.eu (for European users).
Please note that you may still receive advertisements from Icy Ghost and third parties within our games even if you opt out of tailored advertising; these ads will not be tailored to you.
E. Opting Out of Cookie Tracking
Google uses technologies such as cookies in order to track and analyse the use of our Site and/or an SDK to serve ads within our Games. To learn more about how Google processes data, we recommend you review Google’s policies located at: https://policies.google.com/technologies/partner-sites . For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout .
On Icy Ghost websites that use cookies, you can also click on the “Cookies Settings” link, to choose your preferences.
Our games are available to individuals who are sixteen (16) years of age and over. We reserve the right to request proof of age or parental consent at any stage. We may block users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.
If you believe that your child has submitted personal data to Icy Ghost, please contact us at support@icyghost.com.
A. International Transfers
Icy Ghost may send, access, use, and/or store personal data outside of the country or region where you live including, for example, to the United States and Israel. We may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice.
Laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise make efforts to ensure that such transfers meet applicable local legal requirements.
By using the Service, you consent to the transfer of personal data outside of the country or region where you live. If you do not consent to such transfer, please do not use our Service.
B. Retention
We may retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
C. Security
We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.
D. Links to Other Sites/Apps
The Service may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app, and Icy Ghost is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.
E. Updates
We reserve the right to amend the Privacy Notice from time to time, and we encourage you to consult the Privacy Notice regularly for changes. If we make material changes to our Privacy Notice, we will tell you by placing a notice on Icyghost.com or its equivalent in-game. We may supplement this process by placing notices on game blogs, social network pages, and/or forums.
F. How to Contact Us
If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact us at Support@Icyghost.com or at 8 HaMelacha St. Tel Aviv 6721508 Israel.
If you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live.