Last updated: 16 February 2023
Huippee Oy respects your right to privacy. This Privacy Policy explains how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Policy applies to personal information that we collect through our games, like the mobile games under Huippee Heroes brand (”Games”) and websites, like https://www.huippeeheroes.com/ (”Website”) and other software (“Software”). Games, Software and Website are jointly called the “Services”.
If you use our Services, you agree to this Privacy Policy and processing of your personal information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.
If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy Policy.
What personal information we collect and where?
We collect the following categories of personal information about you through the Services:
- Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details (email address) to register an account with us, to begin playing Games or using our Software or Website, to contact our customer support, to subscribe to marketing communications (like newsletters) from us, and/or to submit enquiries to us and invite your friends to also play our Games or use our Software. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Specifically, the information we collect directly from you may include information like (i) your email address and other contact information; and (ii) other personal information required in order to help you with any queries or support matters you may need assistance with via our customer support services.
- Information that we collect automatically
When you use our Services, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include data about your game or software progress, including an automatically created internal account ID, IP address, device type (platform, device name and model), unique device identification numbers, advertising identifiers, operating system, browser-type, broad geographic location (e.g. country or city-level location), language and other technical information. We may also collect information about how you use the Services and how your device has interacted with our Services, including the Games played, Software used and the pages of our Website accessed.
Collecting this information enables us to better understand the players of our Games, users of our Software and visitors who come to our Website, where they come from, and what content or features on our Games, Software and Website is of interest to them. We use this information for our internal analytics purposes, to prevent fraudulent behaviour in our Services, to improve the quality and relevance of our Services to our users and visitors and we may also use this information to serve interest-based advertising to you.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
- Information that we obtain from third party sources
We may receive personal information about you from third party sources, like sign-in and social networking services. You can invite your friends to log in to our Games or Software using social networking services. You can also purchase additional goods like crystals and coins as an in-app purchase through Google Play and Apple App Store. These services will authenticate your identity and provide you the option to share certain personal information with us (mainly your email if you decide to share that with us).
Why we process your personal information and on what legal basis?
We collect and use your personal information for the following purposes. Our legal basis for collecting and using the personal information is also described below.
- For the performance of the contract between us and you
For the performance of the contract, we collect necessary personal information to
- create accounts, activation and user profiles and allow users to play our Games and use our Software or Services;
- verify and confirm payments;
- provide and deliver products and services you request; and
- send you related information, including confirmations and administrative messages.
- To provide you with optimal Games, Software and Services
To customize and provide you with optimal Games, Software and Services we have your consent or a legitimate interest to collect and process necessary personal information to
- update and develop user activation profiles;
- operate our Games, Software and Services;
- analyse, develop and improve Games, Software, other Services and user experience;
- manage our relationship with you;
- respond to your comments and questions, resolve the problems and provide other kind of customer support;
- analyse, profile and customize your use of the Games, Software and Services;
- provide you our offers in our Games, Software and Services as well as in other web sites and services, or by email;
- send you related information, including technical notices, updates, security alerts, and support and administrative messages;
- enable you to communicate with your friends by inviting them to play our Games or use our Software; and
- link or combine information with other information we get from third parties, to help understand your preferences and provide you with better services.
- Prevent fraud and ensure acceptable use of our Services
To identify, prevent, and investigate fraud and provide a fair, equal and enjoyable game or software usage experience to users, we have a legitimate interest to collect and process necessary personal information to
- analyse use of Games, Software and Services and the behaviour of users to detect frauds and other misbehaviour;
- determine accounts or users connected to fraudulent schemes or other misbehaviour; and
- take actions against fraudulent or misbehaving users.
Please see our Terms of Services https://www.huippeeheroes.com/terms-of-service for instructions on the acceptable use of our Services.
- Show you personalized advertisements
If you have given your consent to show you personalized advertisements (so called behavioural ads) in our Games, Software and Services as well as in other web sites and services, or by email, we will collect and use necessary personal information to
- track the content you access when you use our Games and Software or your device, and other online behaviour;
- use cookies, advertising identifiers, or similar tracking technologies; and
- deliver, enable, target and optimize advertising and promotional information.
If you wish to ”opt out” of targeted advertising, click the information button in one of the advertisements shown through our Games or Software and select to opt out from targeted advertising. You can also opt out from target advertising from your mobile device’s settings. Please note that if you choose to ”opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.
With whom do we share your personal information with?
We may disclose your personal information to the following recipients or categories of recipients:
- Advertising and social media partners who use advertising identifiers, cookies, APIs, and/or SDKs in our Services to enable them to collect and analyse user and device related data and information. These partners are listed below, and they can use your personal information and other data for their own purposes. These partners operate under their own privacy policies. We encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies. The opt-out instructions for these partners’ services are also included in their privacy policies. These are the partners who collect personal information through our Services and use the information according to their own policies:
- In-app advertisements and social media:
- AdMob/Google (Google Corporation)
- Our services providers and subcontractors who process your information only on our behalf and according to our instructions. These partners provide data processing services to us, for example, to provide (i) data hosting, (ii) marketing and advertising services, (iii) customer support, (iv) analytics for Games, Software and Services as well as (v) development and maintenance;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and
- to a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
Cookies and similar tracking technology
Like most games, software and online services, we and our partners use advertising identifiers, cookies and similar tracking technologies. Advertising identifiers, cookies and similar technologies are used by us and our partners to provide our Services to you and to collect data from your device. These technologies allow us and our partners to (i) recognise you and your device; (ii) provide interest-based advertising to you; (iii) prevent fraud, (iv) allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction); (v) allow our payment processors to process your payment instructions; and (vi) enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language (subject to availability). You can limit ad tracking, reset advertising identifiers and disable cookies from your device or browser settings.
You may also see our own advertisements in other games, software and services. If you click such advertisements and install our Game(s) or Software, we may share a device identifier with our partners to verify installs and prevent fraudulent actions.
Please note that we use Google advertising service Google AdMob while providing our Services. This means that third parties may be placing and reading cookies on your browser, or using web beacons to collect information as a result of ad serving on our Services. For more information, please see the link “How Google uses data when you use our partners’ sites or apps” (https://policies.google.com/technologies/partner-sites?hl=en).
How do we keep your personal information secure?
We use appropriate technical and organisational measures designed to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include that only those of our employees, who on behalf of their work are entitled to process personal information, are entitled to use a system containing personal information. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies are in locked premises and can be accessed only by certain pre-designated persons. We also aim to minimize the personal information that we process, for example, our Games or Software do not require you to register an account with your name and other details. Moreover, we use only activation and advertiser identifiers and other more technical information to recognize users.
International data transfers
Our main principle is that personal data is processed within the European Union (EU) or the European Economic Area (EEA).
Nevertheless, our Services is global by nature and therefore your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses (or other similar arrangements) for transfers of personal information between us and our third-party service providers and partners located outside the European Union or European Economic Area.
Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). Unnecessary and outdated personal information will be erased or anonymized in connection with the periodical reviews and also at other times when deemed necessary.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update, request deletion, object to processing or restrict processing of your personal information, you can do so at any time by contacting us. The same applies to portability requests.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. In general, if the personal information processing is based on your consent, you have the right to withdraw your consent to such processing at any time.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. The relevant authority in Finland is the Data Protection Ombudsman (https://www.tietosuoja.fi). However, we request that the matter will be dealt with us in the first instance.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.
Special Note About Children’s Privacy
We comply with all applicable laws that are designed to protect children’s privacy, such as the GDPR and the Children’s Online Privacy Protection Act (“COPPA”).
If you are under 13, we will need to receive a parental consent for you to use our Games, Software and Services.
For clarity, some of our Games or Software are not intended to children under 13 years of age, therefore no one under 13 years of age is allowed to use or access the Games and Software or provide any personal information to us. We do not knowingly collect or solicit personal information from or direct or target behaviourally targeted advertising to anyone under 13 years of age or knowingly allow such persons to use or access our Games and Software. If you are under 13 years of age, please do not send any information about yourself to us including your name, address, telephone number, or email address.
If we learn that we have collected personal information from a child under age 13, 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 13, please contact us using the contact details provided under the “How to contact us” heading below.
If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will dispose of that information, or otherwise treat it in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under 13 years of age has provided us with personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Your California, U.S. privacy rights
Residents of the State of California in the United States of America (“California”) have the right to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal data for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To obtain this information, please send a request to privacy@huippeeheroes.com with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.
How to contact us?
The data controller is Huippee Oy, domicile Järvenpää, Finland, business ID 3097631-1.
Should you have any questions regarding this Privacy Policy or the processing of your personal information, please contact us via privacy@huippeeheroes.com.