App Privacy Policy

Privacy Policy

Last updated: January 10, 2020

Privacy and digital safety are top priorities for No WiFi Games. No WiFi Games LLC is providing this privacy statement to explain how we collect, use, and disclose personal information in clear, easy-to-understand language. This privacy statement applies to the following No WiFi Games apps: No WiFi Games Create and Play and No WiFi Games Scribble Scrubbie Pets. This Privacy Policy may be updated at any time as new features are added or as the law changes. Review this policy often. If we make a material change to this policy we will inform you before we make the change. We also encourage you to review the terms and conditions of use.

Table of Contents

  1. Personal Information
  2. Third Party Service Providers
  3. App Stores
  4. Links to Third Party Sites, Services, and Content
  5. Security
  6. California Privacy Rights
  7. California Privacy Rights: Shine the Light
  8. A Note to EU Citizens
  9. Contact Us

Personal Information

No WiFi Games apps do not collect or transmit any personal information, also known as PI. This includes all user generated content, also refered to as UGC, such as drawings, photos, coloring pages, and pet designs which are only stored locally on your device and are not transmitted.

Other information we collect

Our apps may collect and transmit anonymous information regarding usage patterns of the app to help No WiFi Games improve its apps and understand usage patterns. We collect the following anonymous technical data through our analytics provider: App Store, App Version, Device Brand, Device Category, Device Model, First Time Open, Language, New and OS Version. We also collect location information at a country level. For more information, please see the third party service providers section below.

Third Party Service Providers

In order to deliver the best app experience possible, No WiFi Games may use the following third party service providers collect and store anonymous information regarding usage patterns of our apps.

Google Firebase is used to store anonymous usage data for the explicit purpose of helping No WiFi Games improve the app experience. No personal data or PII is collected. All sharing options within Google Firebase are turned off. An example of this anonymous data is the number of times each activity has been played, which helps No WiFi Games understand what type of content is most popular. Google Firebase also collects anonymous technical data including device type, app version, country and language settings. For more information about Firebase, please view the Google privacy policy: https://policies.google.com/privacy?hl=en-US

We use Unity IAP to implement in-app purchases. Analytics and data sharing are deactivated as soon as the app launches and no data is sent to Unity Analytics. For more information, please see the Unity privacy policy: https://unity3d.com/legal/privacy-policy

Parents can contact us regarding their child’s use of the app here:

Consumer Affairs
No WiFi Games, LLC
1425 Casa Buena Drive, Unit 105
Corte Madera, CA 94925

You may also email us here or call us at 706-616-5493.

App Stores

When you download or purchase an App, or make an in-App purchase, you may do so through a third party application online store such as the Apple App Store or Google Play. You may be required to register with the app store and be logged on before you can download or purchase an app or make in-app purchase of another product using the app. When downloading an app, or using an app with on-line features through your platform, the app provider will typically also collect certain device and app-related information. No WiFi Games does not control the requirements or policies of app stores; you should review the Privacy Policy and terms of use of the mobile app stores before downloading or using any app, and check your device settings for control options.

The parent’s section of this app may contain links to other websites, online services, and content that are operated and maintained by third parties and that are not under the control of or maintained by us. Such links do not constitute an endorsement by No WiFi Games of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to your interactions with those third parties, even if you find a link to them on the No WiFi Games website. We encourage you to read the Privacy Policy of the third-party website provider to see how your personal information will be treated on its site.

Security

No WiFi Games uses generally accepted security measures and safeguards in an attempt to keep the data it collects secure and requires that the third parties it works with agree to do the same. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

California Privacy Rights

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California Consumers access the No WiFi Games websites, purchase No WiFi Games products, contact No WiFi Games, visit one of our physical locations, seek employment with No WiFi Games, or become a No WiFi Games employee, we collect the following Personal Information.

Categories of consumer’s Personal Information collected Business or commercial purposes for which the information was collected Categories of sources from which that information was collected Categories of third parties with whom the business shares personal information Personal Information disclosed or sold to third parties for a business or commercial purpose in the preceding 12 months
Identifiers
  • Alias
  • Email Address
  • Account Name
  • Unique Personal Identifier
  • Online Identifier
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To ensure minors do not unlawfully enter our facilities;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies.
This information is collected directly from you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Commercial Information
  • Products or service purchased, obtained or considered
  • Purchasing or consuming histories or tendencies
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
This information is collected directly from you or by logging our interactions with you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Internet or Electronic Network Activity Information
  • Browsing history
  • Search history
  • Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Unique Personal Identifier
  • Online Identifier
  • Beacons
  • Pixel Tags
  • Mobile Ad Identifiers
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
We collect your internet or other electronic network activity information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
  • Geolocation Data
    • Location information
    • Device location information
    • To enforce the Terms of Service or Use of any of our websites, applications or services;
    • To prevent fraud;
    • To provide you with targeted advertising based on your activity on our sites;
    • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
    • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
    • To debug, to identify and repair errors that impair existing intended functionality; and
    • To investigate and prevent activities that may violate our policies
    We collect your geolocation information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
    • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

    In the preceding 12 months, we have not sold Personal Information about consumers.

    In the preceding 12 months, we have not sold Personal Information about minors.

    Individual Rights
    Right to Know About Personal Information Collected, Disclosed, or Sold
    You have the right to request that No WiFi Games disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

    Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

    Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

    No WiFi Games does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless No WiFi Games determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

    Right of Deletion
    You have the right to request that No WiFi Games and our service providers delete any Personal Information about yourself that No WiFi Games has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

    Submitting Requests
    You may submit a request through a webform available by emailing us here or send us a request to our support center inside our game.

    Verifying Requests
    No WiFi Games provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. No WiFi Games must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. No WiFi Games reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

    Authorized Agent
    You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests known as an Authorized Agent. If you choose to use an Authorized Agent, No WiFi Games requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with No WiFi Games. Failure to do so may result in No WiFi Games denying your request.

    Right to Equal Service
    No WiFi Games will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

    California Privacy Rights: Shine the Light

    Under California’s Shine the Light law, California residents who provide certain personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

    To obtain this information please contact us at the information provided below. We will provide the requested information to you pursuant to the contact information provided to us.

    Please be aware that not all information sharing is covered by the Shine the Light requirements and only information on covered sharing will be included in our response.

    A Note to EU Citizens

    No WiFi Games complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:

    For more information on how to action these rights please contact us here.

    If you have a concern about our handling of personal information, please get in contact with us first so we can try to resolve your query. If however you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to your local data protection regulator.

    Contact us

    Please feel free to contact us if at any time you have questions or concerns about our Privacy Policy, or if you are a parent and you have questions about your childs use of the apps.

    Consumer Affairs
    No WiFi Games, LLC
    1425 Casa Buena Drive, Unit 105
    Corte Madera, CA 94925

    You may also email us here or call us at 706-616-5493.