Privacy Policy

Homa Games Privacy Policy

Effective Date: February 21, 2019

Hydrane SAS (collectively, “Homa”, “us”, “our” or “we”) provides this Privacy Policy (this “Policy”) to describe the types of information we collect online and the ways we collect, store, use, and manage these information, including personal information, and data that our users (“users”, “your” or “you”) provide or we collect in connection with your activity on the Homa website available at http://homagames.com/ and any Homa game provided on a mobile platform (each a “Service,” collectively, the “Services”).

The Data Controller of the data processing concerned by this Privacy Policy is: Hydrane SAS, 76, rue Faubourg Saint-Denis, 75010 Paris

Please note that the scope of this Policy is limited to information and data collected or received by Homa through your use of the Services. Homa is not responsible for the actions of individuals with no relationship to Homa or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

Information and Data We Collect from You

Personal Data You Provide When Visiting the Homa website
- We collect personal data that you provide on the Homa website when you use our website Service. This could include:
- contact Information such as your name, address, the browser settings

Personal Data You Provide When Playing our games
When you play our games, we collect information that helps us identify your device, such as:
- the technical features of your terminal equipment and software used by you, such as the browser settings, the installed plug-ins, the time zone, the screen size of your device, unique device ID, Advertising ID*, device type, the type and version of your operating system (“OS”), and your general (city/country) location (based on your IP address).
- Gameplay data - session time, in-app purchases (provided that we never receive your payment or credit card information), resource events such as the acquisition or spend of Game virtual currencies by you, progression events that are used to mark your progress or movement in the Game, Install timestamp: it is the timestamp of the first event received from the app.
- We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings by going to the settings for the app itself.

Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking.

Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

Opt-Out of interest based advertising
On Apple, you can opt out of it by choosing “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Legal Base for Processing

Under the data protection laws applicable, Homa must have a legal basis to process your personal data. The legal basis that applies in a particular instance will depend on the specific purposes for which Homa is processing your personal data:
- In certain cases, Homa will ask for your consent to collect and process your personal data. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “Your Privacy Rights” section. or by opting-out in the settings of the app. Please note that the withdrawal of consent will not affect processing which has already occurred.
- In other instances, the processing of your Personal Data may be necessary in order to comply with any applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.

How We Use Your Information

Homa’s primary goals in using your information are to deliver services and games to you, based on your acceptance of our terms and conditions.
With your consent, we will also collect your information to troubleshoot, improve and optimize our services and games, contact you, conduct research and create reports for internal use to make sure we provide you with the best experience.

In addition, we use your information, with your consent, to promote our services and Games in our Apps and also in other publisher’s apps and to display third-party advertisements to you. Such advertisements allow us to offer you our Services for free. We use information collected through our service and games, with your consent, for purposes described in this Policy or disclosed to you in connection with our service. For example, we may use your information to:
- Understand you and your preferences and provide you with new game content and services, tailor our products
- Provide game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Games, and administering the Games.
- Respond to your comments and questions and provide customer service
- Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by Homa and our selected partners
- Conduct and administer contests promoted by Homa
- Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services
- Deliver advertisements and promotional information to you in our Apps
- Cross promote our Apps and services, meaning we may promote one of our Apps while you are playing a different App of ours
- Analyze gameplay data, improve the content and track potential problems or trends with our Games and services, or to test our new game features and content

Use of Your Information by Others

Our Services contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device-related data and information on our behalf. The third parties may have access to and collect data and information about you. Such information includes the following:
- Application usage, access and session times
- Your viewing of and interactions with advertising or the purpose of providing their services, including, for example, enabling, providing and delivering advertising
- Device make, model and operating system;
- Device properties related to screen size & orientation, audio volume and battery;
- Carrier;
- Operating system;
- Name and properties of mobile application through which a consumer interacts with the Services;
- Country, time zone and locale settings (country and preferred language)
- Network connection type and speed;
IP Address;
- Internet browser user-agent used to access the Services
- Identifier for advertisers (IDFA).

Specific Provisions for EU Individuals

Accessing and Correcting Your Personal Information. At any time, you may contact Homa at the address provided in the “Contact Homa Games” section herein and request to access the personal data that Homa holds about you. Homa may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide Homa with the necessary information to correct it.

Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

Right to Make Complaint: if you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at dpo@homagames.com or write to us at the address set forth in the “Contact Homa Games” section. We will look into your request and make good faith efforts to resolve any concern you may have.

Security and confidentiality. As your privacy is very important to us, we have implemented number of physical, technical and operational security measures to prevent unauthorized access, use, alteration or disclosure of your data. Although we take reasonable measures to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access.
To notify the Company about any security vulnerability or potential data breach, please contact us at: dpo@homagames.com, and we will take the appropriate measures to address such incident, as deemed necessary.

Data Retention. Homa retains your personal data for as long as needed to provide you Services, unless we are required by law to delete or if Homa accepts your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Our Policy Regarding Children. We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.

Transfer of Personal Data Outside Your Country. We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.

Lawful Basis for Processing. On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.
If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.

For questions about data processing, please contact our Data Protection Officer. Visit the “Contact Homa Games” section below for contact information.

Changes to This Policy. We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if Homa needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

Contact Homa Games

Homa’s Data Protection Officer

You may contact Homa’s Data Protection Officer at contact@homagames.com or the address below for further information.
Homa Games
76 Rue du Faubourg Saint-Denis
75010 Paris
France

Homa’s EU Representative

You may contact Homa’s EU representative at the address below.

Homa Games
76 Rue du Faubourg Saint-Denis
75010 Paris
France