Privacy Policy
Last updated: September 1, 2024
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Introduction
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This policy gives a description on how SmallStep (“us”, “we”, or “our”) collects, uses, shares, and protects
information about you for our games on mobile devices, PCs, or on other platforms in order to provide you with
excellent service and
develop our products.
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All SmallStep activities regarding marketing, advertising, and other services (“Services”) are governed by
this
Privacy Policy. Using or accessing a Service on any platform means that you agree to the use of your
information
in
compliance with
this Privacy Policy. This policy also describes how you can withhold or withdraw your consent to the use of
your
data, including for targeted advertisements, and how to request to know about, correct, or delete the
information
we
hold.
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SmallStep is dedicated to transparency, data privacy, and security, and follows the strict regulations
required
by
the CCPA (California Consumer Privacy Act), LGPD(Lei Geral de Proteção de Dados) and GDPR (General Data
Protection
Regulation),
as detailed in this privacy policy.
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If you have any concerns, please contact us using the methods provided in the Contact Us section of this
document.
If you disagree with your information being used as described in this Privacy Policy, please do not install or
use
the Services.
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Information Collection
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Your information is collected at the start of using our games and/or other Services. We use this data to
provide
you
with better game experiences and services for the purpose of optimization, preventing fraud, and for marketing
and
advertising.
We may also collect information from advertising platforms and partners and other third parties such as
information
about purchases and interests.
- We may collect and process the following types of information:
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- The type of your device, IP address, your game ID when using the app, and the country or region that
you’re playing in;
- Details about your gameplay on our app, including: amount of time played, if you have left the game
on a specific level or if you have cleared it, and your scores on levels, and items you own or use;
- Purchase history on behalf of our payment service providers to keep a record on if a purchase has
been successfully made.
- We do not collect credit card information. Information we collect via cookies and other similar
technologies, as explained further below;
- Communications between you and us, whether in-game, via email, or through social media channels. We
keep a record of these communications to provide customer service by answering your questions and
providing you with a better experience using our app;
- Information from our other group companies or other third party companies who have your consent or
have other legal rights to share granted information with us (advertising networks and publishing
partners, platforms). This may include your interests, other games you played, demographic and general
location information. We use this information as described in this Privacy Policy;
- Information as further set out in this Privacy Policy, including social sharing features , marketing
and advertising If you choose not to connect to your social network accounts when using our games, we
still collect anonymous information. There will still be device level identifiers and other
information described here, but there will be no personally identifiable information.
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We may ask for your approval to collect other information in some circumstances from you or your device. If
this
situation arises, we will inform you what information we are to collect, the reason we collect it, and how we
will
be using that
information.
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How do we use your information
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Information Usage and Sharing
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Optimizing Our Services We analyze and optimize to provide you the best possible products by using your
information
from the use of our Services and analysis of de-identified or aggregated data to analyze the performance
of
our
games,
troubleshoot problems, verify that our websites work properly on all devices, create updates, and develop
and
improve the quality of our products.
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Customer Services
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We may use your information delivered or provided directly to us in any communications in terms of
customer
service
and through its channels will be used. We may use such information to contact you and to manage your
account and
relationship
with us to improve your experience in our Services.
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Analytics and Research
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We collect information using analytics tools such as third party analytics tools to see how you play our
games
or
use our Services. Those tools may contain cookies or other similar tracking technologies. We may use your
data
for
research and
analytics purposes to engage with you directly. We may also create reports, analysis or similar services
for use
by
us for the purposes of research or business intelligence.
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Other Usage and Sharing
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The other main way that we use and share information is for marketing and advertising reasons. This usage
is
described in more detail below. We do not sell your information.
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Marketing
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We may serve ads based on your information we collect about you within our Services, or place ads on third
party
websites, apps and internet-connected devices. This information may include:
- Ad identifiers and other non-personal information collected from your device
- Your interactions with our game and Services, including game play information
- Your age, country or region, and gender
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Other information collected from third parties who have obtained your consent or have a legal
right to share
it
with us.
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This information is used to try to make sure that you only see marketing from us that you
are
interested
in, including
our other games. Please note that if you opt-out, you may still have advertisements in the game,
but they will
not
be targeted advertisements (advertisements that are tailored to your interests by using your
information).
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Marketing Partners
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There are various third party marketing partners we use to help market our games. With the help of your
information
collected when you use their services, they make assumptions to ensure that most relevant advertising that
you
would
prefer to
see is presented and evaluate the effectiveness of advertisements.
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This Privacy Policy does not cover the data use of our marketing partners, but they are required to have a
legal
basis to use your data for marketing purposes and to provide you the details on how it’s being used. For
more
information we
recommend for you to read our partners’ privacy policies on their websites
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Marketing Partners
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Advertising
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Our games include advertising for third party products and services. We and our partners use your
information to
improve advertising and targeting for third party ads that are shown in our games. This information is
used to
make
sure that the
ads that you see might be of interest to you or relevant to you.
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This information may include:
- Ad identifiers and other non-personal information collected from your device
- Your interactions with our game and Services, including game play information
- Your age, country or region, and gender
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Other information collected from third parties who have obtained your consent or have a legal
right to share
it
with us.
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Please note that if you opt-out, you may still have advertisements in the game, but they
will not be
targeted
advertisements (advertisements that are tailored to your interests by using your information).
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Advertising Partners
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Non-personal identifiers and other information that is collected from your device when you play our
games or
use
our
Services may be shared with advertising partners in order to deliver ads to your device. Such
information may
be
combined with
information that our advertising partners collect separately to serve you with more relevant ads
(targeted
ads)
and
to enhance the accuracy of their targeting. For more information we recommend for you to scan through
our
partners’
privacy
policies on their websites
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Ad Identifiers
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We use ad identifiers that are non-permanent, non-personal identifiers such as the Android and/or
Apple’s ID for
advertising associated with your device, and similar technologies such as tracking pixels within ads
to provide
interest-based
advertising. These technologies enable us and our third party advertising partners to recognize you
and your
device,
allow our Services to interact with a third party social network or platform, and help our payment
processors to
complete your
payment instructions.
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Your Rights and Control of Data
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Right of Access / Right to Know
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All users have a right to know what information we collect about them and how we use or share that
information. If
you wish to know which information we collect and hold about you, please use the methods described in the
Contact
Us
section so
we can verify your identity to provide you with requested information. You may only request your own
personal
information, and information will not be provided about other users. You will be required to follow the
verification
process listed
under the “Verification Process” section below for security reasons.
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Information Correctness
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If there is any information we hold about you that you would like to correct, please let us know using one
of the
methods listed in the Contact Us section. We will make corrections as soon as possible. You will be
required to
follow the
verification process listed under the “Verification Process” section below for security reasons.
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Data Retention and Deletion
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How long we retain your information depends on why we collected it and how we use it. We generally retain
your
personal information as long as your account is active and for no longer than is necessary for the purpose
for
which
such personal
information is processed. Please note, however, that we may retain and use your personal information as
necessary
to
comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it
is not
technically
and reasonably feasible to remove such information from our databases. Consistent with these requirements,
we will
endeavor to delete your personal information promptly upon your written request.
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Verification process
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If you request to know about, correct, or delete your personal information, you will be required to open
the
relevant game to send us a second message using the in-app messaging system to allow us to verify your
user ID and
use that ID to
retrieve any requested information. Without this step we will not be able to verify and provide
information
related
to your account.
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Data Portability
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You have the right to request the data provided to us to be transferred to another data controller in some
circumstances according to the laws in the country where you live.
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Restriction of Processing
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You may request a restriction of the processing of your data in some circumstances according to the laws
in the
country where you live.
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Right to Object
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You have the right to object to the processing of your personal data in some circumstances according to
the laws
in
the country where you live.
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Authorized Agents
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Authorized agents, including parents or guardians, may make a request on behalf of the user in the same
ways as
listed above. If you have any questions, please contact us using one of the methods listed in the Contact
Us
section.
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Opt Out
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Direct marketing Please follow the opt out link included with our marketing communications (such
as emails) if
you
would not like to receive direct marketing communications from us. If you receive more than one
type of
marketing
communications, you may need to opt out of all of them individually. A few days might take for our
records to be
effectively updated.
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Push Notifications We may occasionally use push notifications to send you game updates or other
services-related
notifications that may be important to you. You may opt out from receiving these types of
communications at any
time by turning
them off for your phone or tablet settings.
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Preferences for Advertising You may reset your ad identifier being used for interest-based
advertising by
changing
the settings of your device, usually found under “privacy” or “ads”.If you would like to withdraw
your consent
for
targeting
advertisements, please contact us using one of the methods in the Contact Us section. Please note
that if you
opt-out, you may still have advertisements in the game, but they will not be targeted
advertisements
(advertisements that are
tailored to your interests by using your information).
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Other Important Policies
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California Privacy Rights
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According to the California Consumer Privacy Act (CCPA), users who are California residents may request
and obtain
a
list of the Third Parties to whom we have disclosed their personal information (if any) and the type of
personal
information
disclosed to those parties during the prior calendar year. This list may be requested once per year and
free of
charge.
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Non-Discrimination
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Users have the right to not receive discriminatory treatment by the business for exercising privacy rights
according to the CCPA and other relevant data privacy laws and regulations.
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Updates to Our Privacy Policy and Practices
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We may revise this Privacy Policy from time to time, as needed. We will notify you via our apps if there
are any
material changes that affect your use of our services, as required by applicable laws. Changes will also
be posted
on this website,
and the revised version will be applicable immediately after it is posted or notice is received. If you
continue
to
use our services after any changes have been made, you hereby provide your consent to the changes.
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We commit to provide information to our users before using their information for any new purpose not
stated in
this
Privacy Policy and give them the opportunity to opt out if they do not agree. If consent for information
usage or
processing is
required by law or contract, Sonio Studio will comply with the law or contract.
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Contact Us
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If you have any questions or concerns about this Privacy Policy, including to exercise any of your rights,
there
are
several ways to contact us: email to
xiaobuinfo2019@gmail.com