Privacy Policy

Welcome to Yeti Delight 3 (our “APP”) and thank you for your interest in this Privacy Policy! We know that the handling of your Personal Identifiable Information (PII) is important to you and because of that we take the greatest possible care to handle your PII in accordance with the Georgia Computer Data Privacy Act (“GCDPA”) and the General Data Protection Act (“GDPR”).

When designing the APP, we also have made sure that as little as possible information that directly identifies you is collected. As however some countries including the European Union, have a broad definition of PII, this policy covers it. In this sense we would need to first of all explore the definition of PII.

“PII” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Who are we?
The responsible entity is:

Skybreak Technologies, LLC
3000 Colonial Center Parkway
STE 100N
Georgia, USA

E-Mail: support.yd3@skybreaktech.com

Legal bases for processing
The processing of your PII may be based on the following legal grounds:

• consent,
• the performance of a contract,
• the adherence to a legal obligation,
• our legitimate interest.

What are your rights?
according to the GCDPA and the GDPR, you have the following rights with respect to us processing your PII:

• Right of access
• Right to rectification
• Right to restriction of processing
• Right to erasure
• Right to information
• Right to data portability
• Right to object
• Right of withdrawal

To assert these rights, please contact us at any time using the details provided above. You also have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority.

Accuracy and updating your information
If you believe that the PII, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer your requests. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of PII, notably where such requests would not allow us to provide our service to you anymore.

Collection of PII
PII may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our APP. As indicated above we have made sure that as little as possible information that directly identifies you is collected.

a) When you create an account
When you start the Game for the first time, an account can be created by providing a Username, your e-mail and password, with the provider PlayFab – Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. PlayFab processes your account data and your Device ID according to its own Privacy Policy. We would like to point out that this policy does not replace Microsoft`s Privacy Policy and merely supplements it when you use our Game and services through PlayFab.

Lastly, your use of PlayFab and its functions is at your own responsibility. In particular you should note that PlayFab may uses your data for market research, advertising purposes and to create profiles about your usage behavior and your interests. For further information about PlayFab’s use of your personal data, please refer to PlayFab’s Privacy Policy. The legal basis for the use of PlayFab is our legitimate interest and/ or a contractual or precontractual measure.

b) When you contact us
If you contact us per e-mail, your transmitted PII will be automatically stored for the purpose of processing the request or contacting you. We delete the data accruing in this context after the storage is no longer necessary for the processing of your request or restrict the processing if there are legal retention obligations. The legal basis for processing is our legitimate interest and/ or a contractual or precontractual measure.

Automatically collected data
a) Downloading the APP
The APP can be downloaded from the “Google Play Store” a service offered by Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service “App Store” a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP.
Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

b) Installing the APP
As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which PII Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which PII Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

c) Device information
We or rather Google and Apple on our behalf collects information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass and Payment Data and Billing confirmations.

How we use information?
The main reason we use your data is to deliver and improve our services as follows:

• to provide our APP to you,
• provide you with customer support and respond to your requests,
• to improve our APP and develop new features and services,
• retain data related to fraudulent activities to prevent against recurrences,
• to ensure legal compliance,
• analyze your profile, activity on the service;
• assist law enforcement, and
• enforce or exercise our rights.

How long do we store your data?
We keep your PII only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your data upon deletion of your account (following the safety retention window), unless:

• we must keep it to comply with applicable law,
• we must keep it to evidence our compliance with applicable law,
• there is an outstanding issue, claim or dispute requiring us to keep the relevant data until it is resolved, or
• the data must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.

Keep in mind that even though our APP is designed to carry out data deletion processes according to the above standards, we cannot promise that all data will be deleted within a specific time-frame due to technical constraints.

Duration of data storage
In general, your APP data is saved and stored in part on your device and through the PlayFab Services on secure servers, and we only store PII for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.

How do we protect your data?
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your PII. As with all online technology, we take steps to secure your data, however we do not promise, and you should not expect, that your PII will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. Upon becoming aware of a data breach, we will notify all affected individuals whose PII may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

How we share your data?
We may disclose your PII to third parties:

• for the purposes of providing services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, in connection with your use of the APP,
• in the event that we sell or buy any business or assets, in which case we may disclose your PII to the prospective seller or buyer of such business or assets, or
• if we or substantially all of our shares or assets are acquired by a third party, in which case PII held by us about our customers will be one of the transferred assets.

We may also disclose your PII to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the APP, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity.

Obligation to provide PII
You are not obliged to provide us with PII. However, depending on the individual case as described above, the provision of certain PII may be necessary for the provision of the services. If you do not provide us with this PII, we may not be able to provide the requested service.

Do Not Sell
We do not sell data to third parties. However, we might, making available, transfer, communicate electronically, PII to a business affiliated inclusive with a third party but not for monetary but for other valuable consideration.

Advertising
Advertisers and third parties also may collect information about your activity on our APP, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our APP and on third-party sites and applications.

You can opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

Authorizations and Access
We may request permission to store your APP data including your Internet Connection and Network State of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.

Uninstall
You can stop the collection of information by our APP by uninstalling it using the standard uninstall procedure for your device.

Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.

Changes
Because we’re always looking for new and innovative ways to improve our APP, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

Queries and Complaints
Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.