Candywriter, LLC Privacy Policy
Last Updated: January 7, 2021
I. Our Commitment to Privacy
Candywriter, LLC ("we" or "Candywriter") is serious about your privacy
and data rights. We are committed to maintaining a relationship of
trust and transparency with you. This Privacy Policy is written in
plain language to make it easy to understand how we collect, use,
store, and share information that is identifiable to you ("Personal
Data") when you access our websites, mobile applications, games,
forums, or other services (collectively the "Services"). By using the
Services, you consent to this Privacy Policy.
II. Controller and Representative
Candywriter is controller according to Art 4 No. 7 GDPR for the
Personal Data we obtain regarding the processes described below.
When you download our products from the Apple App Store and Google
Play Store please note that Apple Inc. and Google Inc. process your
personal data with regard to the download/purchase as an individual
controller. Candywriter has no influence on the purposes and means of
such processing. Please refer to the privacy information as provided
by those companies.
Our European representative according to Art. 27 GDPR is
Rickert Rechtsanwaltsgesellschaft mbH, Colmantstrasse 15, 53115 Bonn,
Germany. E-Mail: info@rickert.law, Tel. +49 228 748980.
III. What Do We Collect?
A. Information You Provide to Us Directly. We collect the information
you give us, which may include your:
• Name
• E-mail address
• Your ID from various Social Networks to improve your social gaming experience (including Apple iTunes, and Google Play)
• Your messages to us or the Services (customer support requests)
• Information that helps us verify it’s actually you, prevent fraud, and improve our Services
B. Automatically Collected Information. We collect other information
automatically from your device through queries and SDK's when you use
our Services, including:
• IP Address

• General Location Data (to help identify regional language and improve social gameplay)
• Device information (such as device type, model, operating system, browser version, or unique device identifiers for checking device compatibility and IDFA or GAID)
IDFA means Identifier for Advertisers on Apple and GAID means Google
Advertising Identifier. These unique identifiers are non-permanent and
non-personal, meaning they do not contain sensitive information about
you but do allow for consistency across all apps and cross-app
tracking. You can opt-out of sharing your device identifier by
updating the settings on your device.
C. No "Special Categories" Collection. We do not collect any "special
categories of information" from you. That is racial data or
information regarding ethnic origin, sexual practices or orientation,
political opinions, religious or philosophical beliefs, union
membership, or health data.
IV. How Do We Use this Data and Why?
We use or may use your Personal Data and non-personal information to:
A. Provide you with our Services.
• Operate, maintain, and improve our Services (Art. 6 I b GDPR).
• Provide customer support for the Services (Art. 6 I b GDPR).
• Resolve disputes (Art. 6 I f GDPR).
• Provide you with the appropriate version of the Services (Art. 6 I b GDPR).
• Identify, fix, and troubleshoot bugs and service errors (Art. 6 I b GDPR).
• Develop new services (Art. 6 I f GDPR for existing apps and Art. 6 I a GDPR for new apps).
B. Secure our Services.
• Identify and/or prevent fraud (Art 6 I f GDPR).
• Identify and/or prevent illegal activities or cheating (Art 6 I f GDPR).
• Verify user identities for customer support communications (Art. 6 I b GDPR).
• Enhance the security of our network and information systems (Art 6 I f GDPR).
C. Personalize our Services or Offer Promotions.
• Provide you with personalized game and other offers (including advertisements).
• Communicate with you regarding your areas of interest and

respond to your requests.
• Serve and measure the effectiveness of our marketing campaigns.
• Perform analytics for internal marketing and demographic studies to improve or personalize the Services.
• Save your game progress and stats.
D. Legal/Other.
• Comply with legal obligations (Art 6 I f GDPR).
• Exercise, establish, or defend our legal rights (Art 6 I f GDPR).
V. Advertising
Advertising is one of the ways of funding our Services and enables us
to make our games available free of charge. In our games, we show our
own ads and also ads from third parties. We also advertise outside of
our Services on third-party properties such as websites or
applications. This section provides more information on how we may use
your data for advertising purposes, and how you can control the use of
your data for these purposes.
Mobile advertising relies on the use of certain online identifiers, in
particular Advertising ID's but also Internet Protocol (IP) addresses
or other identifiers. An "Advertising ID" is an alphanumeric string of
digits provided by the operating system of a device. It is consistent
across applications from different publishers.
Advertising ID's are used for interest-based advertising and other
advertising related purposes. You can control the extent to which your
Advertising ID is used for these purposes. Using the privacy settings
on your device, you can typically reset and/or limit the use of your
Advertising ID. For example, you can "limit ad tracking" on iOS
devices or "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. It
may take some time for your 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.
When you see ads in our games, we may share your Advertising ID and IP
address with our advertising partners. Our advertising partners may
also collect information directly from our games through technologies
such as software development kits (SDK's). 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).

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,
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 ID's 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 ID's or other identifiers are also used for ad
measurement, which involves the collection of metrics such as total
views, clicks, or installs generated by an ad. 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 web beacons 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.
V. Who Do We Share this Data With?
As described below, we will not share your Personal Data with
affiliated or unaffiliated third parties without your consent.
However, we may share non-personal data, including anonymized data, in
accordance with this Privacy Policy. We may share your information,
including Personal Data (aggregated or pseudonymized) to third parties
in the following instances:
A. Third Party Service Providers. We may contract with third parties
to collect or process your information or Personal Data on our behalf
to provide the Services. Our agreements with such third parties
require them to protect the confidentiality and security of your
Personal Data and information in line with this Privacy Policy and the
Data Protection Agreement with each party. The following are our
third-party service providers:
• AdColony (Advertising Network)
• Amazon (Advertising Network)
• AppLovin (Advertising Network)

• AppsFlyer (Attribution/Analytics)
• Chartboost (Advertising Network)
• Facebook (Advertising Network)
• Flurry (Analytics)
• Fyber (Advertising Network)
• GameAnalytics (Advertising Network)
• Google (Advertising Network/Analytics)
• HyprMX (Advertising Network)
• InMobi (Advertising Network)
• IronSource (Advertising Network)
• Mintegral (Advertising Network)
• Smaato (Advertising Network)
• Tapjoy (Advertising Network)
• Unity Ads (Advertising Network)
• Vungle (Advertising Network)
B. Candywriter Affiliated Companies. We may share your information
amongst our subsidiaries, parents, or affiliated companies to improve
our Services and better serve you.
C. A Successor of Acquiring Third Party. If Candywriter is merged with
a third party, acquired, purchased (in full or in part), experiences a
divestiture, reorganization, bankruptcy, or similar event, information
collected under this Privacy Policy may be shared with such third
party as it is our legitimate interest (Art. 6 I f GDPR).
D. As Required by Law. Since Candywriter is based in Florida, United
States, our processing and purposes have to comply with US law and it
is our legitimate interest to do so (Art. 6 I f GDPR). We may disclose
Personal Data if we believe that we are required to do so to:
• Comply with a legal obligation.
• Protect and defend the rights or property of Candywriter, users of the Services, or others.
• Protect the personal safety or vital interest of users of the Services or the public.
• Protect against legal liability.
• Enforce terms of service, policies, or forum/community rules.
• Respond to lawful request by public authorities, including to meet national security or law enforcement requirements.
VI. How do we Store Your Personal Data?
A. Storing your Personal Data. Personal Data we collect, is shared
with us, or is processed under this Privacy Policy may be stored in
the United States or any other country in which we, our subsidiaries/
affiliates, or third-party service providers operate, including
through the use of cloud storage.
The storing of your personal data by us is based on Art. 6 b GDPR

since it is necessary to fulfill the contract (provide you with our
service).
We are working with service providers that are situated in the United
States. Due to the fact that there is no adequacy decision for the US
by the European Commission, a transfer of data to a service partner in
the US require additional appropriate safeguards and are on condition
that enforceable data subject rights and effective legal remedies for
data subjects are available. We have concluded Data Processing
Agreements with our service partners to ensure that they apply the
same level of data protection as we do. However, due to the legal
situation we cannot guarantee that the data subject rights are
enforceable and effective legal remedies are in place regarding the
US-based service providers. This particularly concerns remedies and
enforceability regarding US security and law enforcement agencies
possibly accessing your data.
We therefore require your prior consent by the acceptance of this
Privacy Policy to proceed with the processing of your data. Please
note that – due to our current technical setup – we are unable to
provide you with our services without processing of your data with our
US-based service providers.
VII. Your Privacy Controls
You may assert the following rights free of charge against any person
responsible for the processing of your personal data in accordance
with Art. 4 (7) GDPR, including us, in accordance with the statutory
provisions:
• The right to withdraw your consent (Art. 7 (3) GDPR).
• Right of access: You may request access to your personal information that we process according to Art. 15 GDPR.
• Right to object: You have a right to object for special reasons. You have the right to object to the processing of your personal data at any time for reasons relating to your special situation, which is defined in Art. 6 (1) clause 1 lit. f GDPR. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. The collection of data for the provision of the website and the storage of the log files are absolutely necessary for the operation of the website.
• Right to rectification: If the information concerning you is not (or no longer) accurate, you may request a rectification under Article 16 GDPR. If your data is incomplete, you may request their completion.
• Right to erasure: You can request the erasure of your personal data under Article 17 GDPR.

• Right to restriction of processing: Under Article 18 GDPR, you have the right to request a restriction on the processing of your personal data.
• Right to data portability: In the event that the conditions of Article 20 (1) GDPR are met, you have the right to receive or have a third party receive the data that we process automatically on the basis of your consent or in the performance of a contract. The collection of data for the provision of the website and the storage of the log files are absolutely necessary for the operation of the website. They are, therefore, not based on consent under Article 6 (1) lit. a GDPR or on a contract under Article 6 (1) lit. b GDPR but are justified under Article 6 (1) lit. f GDPR. The conditions of Article 20 (1) GDPR are therefore not met regarding these data.
To assert your rights, please refer to the contact details listed
below under "Contact Us". Our data protection officer is available for
confidential enquiries as well.
Pursuant to Art. 77 et seqq. GDPR, you also have the right to lodge a
complaint about the controller's processing of your personal data with
a supervisory authority responsible for data protection.
VIII. Children Under Age 16
Our Services are not directed, or intended for children under the age
of 16. We do not knowingly collect Personal Data or knowingly use
persistent identifiers to recognize children under the age of 16 over
time and across different websites or online services. If you are
under the age of 16, do not use our Services and do not submit any
information to us. We encourage parents and legal guardians to monitor
their children's Internet usage and to help enforce this Privacy
Policy by instructing their children under the age of 16 never to use
our Services. If you have reason to believe that a child under the age
of 16 has provided Personal Data or personal information to
Candywriter through our Services, please contact us, and we will take
steps to delete that information from our databases as soon as
possible.
IX. Third Party Privacy Practices
This Privacy Policy applies only to Personal Data and information
collected by Candywriter through your use of our Services. Third-party
websites may be accessible through links when using our Services.
These third-party websites are governed by their own privacy policies
and we are not liable or responsible for any content appearing on
those websites or any privacy or security practices for those
websites.
X. Data Retention
We strive to retain only as much Personal Data as is necessary. When

Personal Data is no longer required under this Privacy Policy and no
applicable statutory retention obligation applies, we will delete it
or de-identify it. When it is not commercially reasonable to delete or
de-identify your Personal Data, we will remove your Personal Data from
processing and securely store it until we are able to permanently
delete it.
XI. Updates to Our Privacy Policy
From time to time, we may update this Privacy Policy to maintain our
commitment to privacy. Updates apply going forward, and never
retroactively. When we make changes, we will update the date at the
top of this page and notify if the changes are material. We encourage
you to visit this Privacy Policy frequently to keep current with any
changes.
XII. Contact Us
If you have questions, comments, or concerns about this privacy
policy, please contact us.
Candywriter Attn: Privacy Policy
1521 Alton Rd, Ste 670
Miami Beach, FL 33139
United States
privacy@candywriter.com