Privacy Policy

This is the Privacy Policy (the "Policy") of BlueRiver Interactive GnbR, a company incorporated in Austria, with its registered office at Tanzwiese 1, 4240 Freistadt, Austria (hereafter "Owner", "us" or "we").

The Policy describes how we collect and use information, including personal data (the "Data"), about you ("User" or "you") when you access our websites or when you use any of our games such as PicWords, PicWords 2 or other future games (each a "App" or "Game" and together the "Apps" or "Games"). These apps may be accessed via web browser, social networking sites or via app platforms, like Apple's App Store, Google Play and others) (each a "Platform" and together the "Platforms").

If you have any questions or queries about this Policy, please contact us at blueriverteam@gmail.com

Summary

When you play our Games we will get, and store some personal data about you that we will use for different purposes as explained in this Policy. Most of that data is necessary for us to provide Games to you and for you to play our Games.

However, in some cases we may ask you to provide us with other personal data or use personal data for purposes that are not necessary to play our Games. In those cases, you do not have to provide that personal data to us or have the right to opt out from such use (if the same type of data is used also for other purposes).

Some of our Games will also show advertisements, and on many devices, the ads you see use a specific advertising identifier on your device to provide these advertisements. At the time of this writing we show non-personalized advertisements by default.

You have the right to object to how we use your personal data and you also have other rights to gain insight into and influence how we use your personal data.

These rights include that:

• You can ask for the personal data we have about you;
• You can ask that we correct any incorrect data we have about you;
• You can ask us to delete personal data we have about you;
• If you have any concerns with how we treat your personal data, you can file a complaint with the supervisory authorities;

All your rights and how to make use of them are further explained in the Full Policy section of this Policy.

If you want us to delete any data we gathered from you while playing our games you can also use the inbuilt delete functionality in our apps. Please note that you will also lose all your game progress if you do so. Follow these steps in our policy to delete your data: Delete Data

Please note that we have no possibility to know if you delete a Game from your device and your personal data will thus be stored by us even if you delete a Game. If you want to request the data we have about you or want us to delete personal data we have about you, please contact us.

These are some examples of personal data that we may collect when you use our Apps:

• Device related data (such as IP-address, device identifier and advertising ID). We use this data for example to be able to provide the Apps to you and show non-personalized advertisements for the purpose of monetization.
• App usage history When you play one of our Games we will save some information about the Apps you used, general activities in the App and for how long you used that App. This information is used for analytics of how the App works and to be enable us to improve the App.
• Social network information. If you sign into one of our Apps through a social network and your privacy features on your social network allow it, we are able to access certain information about you through that social network. We only use the types of data that are necessary for our Apps to provide the requested functionality, like the Facebook ID. If you do not want us to use such information at all, please do not sign into any of our Apps through your social network.
• Other information provided to customer service. Information you choose to provide when contacting us for technical or other support.
• Geographical Location. Based on the IP-address we will determine your geographical location on a country and city level. This is used in Games to provide you with localized game experiences.

You need to be over a certain age to use our Apps and Services. The minimum age varies depending on your country of origin. For information about the minimum age in your country, see the Children section of our Full Policy below.

Your personal data will be transferred to companies inside and outside the EU that we engaged with to provide services to us.

Below follows a more detailed description on how we and our partners use personal data.

Full policy

Owner and Data Controller

BlueRiver Interactive GnbR
Tanzwiese 1
4240 Freistadt
Austria

Owner contact email: blueriverteam@gmail.com

Types of Data collected

Among the types of Personal Data that we collect, by ourselves or through third parties, there are: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Geographical location on a country and city level.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using our apps.
Unless specified otherwise, all Data requested by our Apps are mandatory and failure to provide this Data may make it impossible for our Apps to provide their services. In cases where our Apps specifically state that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by our Apps or by the owners of third-party services used by our Apps serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through our Apps and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Apps (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

We may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Content performance and features testing (A/B testing), Managing contacts and sending messages, Hosting and backend infrastructure, Registration and authentication, Advertising, Access to third-party accounts, Infrastructure monitoring and Remarketing and behavioral targeting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Facebook permissions that may be asked by the Apps

The Apps may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows the Apps to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name and their locale.

List of Friends

Provides access to the User's Facebook friends list.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Access to third-party accounts

  This type of service allows the Apps to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  Facebook account access

  This service allows the Apps to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Email and List of Friends.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on the Apps. Some of the services listed below may use Cookies to identify Users. For more information, please check the privacy policies of the relevant services.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  AdMob (AdMob Google Inc.)

  AdMob is an advertising service provided by AdMob Google Inc.
  In order to understand Google's use of Data, consult Google's partner policy.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  AppLovin (AppLovin Corporation)

  AppLovin is an advertising service provided by AppLovin Corporation.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt out.

  Chartboost (Chartboost, Inc.)

  Chartboost is an advertising service provided by Chartboost Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy.

  Tapjoy (Tapjoy, Inc.)

  Tapjoy is an advertising service provided by Tapjoy, Inc.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

  Place of processing: United States – Privacy Policy.

  Unity Ads (Unity Technologies ApS)

  Unity Ads is an advertising service provided by Unity Technologies ApS.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: Denmark – Privacy Policy.

  Fyber (SponsorPay GmbH)

  Fyber is an advertising service provided by Fyber GmbH.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: Germany – Privacy Policy.

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics for Firebase (Google Inc.)

  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google's use of Data, consult Google's partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  The Apps use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Fabric Answers (Google Inc.)

  Fabric Answers is an analytics service provided by Crashlytics, a business division of Google Inc.
  In order to understand Google's use of Data, consult Google's partner policy.

  This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Fabric Answers privacy policy.
  In particular, the Apps use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Fabric Answers service. Fabric Answers may share Data with other tools provided by Fabric/Crashlytics, such as Crashlytics. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
  Users may opt-out of certain Fabric Answers features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Fabric related sections of this privacy policy, if available.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

  Place of processing: United States – Privacy Policy.

  Flurry Analytics (Flurry, Inc.)

  Flurry Analytics is an analytics service provided by Yahoo! Inc.
  This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Flurry Analytics privacy policy.
  If the User chooses to opt-out, Flurry will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward. The analytics service tracking will stop across all applications within the Flurry network.

  Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy – Opt Out.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the Apps.

  Firebase Remote Config (Google Inc.)

  Firebase Remote Config is an A/B testing and configuration service provided by Google Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable the Apps to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of the Apps. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Firebase Hosting (Google Inc.)

  Firebase Hosting is a hosting service provided by Google Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Cloud Functions (Google Inc.)

  Firebase Cloud Functions is a hosting and backend service provided by Google Inc.

  Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Cloud Firestore (Google Inc.)

  Firebase Cloud Firestore is a hosting and backend service provided by Google Inc.

  Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Infrastructure monitoring

  This type of service allows the Apps to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of the Apps.
  

  Crashlytics (Google Inc.)

  Crashlytics is a monitoring service provided by Google Inc.

  Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Firebase Notifications (Google Inc.)

  Firebase Notifications is a message sending service provided by Google Inc. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Firebase Cloud Messaging (Google Inc.)

  Firebase Cloud Messaging is a message sending service provided by Google, Inc. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Registration and authentication

  By registering or authenticating, Users allow the Apps to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, the Apps will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Firebase Authentication (Google Inc.)

  Firebase Authentication is a registration and authentication service provided by Google Inc. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

  Personal Data collected: username.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Facebook Authentication (Facebook, Inc.)

  Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Data deletion

Users may instruct the Owner to delete their personal data either by contacting them through the contact details provided in this document or by following these steps:

• Open the game,
• Access the settings menu by tapping the settings icon (Usually a gear icon or three horizontal lines on the top of the screen),
• Access the privacy settings by tapping the privacy button,
• Tap on "Change Consent" and "Delete Data", then confirm the action.

Please note: All your data will be deleted including your game progress!

Children

You need to be over a certain age to play our Games or use our services. The minimum age varies depending on your country of origin. For information about the minimum age in your country, see below.

We do not to our knowledge collect information, or ask for personal information, or serve personalized ads to any person under the minimum age requirements below. If you think that we might have information about a user younger than the minimum age requirements, please contact us.

Minimum age:

• 16 years: France, Germany, Hungary, Lithuania, Luxemburg, Netherlands, Slovakia
• 15 years: Finland
• 14 years: Austria
• 13 years: All other countries

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Apps or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, the Apps may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within the Apps and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.