Richie Loyalty Program & Website Privacy Policy

Privacy Policy Last updated: 17.02.2024 

Richie Loyalty Program & Website Privacy Policy 

Introduction 

Thank you for choosing Richie. In compliance with data protection laws, we are obliged to inform you about how we manage and safeguard your personal data, our purposes for processing it, and your respective rights concerning your data. Comprehensive details can be found at https://richie.games/pp, and we strongly encourage you to thoroughly read through it.  

Your Consent is Vital Prior to installing the Richie or utilizing our Services via our App or Website, please affirm your consent to our processing of your personal data in accordance with this privacy policy.  

Withdrawal of Consent Should you wish to reverse your decision post-signing into our App, you can withdraw your consent at any time by reaching out to us at [email protected]. Please note that withdrawal will not impact the legitimacy of the processing executed prior to your withdrawal.  

An Overview This policy, along with our Terms and Conditions, which are available at https://richie.games/tos, (referred to as ‘Terms’) is applicable to your usage of:  

• The Richie App Rewards app available on iOS or Android platforms and our Website at https://richie.games (collectively, “the App”).  
• Any services that can be accessed through the App (“Services”).  

This policy elucidates the fundamentals on which any personal data we accumulate from you, or that you provide to us, will be processed by us. It’s crucial to acknowledge that Richie App Rewards is not designed for children, and we do not intentionally gather data pertaining to them. Please proceed with reading the following to comprehend our practices concerning your personal data and how it will be treated.  

Key Information and Responsible Entity  

Richie App Rewards acts as the controller and is accountable for your personal data, referred to as “we”, “us”, or “our” throughout this policy.  

We have designated a data privacy manager. For any inquiries regarding this privacy policy, please reach out to them using the information provided below.  

Contact Information 

Full name of the legal entity: Richie App Rewards 

Data privacy manager’s email address: [email protected] 

You possess the right to complain at any time to the Türkiye concerning data protection matters.  

Modifications to the Privacy Policy and Your Obligation to Notify Us of Changes Our privacy policy may be subject to updates, which will be prominently posted on this page and, where applicable, informed to you via email or upon your next App launch or website login. The revised policy may be showcased on-screen, and you might be compelled to read and accept the alterations to proceed using the App or Services.  

It’s pivotal that the personal data we retain about you is precise and up-to-date. Kindly ensure that you notify us if your data evolves during our relationship.  

Links to Third-Party Websites 

Occasionally, our App may feature links to and from the websites of our affiliate networks, advertisers, and partners. Note that these websites and any services accessible through them have their own privacy policies. We do not accept any responsibility or liability for these policies or any personal data that may be collected through these websites or services, like Contact and Location Data. Please examine these policies before submitting any personal data to these websites or employing these services.  

Use of Pollfish Web Plugin 

This website utilizes the Pollfish web plugin. Pollfish is an online survey platform that collaborates with application Developers and website owners to gain access to users for survey distribution. Pollfish cookies are used and enabled by this website. When a user visits this website, Pollfish determines whether the user is eligible for a survey. Data harvested by Pollfish will be paired with your responses to surveys when Pollfish dispatches such questionnaires to eligible users. A comprehensive list of data acquired by Pollfish via this website is detailed in Pollfish respondent terms at https://www.pollfish.com/terms/respondent. By utilizing this website, you accept this privacy policy and explicitly consent to the positioning of a Pollfish cookie in your system and the processing of the respective data by Pollfish. Moreover, you are informed that you can disable Pollfish operations at any point by using Pollfish’s “opt out section” available on their website or by deactivating “third-party cookies” in your browser’s settings. We further invite you to review Pollfish respondent’s terms of use for a more detailed view of how Pollfish operates.  

1. Types of Data Collected  

Account Data Collection: When you actively engage with Richie, certain information is directly provided by you. During the account creation process, details like your name and email address, phone number, account preferences, and other communications details are collected. This section of the Richie User Privacy Policy clarifies the specific data points we collect when you interact with us directly or participate in our promotional activities. Understanding this information empowers you to make informed decisions regarding your privacy within the platform. 

• Name: Both your first and last name are collected when you create a Richie account. 
• Age: Providing your age allows us to ensure compliance with age restrictions and tailor platform features accordingly. 
• Gender: While optional, sharing your gender information helps us personalize user experience and offer relevant recommendations. 
• Email Address: Your email address acts as your primary login credential and serves as a communication channel for important updates, promotions, and support. 
• Phone Number:  Your phone number allows us to security verification and potentially offer relevant promotions through SMS (with your consent). 
• Account Preferences: Your individual preferences within your account settings, such as language choice or notification preferences, are collected to personalize your user experience. 
• FaceID: Richie prioritizes the security and integrity of its platform, particularly when users redeem rewards earned through their interactions. To ensure these rewards are issued legitimately and prevent fraudulent activity, we utilize a “video selfie” verification process during redemption. 
• Direct Communication: Information shared during direct communication with Richie, including email exchanges, support inquiries, or feedback via surveys, is collected to understand your needs and improve our customer services. 
• Participation in Promotions: When you choose to participate in promotions or contests organized by Richie, additional information may be collected as required by the specific promotion’s terms and conditions. This could potentially include the user name, email address, and other details relevant to the promotion. 

Device Data Collection: This section of the Richie User Privacy Policy delves into the specific details of the personal data we collect, providing transparency and enabling you to understand the scope of information utilized within the platform. 

• IP Address: We collect your IP address, which can provide an approximate location (city/country level) and other network-related information. 
• Geolocation Data: In certain instances, with your explicit consent, we may collect precise geolocation data, including longitude and latitude coordinates, to offer location-based services or features. 
• Mobile Device Identifier: Unique identifiers associated with your mobile device, such as the International Mobile Equipment Identity (IMEI) or Android advertising ID, are collected for device identification and security purposes. 
• Advertising Identifier: We leverage advertising identifiers like the Google Advertising ID to personalize advertising and measure its effectiveness. 
• Device Information: Details about your operating system, device model, and language preferences are collected to optimize the platform for your specific device. 

User Activity and Interaction Data; 

• Log Data: Information regarding your network connection type, applications connected to the platform, and web pages accessed within the platform, is collected for service improvement and security purposes. 
• Gameplay Data: We collect gameplay data like your progress, playtime, and in-game activity. Additionally, with your consent and subject to Game Partner policies, we may gather information on in-game purchases, achievements, and even bugs encountered. Importantly, the specific data collected can vary by game. Rest assured, we abide by data protection regulations and encourage you to review Game Partner privacy policies for additional details. This transparency empowers you to navigate the platform with confidence, knowing your privacy is a top priority. 
• Installed App Data: We may identify whether certain apps relevant to the platform are already installed on your device to enhance your experience and offer personalized recommendations. 
• Storage permission: Used for accessing shared external storage, including the reading and adding of any items.  
• Usage Stats permission: Device usage history and statistics. (App usage history with package names) Usage data is aggregated into time intervals: days, weeks, months, and years. 

Integration with Richie: We have partnered with Richie to provide a connected experience across our games and the Richie loyalty app. By playing our games, users can complete checkpoints and earn rewards in Richie. The data we share with Richie includes:  

• User Key ID: To identify individual users across our games and Richie.  
• Device Key ID: To verify that both our games and Richie are installed on the same device.  
• This information helps to enhance the gaming experience and is only used for the purposes described herein. We are committed to ensuring the privacy and security of this data, and we do not share it with any third-party entities without explicit user consent. 
• Guest users cannot disable this collection. 
• Retention time: Personal Data shall be processed and stored for as long as required by the purpose they have been collected.  

Personal Data from Third-Party Social Networks: This section of the Richie User Privacy Policy outlines the specific personal data we may collect when you choose to utilize third-party social networks like Facebook or Google for registration and sign-in purposes. Understanding this information empowers you to make informed decisions regarding your privacy preferences and utilize these features confidently. 

Data Acquisition Based on Privacy Settings: Richie recognizes that you exercise control over your data privacy settings on each social network platform. When you opt to use a social network login for Richie registration or sign-in, we collect the following information, always adhering to your designated privacy settings on the respective platform: 

• Basic Profile Information: This includes your first and last name as displayed on your chosen social network profile. 
• Profile Details: Depending on your privacy settings, additional information publicly available on your social network profile, such as details included in your posts, may be gathered. 
• Account Identifiers: We collect your email address and unique profile ID associated with the chosen social network for verification and account management purposes. 

Always Adhering to Legal Frameworks: It’s important to highlight that Richie only collects and processes your data for reasons explicitly listed in this Policy and by applicable laws. This legal framework safeguards your privacy and ensures that your information is handled responsibly. 

By providing this comprehensive overview of data collection practices, Richie aims to instill transparency and empower you to navigate the platform with confidence. Should you have any further questions or require clarification, do not hesitate to reach out to the designated contact points within the Policy. 

Automatic Collection 

Certain information is automatically collected when accessing and using our Services, such as: 

• Aggregated usage information 
• Session ID 
• Access time and date 
• Device and geolocation data

Cookies and Usage 

We employ cookies and/or other tracking mechanisms to differentiate you from other App, distribution platforms (Appstore), or Service users and to remember your preferences, enhancing your user experience and allowing us to refine the App. For a comprehensive breakdown of the cookies we use their purposes, and how you can manage your cookie preferences, please view our cookie policy.  

2. Use of Personel Data: 

Richie gathers various data points about its users, encompassing names, emails, device identifiers, and gameplay activity. This information acts as the foundation for several key functionalities, including: 

• Tailored Experiences: Leveraging collected data, Richie aims to personalize your journey by suggesting games and features aligned with your interests. 
• Rewarding Engagement: Active usage of game partners’ applications within the platform translates to rewards offered through the Richie program. 
• Service Enhancement: Data plays a vital role in monitoring game installations, managing in-app gift card redemption, and ultimately improving the overall user experience. 
• Strategic Marketing: Richie employs collected data to effectively promote its services across diverse platforms.  
• Engaging Events: Personalization extends to facilitating participation in contests, sweepstakes, and other digital events, ultimately leading to the selection of winners. 
• Operational Efficiency: Attribution of game installs and reward program management all rely on accurate data collection. 
• Security and Fraud Prevention: Safeguarding the platform and preventing fraudulent activity requires utilizing relevant data points. 
• Face Verification for Security and Fraud Prevention: This process involves capturing a short video of your face using a feature powered by our trusted third-party face verification technology. The captured video generates a mathematical representation of your facial features, creating a unique identifier that becomes part of your account information. Importantly, this video selfie is encrypted directly on your device before secure transmission to our servers for processing. By implementing this verification step, Richie aims to achieve several key objectives: 

• The uniqueness of User Registration: We safeguard against duplicate accounts and ensure legitimate participation by verifying the uniqueness of each user within the platform. 
• Prevention of Fraudulent Activity: The system helps deter the use of bots, automated processes, or any unauthorized software that could fraudulently exploit the reward system. 
• Reward Security: Video selfies enhance the security of your rewards, guaranteeing they are rightfully issued to verified users and cannot be obtained through illegitimate means. 

This verification process aligns with Richie’s commitment to creating a secure and fair environment for all users. By understanding its purpose and implementation, you can confidently engage with the platform and enjoy the rewards earned through your participation. 

• Product Development and Innovation: Insights gleaned from data drive the creation of new products and the enhancement of existing services. 
• Data-Driven Reporting: Aggregated and anonymized data empowers the generation of valuable reports and insights, fostering optimization across various aspects of the platform. 
• Effective Communication: Understanding user preferences allows Richie to tailor its communication channels and improve their relevance. 
• Machine Learning for Personalization: Data fuels the development of machine learning models, ensuring a customized content experience for each user. 

Advertising: This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services. In addition to any opt-out feature offered by any of the services below, Users may opt-out by visiting the Network Advertising Initiative opt-out page.  

•  Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.  
• AdMob (Google Ireland Limited): AdMob is an advertising service provided by Google Ireland Limited. To understand Google’s use of Data, consult Google’s partner policy.   
• Adgem: In addition to personal information that we may receive from you, AdGem may collect other information from Users using the following technologies: 
• Cookies. “Cookies” are small bits of information that the Platform places on the hard drive of your computer. Cookies remember information about your activities on the Platform to make your visits to the Platform more enjoyable and valuable to you by providing a customized experience and recognizing your preferences when you visit the Platform. If you’ve chosen to disable cookies on your browser, some of the functionality of the Platform may be lost. Certain Services provided by AdGem, require that cookies be enabled in your browser and cannot be used when you have disabled cookies in your browser. 
• Web Server Logs. Web server logs are records of activity created by the computer that delivers the web pages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you to a webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server. 
• Device Information. We may collect information about the mobile device or computer you use to access the Platform, including without limitation the hardware model, operating system and version, browser type, unique device identifiers, and mobile network information. 
• SDK Information. We may collect information from a Software Development Kit (SDK) that our Customers integrate into their applications allowing them to provide end users with advertising. By downloading and using the Customer’s application, end users are permitted to share information collected by the SDK with AdGem under this Privacy Policy. 

• Facebook Audience Network (Facebook Ireland Ltd): Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd To understand Facebook’s use of Data, consult Facebook’s data policy.  This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings. 
• Users may opt out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones, or by following the instructions in other Audience Network-related sections of this privacy policy, if available.
• Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
• Place of processing: Ireland – Privacy Policy – Opt Out. 
•  Adjust (Adjust GmbH): Adjust is an advertising service provided by Adjust GmbH.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: Germany – Privacy Policy – Opt-out.
• AdColony (AdColony, Inc.): AdColony is an advertising service provided by AdColony, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy.
• Tapjoy (Tapjoy, Inc.): Tapjoy is an advertising service provided by Tapjoy, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt-out.
• Liftoff (Liftoff Mobile, Inc.): Liftoff is an advertising service provided by Liftoff Mobile, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt-out.
• PubMatic (PubMatic, Inc.): PubMatic is an advertising service provided by PubMatic, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt Out.
• Smaato (Smaato, Inc.): Smaato is an advertising service provided by Smaato, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt-out.
• TripleLift (TripleLift, Inc.): TripleLift is an advertising service provided by TripleLift, Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt-out.
• Unruly (Unruly Group Ltd): Unruly is an advertising service provided by Unruly Group Ltd.
• Personal Data processed: Tracker; Usage Data. 
• Place of processing: United Kingdom – Privacy Policy – Opt-out.
• Google Ad Manager (Google Ireland Limited): Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner unless otherwise specified in this document, has no direct relationship with. To opt out of being tracked by various advertising networks, Users may make use of Youronlinechoices. To understand Google’s use of data, consult Google’s partner policy. This service uses the “DoubleClick” Cookie, which tracks the use of this Application and User behavior concerning ads, products, and services offered.
• Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings. 
• Personal Data processed: Tracker; Usage Data.
• Place of processing: Ireland – Privacy Policy.
• Google AdSense (Google Ireland Limited): Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks the use of this Application and User behavior concerning ads, products, and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings. 
• Personal Data processed: Tracker; Usage Data.
• Place of processing: Ireland – Privacy Policy.
• Unity Ads (Unity Technologies ApS): Unity Ads is an advertising service provided by Unity Technologies ApS. 
• Personal Data processed: Tracker; Usage Data. 
• Place of processing: Denmark – Privacy Policy.
• Aarki (Aarki Inc.) Aarki is an advertising service provided by Aarki Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: United States – Privacy Policy – Opt-out.
• Fluct (Fluct Inc.) : Fluct is an advertising service provided by Fluct Inc.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: Japan – Privacy Policy – Opt out.
• 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 Ireland Limited): Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited. 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.
• This Application uses identifiers for mobile devices 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 processed: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
• Place of processing: Ireland – Privacy Policy.
• Sensor Tower (Sensor Tower Inc.): Sensor Tower is an analytics/store intelligence service provided by Sensor Tower Inc.
• Personal Data processed: Tracker; Usage Data; App Usage Stats; various types of Data as specified in the privacy policy of the service.
• 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 processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of processing: United States – Privacy Policy – Opt Out.
• Facebook Analytics for Apps (Facebook Ireland Ltd): Facebook Analytics for Apps is an analytics service provided by Facebook Ireland Ltd
• Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.
• Unity Analytics (Unity Technologies ApS): Unity Analytics is an analytics service provided by Unity Technologies ApS.
• Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of processing: Denmark – Privacy Policy.
• Yandex Metrica (YANDEX, LLC) :Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC. Yandex Metrica is used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are.
• Personal Data processed: Tracker; Usage Data.
• Place of processing: Russian Federation – Privacy Policy.
• Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)
• Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network. 
• Personal Data processed: Tracker; Usage Data. 
• Place of processing: Ireland – Privacy Policy.
• Beta Testing: This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application. The service provider may automatically collect data related to crashes and statistics related to the User’s use of this Application in a personally identifiable form.
• Google Play Beta Testing (Google Ireland Limited) :Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.
• Personal Data processed: country; device information; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.
• TestFlight (Apple Inc.) : TestFlight is a beta testing service provided by Apple Inc.
• Personal Data processed: app information; country; device logs; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
• Place of processing: United States – Privacy Policy.
• 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 this Application.
• Firebase Remote Config (Google Ireland Limited) : Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.

• Data transfer outside the EU: The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below. Users can inquire with the Owner to learn which legal basis applies to which specific service.
• Data transfer abroad based on standard contractual clauses (this Application)
• If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission. This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

• Handling payments: Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
• RevenueCat (RevenueCat, Inc.): RevenueCat is a payment service provided by RevenueCat, Inc. The service allows the Owner to monitor and analyze the User and their purchase history and can be used to keep track of User behavior.
• Personal Data processed: Application opens; device information; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
• Place of processing: United States – Privacy Policy – Opt Out.
• Payments are processed via the Apple App Store (Apple Inc.): This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
• Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.
• Personal Data processed: payment info.
• Place of processing: United States – Privacy Policy.
• Payments processed via the Google Play Store (Google Ireland Limited): This Application uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.
• Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
• Personal Data processed: payment info.
• Place of processing: Ireland – Privacy Policy.

• Hosting and backend infrastructure:This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
• Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
• Amazon Web Services (AWS) (Amazon Web Services, Inc.): Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: United States – Privacy Policy. 

• Infrastructure monitoring: This type of service allows this Application 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 this Application.
• Firebase Performance Monitoring (Google Ireland Limited): Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.
• Crashlytics (Google Ireland Limited): Crashlytics is a monitoring service provided by Google Ireland Limited.
• Personal Data processed: crash data; device information; Universally unique identifier (UUID).
• Place of processing: Ireland – 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 Ireland Limited): Firebase Notifications is a message-sending service provided by Google Ireland Limited. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.

• Platform services and hosting: These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, and payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
• Apple App Store (Apple Inc.): This Application is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
• By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enable the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis.
• Users may opt out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
• Personal Data processed: Usage Data.
• Place of processing: United States – Privacy Policy.
• Google Play Store (Google Ireland Limited) :This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.
• By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
• Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
• Personal Data processed: Usage Data.
• Place of processing: Ireland – Privacy Policy.

• Social features
• Firebase Dynamic Links (Google Ireland Limited) :Firebase Dynamic Links is a social feature provided by Google Ireland Limited. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.
• Firebase Invites (Google Ireland Limited) Firebase Invites is a social feature provided by Google Ireland Limited that enables Users to share this Application. The sharing may contain referral codes, or content from within this Application and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed this Application via invite.
• Personal Data processed: various types of Data as specified in the privacy policy of the service.
• Place of processing: Ireland – Privacy Policy.
• Further information about Personal Data
• Push notifications This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of this Application. 

Deletion and Retention 

• Deletion: We delete your data by shredding physical information and irrecoverably deleting electronic files. Inactive accounts may be terminated after one year, with the associated data destroyed. 
• Retention: Your personal data will be retained as long as needed for its intended purpose, or as required by law. After account deletion, we may retain data for an additional twelve (12) months for administrative purposes. We may also anonymize data, reserving the right to use it for legitimate business purposes. 

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity  Contact  Financial  Device	Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity  Contact  Financial  Transaction  Device  Marketing and Communications  Location	Your consent  Performance of a contract with you  Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity  Contact  Financial  Profile  Marketing and Communications	Your consent  Performance of a contract with you  Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)  Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity  Contact  Device  Profile  Marketing and Communications	Your consent  Performance of a contract with you  Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity  Contact  Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security
To deliver content and advertisements to you  To make recommendations to you about goods or services which may interest you  To measure and analyse the effectiveness of the advertising we serve you  To monitor trends so we can improve the App	Identity  Contact  Device  Content  Profile  Usage  Marketing and Communications  Location	Consent  Necessary for our legitimate interests (to develop our products/Services and grow our business)

3. Sharing Responsibly:

While your data remains at the core of Richie operations, there are instances where controlled sharing occurs. These scenarios encompass: 

• Corporate Affiliates and Transaction Parties: When necessary, data might be shared with subsidiaries, affiliates, or counterparties involved in corporate transactions, always adhering to legal agreements and data protection regulations. 
• Legal and Security Considerations: If protecting legal rights, preventing fraud, managing risks, or complying with legal obligations necessitates data disclosure, Richie does so responsibly and within the confines of the law. 
• Service Providers: A network of trusted service providers assists with various tasks like customer support, technical infrastructure, reward management, system security, and marketing efforts. All such providers are contractually bound to uphold the same data protection standards as Richie. 
• Advertising and Marketing: Collaborative efforts with advertising platforms and networks enable targeted advertising displays, advertising analytics, and effective management of Richie advertising presence on other platforms. 
• Marketing Vendors: Lawful partnerships with marketing vendors allow for engaging campaigns, testing activities, user events, and surveys, respecting your right to opt out as stipulated by applicable laws. 
• Analytics Insights: Partnering with analytics providers grants valuable insights into user trends and patterns, aiding in sales optimization, service improvement, and product development. 
• Game Partners: To fulfill various objectives like personalized content, marketing, business growth, game install attribution, and reporting Richie may share certain data with its partnering game developers (and their mobile measurement partners), subject to the Game Partners’ own privacy policies. When accessing games through Richie, remember that your data is shared with the respective Game Partner. 

Securing Your Data  

4. Data Security and Your Rights: 

Richie recognizes the importance of data security and implements robust measures to ensure the confidentiality and integrity of your information. These safeguards include administrative, organizational, technical, and physical controls. As a user, you are empowered to make informed decisions regarding your data through several rights: 

• Opting Out of Marketing Communications: You have the right to choose not to receive marketing messages from Richie. 
• Withdrawing Consent: You can revoke your consent to data collection and processing at any time. 
• Erasing Your Data: Richie grants you the right to request the deletion of your personal data or the closure of your account. 
• Objecting to Data Processing: You hold the right to object to how your personal data is processed for specific purposes. 

5. Additional Considerations: 

Children’s Privacy Protection

It is important to remember that:

• This Policy does not govern the data practices of third-party games accessed through Richie.
• Children under 18 are not permitted to use the platform.
• Richie retains data for legal requirements, as long as you actively use the service, or for its originally intended purposes.
• Information on cookie usage and other tracking technologies is available in the separate Cookie Notice.

Richie User Privacy Policy constitutes a comprehensive document designed to foster transparency and empower.

Richie prioritizes the protection of children’s privacy and adheres to the specific requirements stipulated by the Children’s Online Privacy Protection Act (COPPA) in the United States. In compliance with COPPA: 

For residents of Korea, the age restriction is raised to 14. The same provisions apply. 

Lawful Basis  

Consent: Ensure the methods to withdraw consent are user-friendly and transparent in your application or service.  

Legitimate Interest: Consider providing a brief, accessible example of what this might look like in practice for clarity.  

Performance of Contract and Comply with a legal obligation: Ensure the language here is clear and approachable to non-legal professionals.  

Third Parties  

Internal Third Parties: While keeping it concise, perhaps expand slightly to explain the necessity of sharing data within the company.  

External Third Parties: Mention any safeguards or checks to ensure these parties uphold similar data protection standards.  

External Third Parties Detail  

It might be beneficial to differentiate between different external third parties. For instance, you might consider separate categories for:  

• Service Providers: E.g., IT and system administration, cloud storage.  
• Professional Advisors: Specify circumstances under which data may be shared with these entities.  

Specific Rights for Residents of California, USA 

Under the California Consumer Privacy Act (CCPA), California residents are granted extensive rights and control over their personal information. Here’s what this means for you: 

1. Right to Know and Delete: 

• You can request, twice a year at no cost, details about your personal information that we have disclosed or sold, and a description of the categories of personal information shared. 
• We also provide, twice a year and free of charge, any information related to your personal data and how we process it, in a clear and easily understandable manner. 
• You can ask us to delete your personal data on our platform. Depending on your choice, we will either remove your information entirely or add you to a “do not contact” list for a specified period. 

2. Requests Timeline: 

• We’ll respond to your requests to know or delete within 45 days. If more time is needed, we’ll inform you. 
• 3. Authorized Agents: 
• You may appoint an authorized agent registered with the California Secretary of State to act on your behalf for disclosure or deletion requests under the CCPA. 
• We will honor such requests if you provide written authorization to the agent, and we can verify both your identity and the agent’s proof of authorization. 
• 4. Collection, Usage, and Disclosure Chart: 
• The following chart details the categories, sources, and purposes of the personal information we may handle (as described in CCPA Sec. 1798.140(o)): 

CATEGORY	NAME/DESCRIPTION	SOURCES	BUSINESS USE	COMMERCIAL USE
A	Identifiers – name, email, postal and IP address, unique personal identifier, online identifier, Internet Protocol address, account name	User provided on registration and upon redeeming points using the online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format	Operational purposes including customer service; fraud & security incidence detection; website improvement; award prize winners	None
B	Protected classification characteristics under California or federal law	Age and Gender	Recommend suitable Games	None
C	Internet or similar network activity -browsing and search history, information on a consumer’s interaction with a website, application, or advertisement	To determine the performance of media content and analytics purposes	User provided on registration and upon redeeming points using online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format	None
D	Geolocation data	Country Identified using IP Address	Recommend Games for Country	None
E	Inferences are drawn from other personal information	Profile reflecting a person’s preferences	Recommend Games based on preference	None

.  

• Note that although we have collected and disclosed personal information within the last year for business purposes, we do not sell your personal information. 

5. Non-Discrimination Assurance: 

• Richie will not discriminate against you for exercising your rights under the CCPA. 

California Online Privacy Protection Act (CalOPPA) 

Do Not Track Signals 

Most web browsers have a “Do Not Track” (DNT) setting, which, when activated, tells websites that the user does not wish to have their online behavior and personal information tracked (e.g., for interest-based advertising). Under CalOPPA, we’re obliged to let you know that, like most websites, we do not recognize or respond to DNT signals set by your browser. 

Overseas Transfer of Personal Information 

Compliance with Korean Regulations: We may need to transfer your personal information overseas. If this occurs, we’ll ensure that the transfer is done according to the privacy requirements of the Korean Personal Information Protection Act (PIPA) and the Network Act. This includes using a secure information communication network. Your information will be retained and used only until the purpose for which it was collected is fulfilled. 

COMPANY NAME	COUNTRY	CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO PRIVACY POLICY	DATE AND TIME OF TRANSFER	PURPOSE OF TRANSFER	PERSONAL INFORMATION ITEMS TO BE TRANSFERRED
Amazon Web Services, Inc.	U.S.A	Amazon.Com	Upon accessing and using Richie services	Hosting and data security and management services for the personal data that we store. Also used for analytics to monitor and track the reliability of the Services	CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO THE PRIVACY POLICY
Adjust	U.S.A	Email  Adjust.Com	Upon accessing and using Richie services	Advertising, rewards, and fraud detection	Mobile application Google Ad ID, IP address, age, device model, OS version
Facebook	U.S.A	Facebook.Com	Upon accessing and using Richie services	Used for business analytics to better understand how users interact with Richie Services	Google Advertising ID
Google	U.S.A	Google.Com	Upon accessing and using Richie services	Used for business analytics to better understand how users interact with Richie Services	Google Advertising ID
AdGate	Canada	Adgatemedia.com	Upon accessing and using Richie services	Advertising, and rewards	IP address, user agent
Adjoe	Germany	Adjoe.zone	Upon accessing and using Richie services	Playtime (adjoe) is a third feature that is integrated with our app. Playtime allows users to earn in-app currency by playing third-party games and collects devices’ application usage from users. The processing of the data is necessary to recommend, via system messages, the installation of the app available in Playtime that matches users’ interests and calculates the bonuses acquired as a result of users’ use of the corresponding apps. For more information, please refer to Playtime (adjoe) Data Privacy.	IP address, user agent, usage access data