PRIVACY POLICY

Updated on: 13th October, 2022

Thank you for playing our games! This Privacy Policy describes:

The ways we collect personal data about you and why we do so
How we use your personal data, and
The choices you have about your personal data.

This Privacy Policy applies to Habby's games, websites and related services, which we here collectively call the Service. We may periodically update this Privacy Policy by posting a new version on https://habby.fun. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly.

Name of the controller: Habby PTE. LTD.
Name of the responsible: Travis Zhao
Contact: datasecurity@habby.com
Address: 10 ANSON ROAD #26-04, INTERNATIONAL PLAZA SINGAPORE (079903)
email: admin@habby.fun

THE DATA WE COLLECT

Data you provide us.

Contact information (such as name and email address)
Player name and password
Profile information (such as profile photo)
Your messages to the Service (such as chat logs and player support tickets)
Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.

Data about your account and game progress
Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
Data about your device, such as device name and operating system, browser type and language
Data we collect with cookies and similar technologies (see more below)
General location data
Precise geo-location data (GPS, with your consent)
Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

In most cases, we also create a Habby-specific ID for you when you use the Service.

Data we collect from our partners.

Data we receive if you link a third party tool with the Service (such as Facebook, WeChat or Google)
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Data from platforms that the games run on (such as to verify payment)
Data for advertising and analytics purposes, so we can provide you a better Service

Retention period of personal information.

In principle, users' personal information is destroyed or stored separately without delay when the purpose of collection and use of personal information is achieved. However, only for the following reasons, the information is stored and managed separately from other information for a certain period of time, and destroyed or stored separately without delay after the period specified below.

Website Data
Website Data is stored for 3 years from the date of logging for the purpose of reporting and managing queries and then destroyed or stored separately.
Job Application Archive
Job applications are kept for one year from the date of application and then destroyed or kept separately.
Complaints and Disputes Resolution
Subject to the following, if you request deletion of personal information, it will be destroyed or stored separately without delay.
We may be obliged to preserve the information even after the purpose of collection and use has been achieved in accordance with the provisions of relevant laws and regulations, we shall keep the user's information for a certain period of time as stipulated by the relevant laws and regulations (to a reasonable extent).

Retaining and Deleting Personal Information.

We retain your personal information for the duration of our service to you and will delete it after the purpose of the collection is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using commercially reasonable technical measures in a way that the data cannot be reproduced.

WHY DO WE COLLECT YOUR DATA

To make the Service work.

To perform the contract, we process data necessary to

Create accounts and allow you to play our games and use our Service
Operate the Service
Verify and confirm payments
Provide and deliver products and services you request
Send you Service-related communications

To make the Service more suitable for our players.

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

Update and develop player profiles
Develop and improve the Service and player experience
Manage our relationship with you
Provide social features as part of the Service
Customize your Service experience
Respond to your comments and questions and provide player support
Provide you Habby offers in the Service as well as in other websites and services, and by email
Send you related information, such as updates, security alerts, and support messages
Enable you to communicate with other players

To show personalized advertisements.

To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to

Track the content you access in connection with the Service and your online behavior
Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.

To keep the Service safe and fair.

Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the Habby Terms of Service.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Service and its social features
Moderate chats either automatically or manually
Take action against fraudulent or misbehaving players

To analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

With your consent.

With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.

WHO CAN SEE YOUR DATA

Apart from Habby, your data can be accessed by others in the following situations:

OTHER PLAYERS AND USERS.

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

PARTNERS WORKING FOR HABBY.

Habby has partners to perform services for us. These partners process your data only at and according to Habby´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

Other companies and public authorities.

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising and Social Media partners.

The Service includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at habby.fun/partner-opt-out. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by Singaporean laws.

The current status of transferring personal information to overseas companies for service use is as follows.

Company Name	Country	Purpose	Concerned Data	Date & Method	Period of Use
HABBY PTE. LTD. datasecurity@habby.com	Singapore	Data storage according to service usage	All items of personal information specified for the purpose of various service within this Privacy Policy	Data is transferred over the network when the service is used	Except as specifically agreed hereby, data will be permanently erased 1 year after the support request is concluded.

YOUR RIGHTS AND OPTIONS

Opt-out of marketing emails and other direct marketing.

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.

Opt-out of targeted advertising.

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android). For more information, see also: https://www.habby.fun/partner-opt-out.html.

For personalized in-game offers opt-out, you can use the options provided in the game settings.

Access the personal data we hold about you.

If there is a change to your personal information, or you no longer desire our Service, you may edit, update, or delete the data by making the change within your account settings in the game, by contacting the Support team’s email (can also be found in our products) or by contacting us at datasecurity@habby.com. We will provide you a copy of your personal information in an electronic format upon request.

Your privacy rights

Pursuant to your local law, you may have the following rights:

Right of access: You have the right to obtain confirmation from us as to whether or not we process personal information from you and you also have the right to at any time obtain access to our personal information stored by us. To exercise this right you may at any time contact us as at datasecurity@habby.com. You may also access the information you provided in the settings of our product.
Right to rectification of your personal information: If we process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to obtain the rectification of such data. To exercise this right you may at any time contact us at datasecurity@habby.com. You may also change the information you provided in the settings of our product.
Right to erasure of your personal information or right to restriction of processing: You may have the right to obtain the erasure of your personal information or the restriction of processing of your personal information. To exercise this right you may at any time contact us at datasecurity@habby.com
Right to withdraw your consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings. To exercise this right you may at any time contact us at datasecurity@habby.com
Right to data portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller. To exercise this right you may at any time contact us as at datasecurity@habby.com
Right to object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with the Data Protection Authority(DPA).

Your other rights.

You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge). You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

HOW DO WE PROTECT YOUR DATA

Security Safeguards.

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention.

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

General Data Protection Regulation (GDPR)

Under the GDPR regulations, should you wish for your data to be deleted, please send out a request to the relevant emails in the following list:

Game	Email
Archero	archero@habby.com
Slidey®: Block Puzzle	slidey@habby.com
Penguin Isle	penguinisle@habby.com
Spin Rhythm	spin@habby.com
Punball	punball@habby.com
Kinja Run	kinjarun@habby.com
Survivor.io!	survivor@habby.com
SSSnaker	sssnaker@habby.com
SOULS	souls@habby.com
Capybara Go!	capybarago@habby.com