latest update 2021 Apr 20


and its subsidiaries and parent companies (collectively, “”, “we”, “our,” or “us”) represent company that develop, produce and distribute products and services for its customers worldwide.

This is our privacy policy (the “Privacy Policy”), which explains how we collect, use and share data through our mobile applications (the “Applications”), our websites (the “Websites”), our pages or presence on third party websites (e.g., Facebook) (the “Third Party Platforms”) and other platforms, websites products, offers and services that we offer from time to time, all of which together we refer as “Services” or “Service”.

This Privacy Policy applies when you use our Services. Please read it before using our Services.

“” in this Privacy Policy refers to us and any other corporate entities within the same corporate group (including parent companies and subsidiaries) (“Affiliated Entities”).

If you do not want to collect, store, use, or share your personal information in the ways described in this Privacy Policy, you may not use our products or use our services.

Our Privacy Policy applies whenever you use our “Services” which, as we described above, means our products, products, services, content, our websites, for example at and/or other domains or websites operated by . It describes the ways we use your (personal) data and your rights.

Regardless of whether you are located in or outside of the European Union or European Economic Area, us are the “joint data controllers” of your personal data. We will refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in our Privacy Policy.


Data sharing | Children online privacy | Terms of use | Data collection | Use of data | Subjects rights | Linked third party data | Transfer of data | Data retention | Security of information | California residents notice Lei Geral de Proteção de Dados


We will collect and store any data that you provide to us, including when you create your account or a customer profile while using our products.

1 Data about you that you give us directly

While you use our products, you may give us data directly (like when you are setting up your account), and we will store that data on our databases and use it for the purposes described in this Privacy Policy.

When you use our products you may give us the data like:

  • first and last name
  • nickname
  • gender
  • age
  • e-mail address; or

other information that helps us make sure it is you accessing your account or helps us improve our Services

You may also create a customer profile in our product which other customers can see and which may include the data like:

  • profile photo (for example while connecting by Facebook)
  • first and last name
  • nickname
  • gender
  • age
  • physical location data that you provide
  • customer ID that is created by us and used to identify your product account.

2 Information about your contacts

When you connect to our product by Facebook, we may also collect information that you provide to us about your Facebook Friends’ List, but be sure to ask their permission first.

3 Data generated using our products

When you use our products, we collect data about the ways in which you use and interact with our product, such as when and for how long you use, product features and other customers you interact with, purchases you make, progress or levels you achieve, and other scenario activities. If you choose to use communication features in Services that allow you to communicate or share information with other customers, then wewould collect information on what is communicated or shared. This may include your in-product actions like:

  • participation in chats
  • public posts or comments on other customers’ profiles
  • non-public messages or invitations to other customers
  • chats with other customers
  • events in our products

We may access in real-time, record, and/or store archives of these communications, comments, and other user-generated content on our servers to make use of them to protect the safety of our customers; to protect our rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our customers’ experiences, including through the use of analytics; and to manage and deliver (tailored) advertising. Where required by law, we will seek your consent for this.

4 Payment data

We also collect data related to any purchases you make.

If you purchase in-product virtual currency, our third-party payment partners will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address, and financial data. Our payment partners do not share your financial information, like credit card numbers, with us, but they may share non-financial data with us related to your purchases, like your name, and the items purchased.

When you use our products connected third-party applications or platforms (like Facebook, Apple or Google), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, does not receive your financial data, but may receive non-financial information related to your purchases, like your name and the items purchased. The information receives depends on our product you are playing and the third-party application. Our Terms of Use explain our policies and terms related to charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

5 Support correspondence

When you ask for help from our support team, we may collect and store the contact information you give them (generally, your name, e-mail address, customer ID), data about your product use or your activity in a product. We will also store the communications you have with our support and any additional information in those communications in order to provide support and improve the Services. Please note that in many cases in order to identify you we will need a minimum amount of data (e.g., customer ID). Without this information, we will not be able to provide support or answering to your data rights’ requests (as mentioned in Section 5 below), so please be aware that we may contact you and request additional information in order to provide service.

We work with processors based in the United States as well as other countries, which provide an online helpdesk and in-app support systems. When you contact us for support, the below information will be handled by our processors strictly in accordance with our instructions:

  • product you are playing
  • name or nickname
  • e-mail address
  • platform you are playing on
  • problem description
  • language
  • customer ID or
  • Facebook ID.

Our processors also automatically collect additional types of data, such as your IP address and data sent by your device to provide and improve their service. The data is then transferred to a processors’ servers in the United States. As a safeguard to protect your privacy, we arranged a data processing agreement with our support partners or joint sharing personal data agreements (where our partner is also a data controller of the personal data), where we ensure that your personal information is only used in accordance with our instructions and not for their own purposes or are used in accordance with the applicable law requirements or our contractual arrangements with our partners. In addition, your request is submitted via an encrypted connection and we apply the principle of data minimization to collect only such data that is actually required to best answer your support request. The content of your request will be stored as long as you are an active customer of our product, so you can get a faster response in case you have a similar problem in the future. The purpose of using the service support partners is to answer the extensive number of user requests we receive. Our support processors help us to improve our customer service so that you can get a faster and helpful response.

6 Data about you from third-party partners

We collect some information from other entities, including social networks like Facebook, if you access our products through your accounts with those entities or you choose to connect your accounts with those companies to our products.

If you use our products through any third-party applications, including Facebook, may receive certain data about you from the provider of the third-party application. The information we receive depends on ourproduct you are playing, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application. For instance, we may collect and store some or all of the following information from the provider of the connected third-party application:

  • first and last name
  • profile picture
  • your user ID (Facebook ID), which may be linked to publicly-available information (public profile) like your name and profile photo
  • your friends’ list and other public data
  • e-mail address you provided to that third-party application
  • physical location and that of the devices you use to access our Services
  • gender
  • age

information about your activities on or through the connected third-party application

other publicly-available data on the third-party application; and/or

any other information that you or the provider of the third-party application share with us.

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 use and their privacy policy.

7 Cookies

We collect information about your device and how you use our products, including using cookies.

As further described in our Cookies Policy, we use cookies to recognize you and/or your device(s) on, off, and across different Services and devices. We also allow others to use cookies and similar technologies as described in our CookiesPolicy. You can control or opt out of the use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising, as described in our CookiesPolicy.

We, our service providers, and our partners use cookies and other similar technologies to collect and analyze certain kinds of technical data, including:

  • IP address
  • type of computer or mobile device you are using
  • platform type (like Apple iOS or Android)
  • operating system version
  • mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), Android Advertising ID (AAID), and/or Google Advertising ID (GAID)
  • browser type and language
  • number of clicks on an app feature or web page
  • amount of time spent on an app feature or web page
  • pages viewed and the order of those pages; and/or
  • product state and the date and time of activity on our product

If you use our products on a mobile device, in addition to your device identifiers (described above), we may also collect:

  • name you have associated with your device
  • country
  • telephone number (if you provide it)
  • specific geolocation (with your permission)
  • mobile contacts (with your permission, as described below).
  • 8 Other

We may collect data from other third-party sources. Where we do, we let you know.

We may collect or receive data about you from other sources like third-party data providers. We use this data along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.


We use your data to provide, personalize, maintain the security of, and improve the products you use; to maintain our business operations; and to exercise, defend or establish our rights.

We use your data under several legal grounds, including:

  • to perform our contract with you
  • for our legitimate business interests
  • to comply with our legal obligations
  • your consent.

The use of data we collect and store is to provide you with the Services you request from us and to improve your in-product experience, but there are other uses as well. The uses for which we collect and store your data include:

  • to improve and optimize our products and your experiences in our products
  • to create your customer accounts and allow you to use our products
  • to identify and suggest connections with other customers and personalize our Services to you
  • to communicate with you, including in-product updates and notifications, new Services, and promotional offers that we think might be of interest to you
  • to enable customers to communicate with each other
  • to provide support and respond to customer requests
  • to protect the safety
  • to protect our rights and property in connection with our products
  • to prevent fraud or potentially illegal activities, and to enforce our Terms of Use
  • to manage and deliver customized advertising
  • to administer promotional activities or events sponsored or managed by us or our partners
  • to comply with our legal obligations, resolve any disputes we may have with you or other customers, and to enforce our agreements with third parties.

If you are located in the European Countries, our legal basis for collecting and using the data described above depends on what data is and the context in which we collect it.

However, we normally collect data from you only where we need it to perform our contract with you (i.e., our Terms of Use), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if yougive us your consent.

In some cases, we may also have a legal obligation or need to collect data from you or may otherwise need the personal data to protect your vital interests or those of another person (for example, another customer). If we ask you to provide data to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your data (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Use), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing data is mandatory.

Similarly, if we collect and use your data in reliance on our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and direct marketing, for example).

If you have questions or need further information about the legal bases on which we collect and use your personal information, please contact us at any time.


We share some of your data with your friends and other customers that you are playing with to facilitate your in-product interactions. We may also share your data with third parties or allow third parties to collect this information from our products in the following manner:

1 Friends and other customers

Our products support encourage you to interact with other customers. In most products, if you use them through a social network or connect to a social network (like Facebook), your friends who also use the product will see your name, photo, customer profile and descriptions of your in-app activity.

Further, in our apps other customers (not being your friends) will be able to see your customer profile; view descriptions of your in-product activity; communicate with you within our products and send you app requests or friend requests through our products.

2 Third-party advertising and analytics

From time to time we will update our webpage at with privacy policies from our third party partners. Please visit this webpage to learn more about the General Data Protection Regulation (GDPR) as well as to read more about our third party partners.

We share some of your data with advertisers to tailor the advertisements you see when you use our Services to your interests and to enable us to offer some of our Services for free.

We use advertising to enable us to offer some of our products for free. These advertisements may include, without limitation, banner ads on in a app, as a full-screen ads between moves which third-party advertisers offer to provide in-app items to customers in exchange for watching an advertisement or for completing a task. Offers are hosted by third-party offer wall providers, and the offers are made by third-party advertisers or by us (in case of showing our advertisements).

We do not actively share personal data that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

To enable advertisers and ad media partners to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of data when you use our products:

  • performance data (like the number of clicks on an advertisement)
  • certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID, Apple ID, Google ID) ; and/or
  • a unique identifier, such as your Facebook ID or your customer ID

In addition to serving you with relevant ads, the data collected may be used to:

  • measure how effective ads are
  • offer you targeted advertising (both on and off our products) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
  • undertake web analytics to analyze traffic and other customer activity to improve your experience.

Ad networks may collect this data through the use of cookies and other similar tracking technologies, and they may use a single tracking technology or multiple tracking technologies at the same time.

After clicking on a third-party advertisement, you may no longer be on a site or app controlled by us through which you are using our products.

If you do want to receive customized in-application advertisements from third parties, your consent would be required. The practices of third-party companies delivering advertisements in our products are subject to those companies’ own privacy policies.

3 Security measures

We share your data if necessary for safety, security, or compliance with law.Your data and the contents of all of your online communications in our products and between you and may be accessed and monitored as needed to provide our products and may be disclosed:

  • to satisfy any laws or regulations that apply
  • when we have to disclose the information in response to lawful requests by public authorities
  • if our products are being used in committing a crime or to share data with other companies and organizations for the purposes of fraud protectionand other security precautions
  • to protect the rights or property of or applicable third parties.

4 Third-party service providers

We share your data with the third-party service providers and partners that we work with to bring you our products.

We will share your information with third-party companies who perform services on our behalf, like analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share your data with our third-party partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, Amazon, etc.). Where we share your data with third-party service providers and partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).

5 Other third parties

We may share some of your information with other third parties, if we have your consent to do so.

In addition to the sharing described above, we may share your data with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.


1 European Countries ‘Customers’ Rights

If you are a customer located in the European Countries, you have certain rights with respect to your personal information.

If you are located in the European Countries, you have the following rights:

  • You can access or request deletion of your personal information by submitting a request through the Contact Us link within our Applications or directly send us an email to our support team at support (at)
  • You can correct or update your personal information through the settings within our Applications or directly send us an email to our support team at support (at)
  • You may object to processing of your personal information
  • You may ask us to restrict processing of your personal information or
  • You may request portability of your personal information through the Contact Us link within any of our Applications or directly send us an email to our support team at support (at)
  • You can opt-in or opt-out of marketing communications we send you by following the instructions in “Opting in / Opt out of marketing communications from ” below.
  • If we have collected and processed your personal information with your consent, then you can withdraw your consentat any time through the settings within our Applications or by requesting this change through the Contact Us link within our Applications or directly send us an email to our support team at support (at) .com Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information which is to be in ’s case –the leading protection authority is Polish President of the Office of Data Protection. You may also contact your local data protection authority. For more information, please contact such authority.

To exercise your rights to access or deletion, please submit a request through the Contact Us link within our Applications or directly send us an email to our support team at support (at) We ask that you submit all requests through the Application itself to ensure that, at a minimum, we have sufficient information about the user to enable us to service the request. While you send us email message we may ask you to provide more information about you like: customer ID in our product. If you do not provide us with accurate information or we do not have access to your email address and your customer ID and sufficient consent, if required, we will not be responsible for failure to exercise your rights as we will not be able to identify you as our customer. We respond to all data protection requests we receive in accordance with applicable data protection laws.

2 Accessing and deleting personal data held by

You can request a copy of or deletion of your product account data through our product.

To review and update personal data (including given us consents) associated with your customer profile in certain products, visit “Settings” within that Application.

If you want to review or delete your product account, please submit a request through the Application itself or through our support.

For deletion requests, we will take reasonable measures to delete your personal data from our records. We will keep certain records (e.g., personal data relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We will also keep data in order to exercise, defend, or establish our rights.

3 Managing personal data from third-party applications and from your mobile device

To manage the information we receive from third-party applications and from your mobile device, use the settings provided by the third-party application and your mobile device.

You also can manage many aspects of data collection and use from your mobile device by visiting the “settings” of your mobile device or web browser and reviewing the access permissions of each product / application.

Once we receive your data from a third-party application / platform or your mobile device, that data is stored and used by us in accordance with this Privacy Policy. You may access and update that information as described above.

4 Opting In or Out of marketing communication with

You can unsubscribe from promotional emails by clicking the “unsubscribe” link. You can opt out of mobile push notifications in your device’s settings page.

If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn of push notifications by visiting your mobile device’s “Settings”. Many of our products also offer the ability to turn off push notifications in the in-product “Settings”.

Please note that if you opt in or out of receiving marketing communications from us, we may still communicate with you from time to time if we need to provide you with information about the products you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy, our Terms of Use or End User License Agreement.

5 Opting in or out of third-party tailored advertising

While you give us your consent for obtaining the personalized advertising from our third-party partners, you can opt in or opt out of third-party customized advertising through your device Settings and other third-party opt-in or opt-out tools.

If you do not want to receive tailored in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising.

All of the opt-in or opt-out tools described in this subsection are provided by third parties, not by us. does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive third-party advertisements in our products after using these tools, but the advertising you see would not be customized to your interests or needs.


We are not responsible for the ways in which third parties use your data (other than our partners acting under our guidance). Our websites and products may contain advertisements from third-party services that may link to their own websites or services. We are not responsible for the privacy practices or the content of these parties. If you have any questions about how these entities use your data, you should review their policies and contact them directly.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

We do our best to ensure that we do not collect information from or about children.Generally, our products are not intended for children under the age of 16 (collectively, “Children”). Children are not permitted to use our products, and we do not knowingly collect any personal data from Children.

Though our Services do not target Children, we may collect age information before allowing a customer to proceed for certain products. For customers who identify themselves as Children in our age-gate on such products, if we allow Children to use the products, we will either provide a version of that products that does not collect, use, or disclose “personal data” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA or obtain legally valid legal guardian consent.

If we learn that we have inadvertently gathered personal data that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.


When you use our products, your personal data may be sent outside of the European Counties, for example, to the United States, Israel and Hong Kong and possibly other countries. When we transfer, store, and use personal data collected in the European Countries outside of the European Countries, we comply with our legal obligations and ensure that your personal data is subject to suitable safeguards (such as encrypting communication) or transferred to “approved” territories.

As a global company, we may transfer your personal data to our “Affiliated Entities,” located in European Countries and outside like United States, Israel and Hong Kong which are any other corporate entities under common ownership with , or to our business partners and service providers from time to time for our legitimate business purposes. For example, provides certain services to its Affiliates.

We store personal data about customers and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, marketing communication with customers and product development. When we transfer your personal data internationally we will take reasonable steps to ensure that your data is treated securely, lawfully, and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your data is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

Additionally, if we share with entities which are not subject to the Privacy Shield framework, and we make sure that these entities ensure an adequate level of protection, the transfer is supported by the European Commission’s standard contractual clauses for the transfer of personal data to a country outside the European Countries. These standard contractual clauses are available here:

Participating European countries’ residents should direct any questions, concerns or complaints regarding ’s handling of personal data or compliance with the Privacy Shield to at:

ATTN: Data Protection Officer


We will answer your questions in a timely and complete manner. If, after discussing the matter with us, your question or complaint is not resolved.

If your complaint still is not resolved through these channels, an additional binding arbitration option may be available to you.


We’ll keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights.

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.


We work to protect your information but you as a customer also have to take certain steps.

We implement reasonable and appropriate security measures to help protect the security of your data and to ensure that your data is treated securely and in accordance applicable laws.

It is important that you protect and maintain your account’s security and that you immediately tell us of any unauthorized use of your account. If you access our Services through Facebook and your account is hacked or otherwise compromised, this may lead to someone accessing or deleting your product accounts without your permission. So, be careful to keep your Facebook account information, including your social network account password, secure as well. We urge you to log out of your account and any social network account you have used to access our Services when you are finished using them.


With respect to your personal data, Global Limited and are joint controllers, which mean that both, Global Limited and decide about purposes and means of processing (mentioned in this Privacy Policy).

Global Limited and as joint controllers have agreed upon the relevant arrangement determining their respective responsibilities for compliance connected with the personal data security.

Global Limited is the company responsible mainly for the distribution of products and financial service of products and is responsible mainly for the performance of information obligations towards the customers of our Services and for ensuring the performance of customers’ rights. To ensure the protection of your rights, Global Limited and have appointed a joint Data Protection Officer (please see Section 12 below).


has a Data Protection Officer (the “DPO”) who is the person at responsible for all matters related to data protection and privacy matters. The DPO is the designated contact for data protection issues for You can reach ’s DPO at the following address:

ATTN: Data Protection Officer

If you have a customer service-related issue, please contact our Support Team instead of contacting the Data Protection Officer.

If you want to request access to the information that has on file for you, please Support Team. If you want to request that correct any information that has on file for you, please Support Team. If you want to request that delete information that has on file for you, please Support Team.

Please be sure to include your name or your customer ID or address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.


Additional Privacy Information for product

productface is a social application platform, designed to enable you to interact in shared worlds, share your scenario videos and participate in scenario challenges. That means we need to collect your personal data in order to provide you with this experience.

You give us your personal data when you create an account, register for a live event or enter a challenge. Note that when you participate in live events or share your in-product video, your in-product actions and achievements, in-product username and your avatar/profile picture, team, and other components of your in-product profile will be visible to other event participants and to the other users.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the productface.

What do we do with data you provide us within productface

Apart from beforementioned in this Privacy Policy ways, we will use the information we collect about you as follows:

  • to administer productface (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee the platform’s stability and security) and to solicit your feedback;
  • to allow you to participate in interactive features of productface, when you choose to do so;
  • to personalise the content you receive and provide you with tailored content that will be of interest to you;
  • to provide you with your profile information to send to anyone you choose and to enable you to participate on the Platform and interact with other users;
  • to make your information available to other users in accordance with the privacy settings you chose for the respective information;
  • to show you content that is similar to content you liked or interacted with (by commenting and/or watching the content), content from your region as well as content from users you follow;
  • to show you advertisements that are relevant to you

Data we collect from you

When you create an account within productface, you may give us data such as:

  • profile photo;
  • nickname;
  • customer ID that is created by us and used to identify your product account.

You can choose whether to find other users of the Platform either through (i) your phone contacts or (ii) Facebook contacts. If you chose to find other users through your phone contacts, we will access and collect your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the Platform by matching them with existing users of the Platform. If you want to find other users through your Facebook contacts, we will collect your public Facebook information as well as names and profiles of your Facebook contacts.

However, productface revolves around uploading your scenario videos consisting of the product itself and image/video from your device’s front-facing camera. To that end you may give us:

  • your image and/or voice that you provide us by using your device’s front-facing camera. The use of your image means than we can store, copy, reproduce, distribute and make it available for other users
  • your device location information
  • metadata that are uploaded automatically when you upload video. In essence, metadata describes other data and provides information about your content that will not always be evident to the viewer. In connection with your video the metadata can describe how, when and by whom the piece of content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the video to your user account. Metadata will further consist of additional data that you chose to provide with the video, e.g. any hashtags used to mark keywords to the video or comments.


productface is not addressed to the children under the age of 16 and we do not knowingly collect any personal information from children under 16. Children under 16 should not use productface at any time. If we learn that we have inadvertently gathered personal information from a child under 16, we will take reasonable measures to promptly remove that information from our records. If you become aware of any data we have collected from children under the age of 16, please contact us at your earliest opportunity using the Contact Us link within productface.


A company that is subject to California Civil Code Section 1798.83 is required, if engaged in sharing data with third parties for direct marketing requests, upon request from a user, to disclose to its users the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal data disclosed. The company is required to respond to this request once per calendar year. Our California-resident customers should make any such request through the Contact Us link found in our Applications or by contacting the DPO.

A company subject to California Business and Professions Code Section 22581 is required to allow any California resident under age 18 who is a registered user of an online site, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances. Our California-resident users should make any requestto remove any content or information that they have publicly posted through the Contact Us link found in our Applications or by contacting the DPO.


We let you know about any material changes to our Privacy Policy. If we decide to make material changes to our Privacy Policy, we will tell you and other customers by placing a notice in-product or on our website at or by sending you a notice to your e-mail address we have on file for you before the change becomes effective (and we will ask for your consent where required by law).

Please also periodically check at for updates of this Privacy Policy.

Lei Geral de Proteção de Dados

We will be updating those existing Ads data protection terms to add LGPD-specific terms. Our status under the LGPD as either a controller or processor for each Ads product will be the same as under the GDPR. The LGPD terms will be incorporated into our existing Ads data protection terms, so no action is required to accept the LGPD terms where the existing Ads data protection terms already form part of your contract.

If your existing contract does not incorporate our existing Ads data protection terms, please contact us for more information on how to accept the terms in the relevant Ads product UI.

In addition to the updated LGPD terms, we offer product controls that our Ads customers may utilize as part of their LGPD compliance strategy. If you believe you may be in scope of the LGPD, we recommend that you work with your legal advisors to determine how to comply with the LGPD, including how to use the options we offer.


We welcome you to use the services of , Inc. and its affiliates (“, “we”, “us”, “our”). We provide mobile and online services, including but not limited to product applications (the “product(s)”), and the related website located at and its subdomains (the “Site”), (the products, the Site and other products, mobile applications, services and websites provided by us collectively, the “Service”).





These Terms of Use (collectively, the “Terms”) set forth the legally binding terms and conditions which are applicable to your use of the Service, however installed, accessed and/or used, whether via personal computers, mobile devices or otherwise. Please be reminded that the Terms constitute an agreement between you and us and define the rights and responsibilities that you have with respect to the Service. It is important that you read and understand the Terms. By downloading, installing, accessing or using the Service (including products) you confirm that you have read and understood the Terms and any other documents referred to herein, including without limitation in our Privacy Policy part and that you agree to be bound by this agreement whether or not you are a registered user of any of our products. Consequently, if you do not accept or understand the Terms, please do not use, download, access or register with the Service. If you do not agree to these Terms, you are not entitled to use the Service and you must promptly uninstall and delete all copies of any products.

The terms “you” and “user” shall refer to all individuals and entities that access the Service. You represent and warrant that you have the right, authority and capacity to accept these Terms and to abide by them and that you have fully read and understood the Terms.

In addition to these Terms, you agree to abide by any supplemental policies of the Service, such as policies related to specific services (including without limitation forums, chats, contests or sweepstakes) as well as all other operating rules, policies and procedures that may be published from time to time on the Service, each of which is incorporated herein by reference.

Modifications To These Terms Of Use

From time to time, we may modify or amend these Terms. If we do so, we will post any such modifications or changes in the Service. You can tell when changes have been made by referring to the “Last Updated” legend on top of this page. Please review these Terms regularly to ensure that you are aware of any changes. If you continue to use the Service following such a posting of changes, you accept any such change or modification.

If you have any questions about these Terms or our Privacy Policy, please see our contact information in the last section of these Terms.


Use of the Service is subject to your continued compliance with these Terms. You are only allowed to use the service if you have reached the age of “majority” where you live. By accessing or using the Service you represent and warrant that you have reached the age of “majority” where you live and that you agree to be bound by these Terms. You undertake to monitor your User Account to restrict use by minors, and in particular you will deny access to children under the age of 13. You accept full responsibility for any unauthorized use of the Service by minors and you acknowledge that you are responsible for any use of the Service, including use of your credit card or other payment instrument by minors.

Any access to or use of the Service by anyone under 13 is expressly prohibited.

The Service is intended solely for your personal use. You represent and warrant that you will use the Service in compliance with any and all applicable laws and regulations. The Service is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject to any registration requirement within such jurisdiction or country, and the use of the Service is unauthorized in any such jurisdiction. You agree not to access or use the Service in any such jurisdiction.

Certain parts of the Service, in particular use of the products, require a user account (“User Account”). When you use any of our products, a User Account is automatically created based on your device IDs, or your Facebook account if you decide to connect your User Account with it. You may also be able to provide us with profile information within the Service. You agree not to provide inaccurate, misleading or false information in connection with your use of the Service and in particular in connection with your User Account for the Service. If information you have provided to us subsequently becomes inaccurate, misleading or false, you will promptly notify us of such change. Please also see our Privacy Policy for more information about how we process your personal data.

We reserve the right to require our prior or later acceptance for registration. We have a right to refuse the registration for any reason. Registration can be limited, for example, in terms of territory.

You agree not share the User Account or any user credentials or password with any other party and not to let anyone else access your User Account or do anything else that might jeopardize the security of your User Account. You agree to notify us immediately if you suspect any breach of security in the Service. You are solely responsible for maintaining the confidentiality of your User Account, and accept responsibility for all uses of the User Account, including any purchases, whether or not authorized by you.

We reserve the right to invalidate User Accounts if we become aware that a user is less than the required minimum age and we may request additional information to confirm a user’s age at any time. Other legal ramifications may also apply.

We reserve the right to remove or reclaim any usernames at any time and for any reason, including but not limited to claims by a third party that a username violates the third party’s rights.

Purchases; product Currency

Certain features of the Service may be subject to a fee. These features may include the possibility to purchase upgrades (such as access to certain elements in the Service) or to purchase virtual currency to use a product (“product Currency”). Applicable fees are displayed in the Service in connection with the respective feature of the Service. We reserve the right to change the pricing for the goods and services offered through the Service, including the product Currency, at any time.

The product Currency or upgrades, where applicable, can be purchased for real money or won during scenario, but they have no cash value. Any product Currency you purchase or win during scenario is licensed to you on a limited, personal, non-transferable, non-sublicensable and revocable basis and only for non-commercial use in the Service. product Currency is licensed, not sold to you. product Currency may never be redeemed for actual monetary instruments, goods or other items of monetary value from or any other party. You agree not to sell, trade, redeem or otherwise transfer product Currency to any person or entity, including but not limited to another user or any third party, or in any other way cash out or exchange the product Currency for real money or for any real goods.

The estimated pack chances for Charms can be found here: https://charms.

You are responsible for all charges and usage on your User Account or using your user credentials and all purchases made by you or anyone that uses your User Account or user credentials, including applicable taxes. You may pay using the methods available in the Service from time to time, which may include payment via your Apple, Google or Amazon account, or other similar accounts, and you agree to the terms and conditions applicable to each payment method you choose, including any additional payment processing fees which may be applicable. We are not responsible or liable for any issues related to the services provided by the payment provider to you in connection with the purchase.

You (i) represent that you are authorized to use the payment method you use and that any payment information you provide is true and accurate; and (ii) authorize us and/or the applicable payment provider to charge you for the Service using your payment method. You must promptly update all billing information to keep it current, complete, and accurate (such as a change in billing address, credit card number, or credit card expiration date), and you must promptly notify the us and the applicable payment provider if your credit card is canceled, lost or stolen or if the security of your payment method has otherwise become compromised.

Provision of product Currency and any upgrades is a service that is offered to you as a part of the Service. By paying the applicable fees you acknowledge and agree that the provision of the product Currency or any upgrades commences immediately upon you subscribing to or purchasing such service and therefore any right of withdrawal or right of cancellation or “cooling off” period does not apply.




You are solely responsible for any costs you incur to access the Service through any Internet, wireless or other communication service, such as any fees for web browsing, messaging, and data usage on an Internet provider’s or wireless carrier’s network. Check with your carrier to determine the fees that apply.

Third Party Material

The Service contains links to websites, services and content owned and/or operated by third parties, for instance third parties who may invite you to participate in promotional offers or rewards programs or third-party advertisers, affiliate advertising networks or payment providers. Any separate charges or obligations that you may incur in your dealings with these third parties are your sole responsibility. We are not responsible for any such third-party websites, services or content and do not have control over any materials made available therein. Our inclusion of a link to a third-party website, services or content in the Service does not in any way imply our endorsement, advertising, or promotion of such websites, services or content or any materials made available therein. By accessing a third-party website, services or content you accept that we do not exercise any control over such websites, services or content and have no responsibility for them. The third-party sites may collect data or solicit personal information from you. We are not responsible for privacy policies, or for the collection, use or disclosure of any information those sites may collect. We encourage you to familiarize yourself with the terms of service and privacy policy applicable to any third-party website, services or content you may access.

We do not warrant or endorse and do not assume and will not have any liability or responsibility to you or any other person for any third-party products, services, materials or websites. Please note that the applicable third party is fully responsible for all goods and services it provides to you and for any and all damages, claims, liabilities and costs it may cause you to suffer, directly or indirectly, in full or in part.

Intellectual Property

These Terms confer only the right to use the Service, while these Terms and the specified licenses are in effect, and they do not convey any rights of ownership in or to the Service. All right, title and interest, including without limitation any copyright, patent, trade secret or other intellectual property right in the Service will remain our sole property. retains all right, title and interest in and to the Service and any content available therein, including, but not limited to, any products, titles, source and object codes, product client and server software, other computer codes and software, User Accounts, themes, objects, characters and character likenesses, character names and character profile information, stories, dialogue, catch phrases, locations, artwork, animations, sounds, musical compositions, audio-visual effects, concepts and methods of operation, layout, text, data, files, images, graphics, the “look and feel” of the Service, documentation, application history and recording of product use, transcripts of any chat rooms, and moral rights, whether registered or not, and all applications thereof.


CCPA Privacy Notice

The TLDR for California residents is:

We do not sell your Personal Information.

The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in our Privacy Policy.

The CCPA defines various business and commercial purposes for collecting, using, and disclosing Personal Information. While we collect, use, and disclose Personal Information pursuant to our Privacy Policy as a whole, we wanted to clarify out that this includes Personal Information in accordance with the specific CCPA business and commercial purposes below:

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use.

Contracting with service providers to perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services. Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

For other purposes for which we provide specific notice at the time the information is collected.

Collection and Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from general sources including you, your use of our services, your devices, our affiliates, our vendors, and our service providers. More specific information about Personal Information we collect is laid out in this notice and in our Privacy Policy, which we update from time to time.

As also explained in our Privacy Policy, we share your Personal Information with the following categories of CCPA third parties:


Vendors and service providers, including for data analytics and marketing and advertising our products and services to you.

  • Third parties integrated into our services.
  • Third parties as required by law and similar disclosures.
  • Third parties in connection with a merger, sale, or asset transfer.
  • Other third parties for whom we have obtained your permission to disclose your Personal Information.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share your Personal Information with nonaffiliated companies for their direct marketing purposes, unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, you can deactivate and purge your account in your application settings. For other requests or to authorize an agent to make a request on your behalf, you can also reach out to us at .

CCPA Data Processing Addendum

This CCPA Data Processing Addendum (the “Addendum”) reflects the requirements of the California Consumer Privacy Act of 2018 and its implementing regulations, as amended or superseded from time to time (California Civil Code §§ 1798.100 to 1798.199) (the “CCPA”). This Addendum makes clear that is acting as a Service Provider for CCPA purposes.

This Addendum is an addendum to the Customer Terms of Service (“Agreement”) and its incorporated Customer Data Processing Agreement (the “DPA”) between , and the Customer (each a “Party”; collectively the “Parties”) and is in effect for so long as maintains Personal Information (as defined in and to the extent protected by the CCPA) provided by Customer or which is collected on behalf of Customer by (hereinafter, the “Personal Information”). This Addendum shall only apply and bind the Parties if and to the extent Customer is a Business under the CCPA. This Addendum prevails over any conflicting terms of the Agreement or DPA, but does not otherwise modify the Agreement or DPA. All capitalized terms not defined in this Addendum shall have the meanings set forth in the CCPA. Customer enters into this Addendum on behalf of itself and, to the extent required under the CCPA, in the name and on behalf of its Authorized Affiliates (defined below).

The parties agree as follows:

  • 1. Definitions
    • 1.1. “Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.
    • 1.2. “Authorized Affiliate” means any of Customers’ Affiliate(s) permitted to or otherwise receiving the benefit of the Services pursuant to the Agreement.2. Scope and Applicability of this Addendum.
  • 2. Scope and Applicability of this Addendum
    • 2.1. This Addendum applies to the collection, retention, use, and disclosure of the Personal Information to provide Services to Customer pursuant to the Agreement or to perform a Business Purpose.
    • 2.2. Customer is a Business and appoints as a Service Provider to process the Personal Information on behalf of Customer. Customer is responsible for compliance with the requirements of the CCPA applicable to Businesses.
    • 2.3. collection, retention, use, or disclosure of Personal Information for its own purposes independent of providing the Services specified in the Agreement are outside the scope of this Addendum.
  • 3. Restrictions on Processing.
    • 3.1. is prohibited from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the Services specified in the Agreement for Customer, as set out in this Addendum, or as otherwise permitted by the CCPA.
    • 3.2. shall not further collect, sell, or use the Personal Information except as necessary to perform the Business Purpose. For the avoidance of doubt, shall not use the Personal Information for the purpose of providing services to another person or entity, except that may combine Personal Information received from one or more entities to which it provides similar services to the extent necessary to detect data security incidents, or protect against fraudulent or illegal activity.
  • 4. Notice.
    • 4.1. Customer represents and warrants that it has provided notice that the Personal Information is being used or shared consistent with Cal. Civ. Code 1798.140(t)(2)(C)(i).
  • 5. Consumer Rights.
    • 5.1. shall provide reasonable assistance to Customer in facilitating compliance with Consumer rights requests.
    • 5.2. Upon direction by Customer and within a commercially reasonable amount of time, shall delete the Personal Information.
    • 5.2.1 shall not be required to delete any of the Personal Information to comply with a Consumer’s request directed by Customer if it is necessary to maintain such information in accordance with Cal. Civ. Code 1798.105(d), in which case shall promptly inform Customer of the exceptions relied upon under 1798.105(d) and shall not use the Personal Information retained for any other purpose than provided for by that exception.
  • 6. Deidentified Information.
    • 6.1. In the event that either Party shares Deidentified Information with the other Party, the receiving Party warrants that it: (i) has implemented technical safeguards that prohibit reidentification of the Consumer to whom the information may pertain; (ii) has implemented business processes that specifically prohibit reidentification of the information; (iii) has implemented business processes to prevent inadvertent release of Deidentified Information; (iv) will make no attempt to reidentify the information.
  • 7. Mergers, Sale, or other asset transfer.
    • 7.1. In the event that either Party transfers to a Third Party the Personal Information of a Consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the Third Party assumes control of all or part of such Party to the Agreement, that information shall be used or shared consistently with applicable law. If a Third Party materially alters how it uses or shares the Personal Information of a Consumer in a manner that is materially inconsistent with the promises made at the time of collection, it shall provide prior notice of the new or changed practice to the Consumer in accordance with applicable law.
  • 8. As required by law.
    • 8.1. Notwithstanding any provision to the contrary of the Agreement, the DPA or this Addendum, may cooperate with law enforcement agencies concerning conduct or activity that it reasonably and in good faith believes may violate international, federal, state, or local law.
  • 9. No Sale of Personal Information.
    • 9.1. The Parties acknowledge and agree that the exchange of Personal Information between the Parties does not form part of any monetary or other valuable consideration exchanged between the Parties with respect to the Agreement, the DPA or this Addendum.