Privacy Policy

Effective Date: May 1, 2022

This Policy describes the ways in which the company collects and uses information about you when you play the company’s product which accessed via Apple’s ‘App Store’, Google Play.

Who this Policy applies to:

Starnursery limited and its affiliates (“Studio” “us”, “our” or “we”) develops and publish games for mobile devices. This Privacy Policy (this “Policy”) describes the ways we collect, store, use, and disclose the information, including personal information, and data that our users (“users” or “you”) provide or we collect in connection with the Studio website available at starnurseryfly.com and any Studio game provided on a mobile platform (each a “Service,” collectively, the “Services”). Additionally, this Policy describes your rights and choices concerning your information.

Please note that the scope of this Policy is limited to information and data collected or received by Studio through your use of the Services. Studio is not responsible for the actions of individuals with no relationship to Studio or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

If you do not want Studio to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.

Information the company collects and uses if you contact us or make complaints:

When the company receives complaints by email it files any relevant document and may retain details of the complainant and other individuals identified in the complaint. The company will only use this information to process the complaint and to check on the company product’s services and staff. Subject to mandatory law, the company shall retain information in relation to a complaint for 7 years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis.

Information the company collects when you use the company’s products:

The company may collect the following related information when you use the products: if you sign into one of the products through a social network the company may be able to access certain information about you through that Social Network. The company will only access information which you have agreed to make available as part of your membership of such social networks. You can change what information the company can access by changing your privacy features on your social networks; Information in relation to your purchases within the products, these are handled through the platform on which you purchased the product or other payment processors. The company does not retain any card or payment details. The company does keep a record of your purchases and your aggregate spending; and your Unique Device Identifier or a record of the internet browser which you are using when you use the product. This may provide the product with an approximate location as to where you are using the product and on what device.

In some function of our service, such as leader board and social system. We need collect and share your game information among users. Those data including:

Your name in game
Your avatar in game
Your scores or coins
Some other basic statistics, such as wining rate

For continuously improve our app and provide more better experiences, We and our service providers may use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:

IP Address
Platform Type
GPS Location
Your operating system version
Your mobile device’s identifiers

We may collect and store some of those information shared by the provider of the connected third-party application:

First Name and Last Name
Your profile picture’s URL
Your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo
The user ID number and other public data for your friends
Your gender

any other information that you or the provider of the third-party application share with our game

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more plolicy about their privacy practices.

How we uses information collected from you when you use the products:

The company may use the information it collects from you described in part 3 above to: tweak, tune and facilitate the improvement of the product and your experience of the product; provide advertising within the product which is more relevant to you (for example, which is based on your location and information made available through your social networks); allow you to partake in the product as social games, for example if you wish to play as part of a ‘Team’. Your information (for example your Apple Game Centre Name, your name and photo from social networking platforms or any ID which you have given us) may be shared with other players and within your social networks. You may also share elements of your performance or participation in the product with other players and your social networks and invite other people to play with you; complete your transactions in respect of your purchases within the product; provide technical support in relation to player enquiries and troubleshooting; prevent fraud or illegal activities; share this information with the following third parties for the following purposes: any third party, such as group companies, processing data on behalf of the company; The company’s online partners to serve adverts within the product. The company may share your anonymized Unique Device Identifier and other relevant data with you with its partners to ensure that the ads you receive are relevant to you; your social networks (including Facebook), who may combine this information with other information they hold about you – you should refer to your social network’s privacy policy to see how they will use this information; any third party, in relation to the sale of some or all business, or its assets, or as part of any business restructuring or reorganization. The company will take steps with the aim of ensuring that your privacy rights continue to be protected; or law enforcement agencies in compliance with law enforcement.

Why we collect your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

where you have given consent
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create adn manage your account with us	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
Providing services and/or the functionalities of the app to you	Depending on the circumstances: To perform our contract with you or to take steps at your request before entering into a contract. For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us	To comply with our legal and regulatory obligations OR for our legitimate interests or those of a third party, ie to minimize the risk of account or identity theft or fraud that could be damaging for you, a third party or us
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: To comply with our legal and regulatory obligations. In other cases, for our legitimate interests or those of a third party, ie to protect our business, interests and rights or those of others
Communications with you not related to markeing, including about changes to our terms or policies or changes to the app or service or other important notices	Depending on the circumstances: To comply with our legal and regulatory obligations. In other cases, for our legitimate interests or those of a third party, to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training and quality control or to provide support to you	For our legitimate interests or those of a third party, ie to be as we can so we can deliver the best service to you at the best price
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, ie to be as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: To perform our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. Where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations, eg to record and demonstrate evidence of your consent to our use of your personal data where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests or those of a thirdparty, ie to promote our business to existing and former customers. See ‘Direct Marketing’ below for further information
We may need to share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: To comply with our legal and regulatory obligations. In other cases, for our legitimate interests or those of a third party, ie to protect, realise or grow the value in our business and assets

International transfers of data

The data that we collect from you will be transferred to, and stored at, destinations both within and outside the EEA. We may disclose your personal data to our group companies and their service providers located in US and elsewhere, and to employees operating outside of the EEA who work for us or for one of our group companies or their respective service providers.

We want to make sure that your personal data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data. For example, this could be:

by way of an intra-group agreement between Starnursery entities, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws;
by way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws; or
by transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer your data to a benefits provider based outside the EEA); or
where you have consented to the data transfer. Where we transfer your personal data outside the EEA and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

Security:

The company has implemented technology and policies to safeguard your privacy and personal data from unauthorized access and improper use. You may also change your account settings on your social networks (e.g. Facebook) to prevent both us and third parties seeing information in relation to you.

The company’s policy towards children under 13:

If you are under 13 years of age or a minor in your country of residence, you need your legal guardian’s permission to use or access the product. The company’s product is intended for audiences aged 13 and above. However, the content of the product has been rated by Apple as being acceptable for ages 4 and above. The company does not request, seek or track the age of its players and so any individual who has access to a device of any age may play our game and, if unsupervised, make purchases without the device owner’s permission. If as a parent or guardian of an under 13 or a minor, you have any concerns about our Policy or you have experienced issues with purchases been made using your device without your permission please contact us. Please note that it is the platform providers (e.g. the Apple App Store, Google Play etc.) not the company who control the payment process for in app purchases. Thus, any queries or application for refunds should be made directly to the platform provider. However, should you wish to contact us we would be more than happy to discuss any query you have with you. Information on how to complain about purchases can normally be found within invoices from platform providers.

How to Delete

You have the right to request us delete the personal information that we collected from you and retain, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If you want to delete your account or information, please contact us by this email: support@starnurseryfly.com

Contact

If at any time you would like to contact the company about your views on this Policy or any enquiry relating to your personal information you can do so by sending an email to us.

please email to: support@starnurseryfly.com