PRIVACY AND COOKIES POLICY

Last Updated: May 24, 2018

Disrapptive Ltd ("Disrapptive") understands and respects the importance of your privacy. This privacy and cookies policy ("Privacy Policy") explains how Disrapptive and its third party marketing and advertising partners collect, use, process and share information about you, and how you can exercise your privacy rights.

Disrapptive collects, stores, and uses your personal information as a data controller in connection with Disrapptive's products, services and websites (together "Disrapptive Services") according to this Privacy Policy.

All Disrapptive Services are governed by this Privacy Policy and also by the Terms of Service. By downloading, accessing and/or playing our apps and games, or interacting with our website and the rest of Disrapptive Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to Disrapptive's and our advertising partners' use of your data for targeted advertising purposes.

Disrapptive reserves the right to update or alter this Privacy Policy from time to time without notice to you. If Disrapptive makes any changes to this Privacy Policy, Disrapptive will change the "Last Updated" date above. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

1.- What information does Disrapptive collect?

The information that Disrapptive may collect about you through the Disrapptive Services broadly falls into the following categories: 

(i) Information that you provide voluntarily. Such as any information you submit to our customer service via email;

(ii) Information that Disrapptive collects automatically. Information from you and/or your device such as: data and analytics about your use of the Disrapptive Services, your IP address and device identifiers such as your Advertising ID, your device type, operating system that you use, device model, device maker or screen size.

Advertising ID means Apple Identifier for Advertisers ("IDFA") on Apple and Google Advertising Identity ("GAID"). Advertising IDs are non-permanent, non-personal identifiers.

Some of this information may be collected using cookies and/or similar technologies (suc as software development kits).

(iii) Information we obtain from third party sources: information from social media platforms, third party service providers and advertising partners.

(iv) No special categories of information. We do not request or intend to collect any "special categories of information" such as any information of race, health, political opinions, religion, sexual preferences or orientation.

Disrapptive uses Google Analytics. Please read "How Google uses data when you use our partners' sites or apps"

2.- How does Disrapptive Use your information collected?

Disrapptive will use your personal information for a number of purposes including the following:

(i) To provide and operate the Disrapptive Services such as provide you with the correct version of our apps and/or games.

(ii) To improve the Disrapptive Services: to respond to your customer support requests, to fix bugs from the Disrapptive Services, to detect and prevent illegal activities, to track apps and/or games installs or to carry out research.

(iii) To personalise the Disrapptive Services.

(iv) For promotional activities including advertising and marketing.

(v) Other such as: to comply with legal obligations, exercise legal rights, to prevent and/or detect fraud.

3.- Advertising

We may use advertising to fund the Disrapptive Services and to make our apps and/or games available for free.

To enable us to show in-app/game ads we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our apps and games and on third party properties. You can control and limit our use of your advertising ID in your device settings. We do blacklist certain category of ads.

Advertising IDs are used by the ad networks with for a number of purposes (please refer to the Privacy policies of our advertising partners Google and Amazon).

Please do not use the Disrapptive Services, if you want to be certain that advertisements are not displayed to you.

4.- Legal basis for usage of personal data

Where we intend to use your personal data, we rely on the following legal grounds:

(i) Performance of a contract: We may need to collect and use your personal information to enter into a contract you or to perform a contract that you have with us.

(ii) Legitimate interests such as serve interest based advertisements to you.

(iii) Compliance with a legal obligation such as records relating to tax.

(iv) Consent: You may be asked to provide your consent in connection with certain services that we offer such customer service or marketing purposes.

5.- Who does Disrapptive share personal information with?

Disrapptive may share your personal information to the following categories of recipients:

(i) Third party services providers and partners data processors with your consent or where Disrapptive needs to do so in order to provide Disrapptive Services.

(ii) Disrapptive will keep your information confidential except where disclosure is required or permitted by law and is necessary to address potential or actual injury with Disrapptive's rights, protect your safety or the safety of others, combat fraud and/or comply with a legal process such as any competent law enforcement body, regulatory, government agency or court.

(iii) Disrapptive may also disclose your personal data to third parties in connection with a merger, acquisition, the sale of all or a portion of Disrapptive's assets or other corporate change. Disrapptive will make reasonable efforts to notify you of such disclosure in a reasonable manner.

(iv) To any other person with your consent to the disclosure.

6.- Cookies and similar tracking technologies

The Disrapptive Services may use cookies and other technologies such as hardware-based device identifiers in order to improve your user experience by enabling to identify your device and distinguishing you from other users of Disrapptive Services.

A cookie is a piece of record-keeping information in the form of a text file that is placed on a user's device by a web server.

You can accept or decline cookies at any time by accessing the preference panel from your browser's main menu; however, disabling cookies may affect your ability to use the Services.

7.- How long will Disrapptive keep my personal information?

Disrapptive only keeps the collected data we collect from you where we have an ongoing legitimate business need to do so such as to provide you with the Disrapptive Services you have requested, applicable legal, tax or accounting requirements.

8.- Security

We use appropriate technical and organisational measures designed to protect personal information that we collect and process about you.

Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.

9.- International Data Transfers

Where you are submiting personal data from within the European Economic Area ("EEA"), such information may be transferred to countries outside the EEA. If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected. It includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.

10. Your Data Protection Rights

You have the following data protection rights:

(i) To access,  correct, update, request, deletion or portability of your personal information. You may do so by contacting us using the details at "Access to Your Personal Data" heading below.

(ii) To object to processing of your personal information ask us to restrict processing of your personal information. You may do so by contacting us using the details at "Access to Your Personal Data" heading below.

(iii) If we are processing your personal information with your consent, you can withdraw your consent at any time. Again you may do so by contacting us using the details at "Access to Your Personal Data" heading below.

(iv) You have the right to complain to a data protection authority about our collection and use of your personal information.

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. 

11.- Age Limit

When we collect personal information we do not know the age of our apps users and/or games players. If we learn that we has inadvertently gathered personal information from a child under 13 years old, we will take reasonable measures to promptly erase such personal information. If you are aged under 16, please get your parent/guardian's permission before you provide personal data to Disrapptive. Users without this consent are not allowed to provide Disrapptive with personal data. If a parent or guardian becomes aware that his or her child has provided Disrapptive with personal data without their consent, he or she should contact Disrapptive at privacy@disrapptive.com. Disrapptive will delete such personal data from its files within a reasonable time.

12.- Third Party Terms and Conditions

Please note that you access to and use of the Services may be subject to certain third party services and Disrapptive does not accept any responsibility or liability for these third party services terms and conditions and their use of your personal data.

13.- Access to Your Personal Data

Data controller: Disrapptive Ltd, 20-22 Wenlock Road, London N1 7GU, United Kingdom. Email: privacy@disrapptive.com

The Data Protection law gives you the right to check that your personal data is being processed lawfully ("subject access right"). Your subject access right can be exercised in accordance with the law. Any subject access request must be made in writing to: Disrapptive Ltd, Legal, 20-22 Wenlock Road, London N1 7GU, United Kingdom.

Disrapptive makes good faith efforts to enable you to review, update and have any inaccuracies corrected of the personal information Disrapptive's holds about you. Disrapptive will required you to prove your identity and Disrapptive will use reasonable efforts to supply, correct or delete personal data about you on our files.

If you have any questions or comments about this Privacy Policy please contact Disrapptive at privacy@disrapptive.com