Privacy Policy
PRIVACY AND COOKIE POLICY
Effective Date: 12/18/22
Sleepless Studios (“Sleepless” or “we”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). This Online Privacy and Cookie Policy (the “Policy”) has been provided to inform you as to the ways we collect, store, use, and manage the information you provide in connection with any Sleepless website (collectively, the “Site”), or any Sleepless game or application (the Site, games and applications are, collectively, the “Service”). Please note that the scope of this Policy is limited only to information collected by Sleepless through use of the Site or Service. This Policy does not apply to the practices of third parties that Sleepless does not own or control.
Sleepless offers its games also to users resident in jurisdictions across the world, including the European Union (“EU”), United Kingdom (“UK”), Switzerland and Brazil. Sleepless is the data controller for personal information collected from those users, insofar as this concept applies in those jurisdictions.
In compliance with the EU General Data Protection Regulation (“GDPR”) Users who are resident in the EU may address questions relating to the way we collect, store, use and disclose their personal information to ThreePedalPat@gmail.com
In compliance with the UK Data Protection Act, users who are residents in the UK may address questions relating to the way we collect, store, use and disclose their personal information to ThreePedalPat@gmail.com
It is advised that you review this Policy regularly, as it may be amended from time to time as set out below (see Changes to this Policy).
Information collection
We collect information about you directly from you, from third parties, and automatically through your use of our Service. We may combine the information that we collect about you from these various sources.
Information we collect directly from you
We will also collect any information or categories of information that you provide to us through your use of our Service from the sources identified below. The types of personal information we collect may vary depending on your activity. Personal information may include identifiers such as:
Your name;
User identification number;
Email address;
Password.
We are not responsible for any Payment Service Providers handling your transaction and you should refer to the Payment Service Provider’s privacy policy to see how they use your data, which is subject to their rules and policies.
If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.
Additionally, we may acquire information from you through your access and participation in message boards on the Service. This information may include posts, comments, photos or screenshots, videos, ratings, and in-game messages. If you post content to our Service, such information may be available to other users of our Service (e.g., in-game messages will be available to the recipient of your message and if you upload a profile picture, your image may be available to all other users of our Service). If you post your own content on our Service, your posting may become public and Sleepless cannot prevent such information from being used in a manner that may violate this Policy, our Terms of Use, the law, or your personal privacy.
Information we collect about you from third parties
When you install any of the Services, we may collect and record the information you provide us voluntarily through a social networking website in accordance with their policies and terms.
Information use
We need the above personal information for the purposes as described in this Policy, and not providing certain information may have an impact on our ability to provide you with the Service.
Sleepless' primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.
In addition, we may use user information for the following purposes:
Providing and improving our Services. To facilitate payments and communications between users; to provide and maintain the Service; to improve the Service; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use the Service; and for other customer service and support purposes.
Marketing and communications. To communicate with you, including via email or push notification, about your account and use of the Service, including to send Service and product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, keep you and others informed of your in-game activity, and other information we think may interest you; and for other informational, marketing, or promotional purposes.
Research and analytics. To analyze how you interact with the Service; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Protecting rights and interests. To protect the safety, rights, property, or security of Sleepless, the Service, any third party, or the general public; to detect, prevent or otherwise address fraud, security or technical issues; to prevent or stop activity which Sleepless, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy and our Terms of Use.
Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
Lawful Basis to Process in Certain Locations
We collect, use, and otherwise process your personal information when we have a lawful basis, as follows:
Contract Performance: we process your personal information to enter into an agreement with you and/or provide you with the service you request, pursuant to our Terms of Use;
Legitimate Interest: We process your personal information when necessary for our legitimate business interests and when these interests do not outweigh your own rights and interests, and subject to your right of objection to: (i) improve our services and your gaming experience; (ii) ensure the security function, and integrity of our games; (iii) when permitted by law, send you newsletters, marketing emails and push notifications with the latest information on our products and company, as well as other advertising for our products; (iv) protect our rights and property, enforce our Terms of Use and legal notices and for the establishment, exercise and defense of legal claims; (v) conclude corporate transactions (e.g., corporate restructuring, sale or assignment of assets, merger); (vi) share your information with third party marketplaces and service providers for adverting purposes; (vii) otherwise support our business, operations, and services; (viii) enforce our Terms of Use; and (ix) prevent fraud illegal activity and/or any violation of our intellectual property rights.
Legal Requirements: We collect and process your personal information to comply with our legal obligations, including any court order or binding decision;
Consent: We ask you for consent to collect or process your personal information for purposes unrelated to those described in this Privacy Policy by first notifying you and, where required, offering you a choice as to whether or not we may use your personal information in this different manner. Where we rely on consent to process your personal information, applicable law may require that we obtain your explicit affirmative consent, and you may also have the right to withhold or later withdraw your consent. Where such requirements apply, we will obtain your consent and enable you to withhold or withdraw it accordingly.
To the extent you provide information about friends and family members, you will present them this Privacy Policy and obtain their consent to provide the information. If you do not have their consent, do not send us their personal information.
Third party services
Please note that third party partners/providers, such as analytics companies or companies delivering advertisements in our games or on the Service, may also use cookies or other technologies, and those practices and providers are subject to their own policies.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
Sharing of information with third parties
Except as set forth in this Policy, Sleepless does not share your personal information with any third parties. In the event we offer services or promotions where your information is separately collected and used according to the privacy policy of a third party, we will inform you of that at the time of collection and you may elect not to participate in the service or promotion.
Other Sleepless users. We will share your information with other Sleepless users to provide our Services. For example, if you post a profile picture, that picture may be available to all other users of our Services.
Data retention
We will keep your information for as reasonably necessary for the purposes set out above in accordance with applicable law, generally no longer than 3 years from the date you stopped using our services. To determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process the personal information and whether we can achieve such purposes through other means, as well as applicable legal and regulatory requirements.
Protecting personal information
We strive to protect personal information while it is under our control. If you have an account with us, your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You acknowledge that you provide your personal information at your own risk. You are also responsible for all uses of the Sleepless games and applications by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.
Security
We have implemented technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, please note that no system or network is 100% secure and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes.
To protect your privacy and security, we may take reasonable measures (such as requiring a unique password) to verify your identity before permitting you access to your account or the Service.
Your rights and choices in relation to your personal information
Accessing, correcting, or deleting your personal information
Sleepless takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others' privacy), you may have rights under applicable law to request information from us about the personal information we hold in relation to you and correct any inaccurate data we hold.
Furthermore, depending on where you live, you may also have rights to change or request that we delete any personal information about you, such as by changing the applicable information found in your Sleepless account. However, if you decide to delete or anonymize your personal information, you may no longer have access to certain content (e.g. information of your game progress) and your account may become deactivated.
In certain territories (including the EU, UK and Brazil), you also have a legal right to ask for a restriction of processing or to object to processing.
You may also have the right to withdraw your consent, on the basis of which we process your personal information, at any time, by closing your account or otherwise clearly indicating your withdrawal of consent. However, this does not affect our lawful processing based on your consent before this withdrawal.
Subject to applicable law, you also may have rights to request that we provide such information to you in a portable format, or to request additional information about how we collect or disclose your personal information.
The rights that you have are subject to conditions and may not always be applicable.
If you or an authorized agent wants to exercise any of these rights, please contact us at: ThreePedalPat@gmail.com Subject to applicable law, you can freely exercise these rights and choices. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Once we receive your request from you, we may verify it through your account or by requesting information sufficient to confirm your identity.
Marketing communications
Subject to applicable legal provisions, we may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Service you have requested or received from us.
Push notifications
We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.
Behavioral advertising
Users in the United States may opt out of receiving interest-based advertising from many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Users in the European Union or United Kingdom may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or App or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). If your browser is configured to reject cookies when you opt out on the DAA, NAI, and/or EDAA websites, your opt out may not be effective. Please note that if you use multiple devices you will have to opt out on each individual device.
Links to other websites or applications
Links from the Sleepless Service to third party websites or applications are provided for your convenience. In addition, content in the Service may be hosted by other websites or applications. Any personal information you provide on the linked pages or applications is provided to that third party and is subject to that third party's privacy policy, not ours. These other websites and applications maintain their own policies regarding cookies and the collection and use of personal information. We encourage you to review those policies yourself.
Policy regarding Minors
Generally, we direct our Services to a general audience, and we do not knowingly collect, solicit, or market personal information from children under 16 years old (or older, if required by applicable law), and do not wish to do so.
We reserve the right to request proof of age (for example, we may request your month and year of birth) or parental or legal guardian consent at any time, and we may block users if we suspect they are under the applicable age.
If we learn that a child under 16 years old is using the Services, we may block such use. If we become aware that personal information from a child has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you learn about any personal information we have collected from a child under age 16, please contact us immediately.
We encourage all parents, guardians, and others of the age of legal majority to instruct children to never give out their real names, addresses, or other personal information without permission when using the Internet.
Changes to this policy
Sleepless may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you, such as by posting an announcement on our Service or sending you an email to an email address that you may have provided to us. Material changes will take effect seven (7) days after such notice was provided on our Services or sent to you via email, whichever is the earlier; all other changes to this Privacy Policy are effective as of the stated “Last Revised” date. Where applicable law requires consent for the processing of your data under this Privacy Policy, your continued use of the Services on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms should be amended to comply with legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.
Questions or concerns & contact details
If you have any questions or concerns regarding privacy at Sleepless, please contact us at:
Email: ThreePedalPat@gmail.com
While we prefer that you contact us in case you have any issue or feel we do not respond adequately to your questions or concerns, please note that you have a right to lodge a complaint with your competent supervisory authority.