Privacy Notice

To perform our contract with you, we may process your data as necessary to:

• create and maintain an account for you in our Games or other Services where applicable,
• enable you to play our Games or use our other Services,
• provide the correct version of our Games or other Services to you (for example, by selecting an appropriate language version for you),
• where available, enable you to communicate with other users in our Games or other Services (for example, by providing or managing chat, communities, forums, or other similar features within the Services or on third-party platforms),
• send you service-related communications (for example, technical notices, security alerts, or administrative messages), or
• verify and fulfill your purchases or other transactions in our Games or other Services.

Based on our legitimate interest to make our Services the best they can be, we may process your data to:

• operate and maintain our Services (for example, by making sure our Services are secure and function as intended),
• troubleshoot or debug any bugs, errors, or other issues in our Services,
• measure and analyze the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations),
• create data that is not identifiable to you (for example, aggregate data), which we may then use and share freely,
• conduct surveys or other research to learn more about our users, or
• improve our current Services or develop new Services.

Based on our legitimate interest to make sure you have the best possible user experience in our Games, we may process your data to:

• personalize your gameplay experience in our Games based on your activity,
• provide you with offers and rewards in our Games based on your activity,
• where available, enable your gameplay across multiple devices (for example, by allowing you to connect a third-party account with our Games for that purpose),
• where available, provide social features (for example, clans, matchmaking, or leaderboards) or competitions, promotions, or events in our Games or other Services,
• handle your support requests or otherwise manage our relationship with you, or
• send you service-related communications (for example, technical notices, security alerts, or administrative messages).

Based on our legitimate interest to make sure our Services are a fair and safe environment for all users or, where applicable, based on a related legal obligation, we may process your data to:

• ensure that you have access to content and features which are appropriate for you, for example based on your age,
• moderate and monitor the use of our Games or other Services (including any messages sent through the Services), either automatically or manually, or
• ensure that our Terms of Service and, in particular, our Code of Conduct are followed.

Based on our legitimate interest to promote our Services and to make sure we reach interested audiences, we (and our advertising partners acting on our behalf) may process your data to:

• keep track of installations of our Games (including the source of each install),
• measure, analyze, and improve the effectiveness of our advertising (including our advertising outside of our Services),
• send you communications about offers, rewards, events, or other news related to our Services or other operations,
• show or not show our ads to you based on your activity (including by limiting the number of times you see our ads), or
• advertise our Games or other Services to audiences who our advertising partners believe have interests similar to yours.

Based on our legitimate interest to provide you with relevant ads in our Games and to fund our Services so that we can keep providing them to you, we may process your data to:

• show ads to you in our Games, either from us or our advertising partners,
• keep track of your activity in our Games to learn about your interests and improve the advertising in our Games, or
• personalize the ads you see in our Games to make them more relevant to you.

Based on our legitimate interest to safeguard our operations, we may process your data to:

• detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior,
• audit our operations or processes (for example, to verify that they function as intended and according to regulatory or contractual requirements), or
• establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations.

With your consent, we may process your data:

• to share it with our advertising partners (specified when asking for your consent, including for example any of those listed here) for their independent use under their own privacy policies, which may include creating a personalized ads profile about you, selecting personalized ads for you, measuring ad performance, generating audience insights, and other uses,
• to send you newsletters or other similar communications if you have subscribed to them (for example, when creating an account with us or through a subscription form on our Websites), or
• for other purposes explained to you when we ask for your consent (for example, using your GPS location to provide location-based experiences).

Finally, we may process your data as necessary to:

• comply with legal obligations which we believe apply to us (including accounting and tax requirements, requirements to limit access to our Services, and requirements to provide information to competent authorities upon due request) or
• protect your vital interests or the vital interests of another person.

In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.

We do not use your data to make automated decisions which significantly affect you. By an “automated decision,” we mean a decision made by an information system without any human intervention.

Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses and other identifiers. An “Advertising ID” is an alphanumeric string of digits typically provided by a device or its operating system. It is consistent across applications installed on the device, even if those applications are from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Equivalent identifiers may exist on other operating systems and devices.

Advertising IDs are used for interest-based advertising and other advertising related purposes as a means of establishing a pseudonymous identity which remains constant from one application or other property to another. You can control the extent to which your Advertising ID is used in this manner. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can choose to not “allow apps to request to track” on iOS devices or to “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them to your desired state on each of your devices individually. Our Games may offer additional options to opt in to or out of advertising related uses of your data. Where available, these options are found in the game settings, and you may be prompted to select your preferences. It may take some time for your selection or any updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads, but the ads you see may be less relevant to you.

For more information on mobile privacy settings, we encourage you to refer to resources such as the Network Advertising Initiative’s guide on mobile device opt outs (link). However, please consider that we do not maintain those resources and cannot guarantee their accuracy.

When you see ads in our Games, we may share your Advertising ID and IP address, along with information about the game and your device, with our advertising partners. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed here.

When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID and data about user engagement with our Services, have determined that you may be interested in our Services. Ad networks may also use your data to:

• limit the number of times you see our ads,
• inform users who have previously played our Games about new content, updates, or other news related to those Games, or
• refrain from showing our ads to users who already play the Game being advertised.

In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services.

For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as views, clicks, or installs generated by an ad. This measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as conversion pixels inserted into ads. It is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.

We may process the following data relating to you:

• your name, email address, or other contact information if you have provided them to us (for example, when creating an account with us or subscribing to our communications),
• your age or information about when you were born,
• online identifiers such as your in-game alias, IP address, identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID,
• technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
• your coarse location (for example, country, state, or city), inferred from your IP address,
• information about your use of the Services (for example, information about your progress or purchases in our Games or other Services, your use of an account you have with us, your visits to our Websites, or your interactions with ads in our Games),
• information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
• crash logs or other information related to bugs, errors, or other issues you encounter in our Services,
• inferences we make based on your activity in our Services (for example, about the content you might enjoy),
• messages or other communications you send to us or through the Services or related communities managed by us on third-party platforms (for example, your chat messages in our Games, emails you send to our support team, or messages you post to official community groups for the Games),
• if you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends information to provide social features),
• if you make purchases in our Games or other Services, information we receive from third-party payment service providers to validate those purchases (note that we do not receive your credit card or other payment method information when you make purchases in our Services),
• if you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications,
• if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
• information about your choices regarding your data (for example, any consents you may have given or withdrawn),
• any other information you choose to submit to us through our Services or otherwise, and
• with your consent, other information explained to you when asking for your consent (for example, your GPS location for location-based experiences).

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

We may collect data relating to you from the following sources:

• directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
• directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
• companies that distribute or publish our Games, which may include both companies in the Rovio group and third parties (for example, platform operators),
• if you interact with ads in our Games or our ads outside of our Services (for example, on third-party websites or applications), from our advertising partners involved in the delivery and measurement of those ads,
• if you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
• if you participate in official community groups for our Games on third-party platforms, from those community groups or the platform provider,
• if you make purchases in our Games or other Services, from the third-party payment service provider involved in those transactions, or
• with your consent, from other sources explained to you when asking for your consent.

Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games (or to utilize the privacy settings of those third-party services to control the extent to which your data is shared to us), to use options provided to you in our Games to manage your preferences regarding the use of your data for advertising purposes, to use your device settings to reset or control the use of your Advertising ID or to toggle features such as push notifications or location tracking, or disable some or all cookies from your browser settings. At the same time, please be aware that our Websites may not respond to “Do Not Track” signals in HTTP headers.

We may share your data with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:

• other companies in the Rovio group, for example where they help us develop or operate our Games or other Services,
• persons or companies outside of the Rovio group that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services),
• payment service providers that facilitate payments for purchases made in our Games or Services and may process your data (including your payment method information) independently of us,
• other partners we work with while providing the Services (who may process your data independently of us), including advertising partners and others listed here,
• prospective or actual buyers (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
• competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation,
• any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
• with any other person or entity with your consent.

In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards. You should expect this kind of information to be publicly available and not submit or make available any information which you wish to remain private.

We may transfer your data outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies or the service providers we use to provide the Services may be located outside of the EU and the EEA. These countries may have data protection laws that differ from the laws of your home country. In these cases, we will provide appropriate safeguards to protect your personal data. This may include applying the standard contractual clauses approved by the European Commission for transfers of personal data or other safeguards recognized by applicable laws and regulations. Upon request, we can provide you a copy of the European Commission’s standard contractual clauses and further details on the applicable safeguards.

If we are processing your data, you have the right to:

• access, correct, or request the deletion of your data,
• request us to restrict our processing of your data,
• object to our processing of your data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
• where technically feasible, request a copy of the personal data you have provided to us in machine-readable format.

Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Where applicable, you may manage your advertising preferences in the game settings under “Terms & Privacy” or a similarly named option. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.

To access your data in our Games or to request its deletion, please use the automatic tools provided in our Games. You will find them in the game settings under “Terms & Privacy” or a similarly named option. On the same page, you can also opt out of our personalized offers, where applicable. These tools are specific to each game, which means you should submit your request in each game separately. Please use these tools to submit requests. This helps us validate, process, and fulfill your request more quickly and reliably.

If you have created an account with us for use across our Games, automatic tools to access data associated with the account or to request its deletion are provided through the account settings. These tools are specific to the account used across our Games, which is separate from your account in each individual Game. This means that you should, where you wish to do so, request access or deletion for the Games you play separately as described above. Please submit requests through the account settings. This helps us validate, process, and fulfill your request more quickly and reliably.

To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.

To exercise any of your rights, you may also contact us at privacy@rovio.com. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations.

Should you be unsatisfied with how we fulfilled your request, you may appeal the decision you have received using the internal appeal process we have established. To do so, please submit a new request after you have received a decision from us on your earlier request. In the new request, you should state that you wish to appeal an earlier decision and that you are asking for the matter to be considered in accordance with our internal appeal process. You may be asked to provide information about the earlier request and decision that reasonably allows us to identify them. Once you have submitted the appeal and provided information to adequately identify the earlier request and decision, we will process your appeal as soon as practicable.

Finally, you always have the right to lodge a complaint with your local data protection authority (such as the Office of the Data Protection Ombudsman in Finland) regarding our processing of your data. However, we ask that you reach out to us first to allow us to address your concerns.

Note that if your request relates to information about a payment method or other transactional data about a purchase made in our Games or other Services, you should directly contact the payment service provider through which you made the payment, as they will have processed the transaction independently of us.