Last Updated: July [●], 2023

Protecting your privacy is important to SmileyGamer BV (hereinafter “SmileyGamer”). This SmileyGamer California Privacy Policy (“Policy”) describes how SmileyGamer collects, uses, discloses and safeguards the personal information you provide on SmileyGamer’s website, http://www.smileygamer.com/ and through or in connection with our mobile apps (collectively, the “Apps” and such app “App”) or other software and Internet-enabled programs and services sponsored by SmileyGamer (the “Sites”), as well as information collected when you otherwise communicate or interact with SmileyGamer.

This Policy reflects our compliance with applicable California law, including the California Consumer Privacy Act. Please see our general Data Protection Statement, available at www.thelighthousepublishing.com/privacy-policy/ for more information regarding how SmileyGamer. collects, uses, discloses and safeguards personal information. The following table sets forth the categories of personal information we have collected in the preceding 12 months, the source of that personal information, and how we have used and shared such personal information in the preceding 12 months.

Category of Personal Information Collected Source of Information Purpose for Collection Categories of Recipients
Contact information: such as your name, address, email address, or other contact information. From you To communicate with you, to send you catalogs, information, newsletters, promotional materials and other offerings from us or on behalf of our partners and affiliates, to offer a sweepstakes, contest, price competition or other promotion, when you contact us, when you request customer service or support, to complete your registration on our Sites, to administer your account with us, and to provide you with offers that may be of interest to you. A user may also be required to disclose additional personal information, such as his full name, address, etc., for purposes associated with the contractual use of the games App and the performance of the license agreement accepted by downloading the App, and in particular data associated with the use of paid services by the user (i.e. download of a paid App or in-game purchase). Our service providers, and our co-marketing partners, including select partners and affiliates that we believe may have or facilitate offers that may be of interest to you.Note: The contractual use of the games Apps requires the collection and processing of the user’s personal data by the stores. SmileyGamer has no control over this type of data collection and does not accept any liability or responsibility. Detailed information about the data collected by Google Play and Apple App Store, Windows Store and other stores may be obtained from the data protection statement of the respective store.
Device information: IP address, internet provider, operating system and browser used, type of device (such as laptop or smart phone), device cookie settings and other device details (such as MAC address ), Advertisement Identifiers From you and from our Sites or Apps technology’s interaction with your browser or devices To make sure our Sites and Apps technology works properly with your device and make sure you can see and use our intended Sites and Apps on the device you are using, for analytical and demographic purposes, and to provide offers that may be of interest to you.We also will use this information to protect the security and integrity of the Sites and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users Our service providers who help us with fraud protection, and third party vendors and service providers that perform website analytic services for us or enable more relevant offers to you on our Sites, an App or elsewhere.  We share the device Advertising identifier of our users with Facebook to construct a “Custom Audience” (See below under Market Preference information
Purchase and order information: contact information, together with purchase details online and in store through e-receipts, delivery details, payment details, and any communications we have received about your order or purchase From you To validate, confirm, verify, deliver, install, and track your order, including to arrange for shipping, handle returns and refunds, maintain a record of the purchases you make, to service products you purchased from us, and to provide you offers that may be of interest to you Our service providers who process, fulfill and ship orders
Information you provide about a third party: if you send someone else a communication from the Sites, we may collect information, such as that person’s name, telephone number, email From you To deliver to or communicate with the person at the address which you have requested Our service providers, and our co-marketing partners
Legal information: fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected crimes, complaints, claims and accidents From you, the police, crime and fraud prevention agencies, payment card providers, the public, regulators, your and our professional advisors and representatives On a case-by-case basis, to protect you, other customers and our business against criminal activities and risks, make sure we understand and can meet our legal obligations to you and others and can defend ourselves Our service providers who help us with fraud protection and credit risk reduction, and law enforcement and other governmental authorities in accordance with applicable law
Marketing Preference information / Look Alike Audience: your marketing preferences, your account settings (including any default preferences), any preferences you have indicated, the types of services/offers that interest you, the areas of our Sites that you have visited or ways that you interact with our Sites From you, from our Sites technology interaction with your browser/devices and cookies and other similar technologies tracking the pages you visit, the marketing messages you open and the links you follow To enhance your online shopping experience, including as a way to recognize you and welcome you to the Sites or Apps, to provide you with customized Sites or Apps content, targeted offers from us or others, promotions and advertising on the Sites or Apps, through other third party sites or apps, via email, text messages, or App push notifications that are offered by us or others that might be of interest to you. With regard to the use of a “Look Alike Audience,” Facebook gives us the option to create a look-alike audience. This means that Facebook compares the information with their user base to find individuals, that Facebook determines to behave similarly to the users we have provided via the Custom Audience. Once that determination is made, then a look-alike audience is created and made available to us. For more information, please visit https://developers.facebook.com/docs/marketing-api/audiences/guides/lookalike-audiences Our third party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping experiences through our Sites, an App or elsewhere We share the device Advertising identifier of users with Facebook to construct a “Custom Audience.”
Communications: communications we have with you. From you To handle your requests, to contact you when necessary or requested, including responding to your questions and comments and providing customer support, and to obtain customer feedback and improve our customer service and customer shopping experience Our service providers who assist us with customer service
Voluntary information: any voluntary information you provide us with, such as responses to surveys or competitions, entries on our online forum, and social media account details From you and your social media account provider To know you better, make our communications with you more personal, learn and improve from your survey feedback, organize events and pick competition winners Our service providers who administer surveys and promotions, and our co-marketing partners
Personalization: your journey online and how you use our Sites and Apps From you, from our Sites or Apps technology’s interaction with your browser or devices and cookies tracking the pages you visit To improve our Sites, products and services, customer service, and customer shopping experience Our third party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping or website experience for our Sites, an App or elsewhere
Information automatically collected from your browser: when you use the Sites, some data is automatically transferred from your browser to our server, including your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, IP address, mobile device identifier or other unique identifier, sites or apps visited before coming to our Sites or Apps, the amount of time you spend viewing or using the Sites or Apps, the number of times you return, or other click-stream or site usage data, emails we send that you open, forward, or click through to our Sites or Apps From you and from our Sites or Apps technology’s interaction with your browser or devices We will use this information in an aggregated non-specific format for analytical and demographic purposes. We also will use this information to protect the security or integrity of the Sites and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users Our third party vendors and service providers that perform website analytic services for us or enable the customization of offers to you to improve your shopping or website experience and the relevance of offers to you on our Sites, an App or elsewhere
Suspected crime information: details of your identity, image, name and address, suspected or alleged thefts, fraud, assault or other criminal behavior From crime and fraud prevention agencies, from you, witnesses, and from the police To protect customers, the public and our business against risks and crime, to prevent loss, to prosecute crime, and to defend ourselves Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, SmileyGamer and the Sites do not recognize DNT.

Your California Privacy Rights

If you are a California resident, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes.  To make such request, please contact us as set forth in the “Contact Us” section below. Please allow up to 30 days for us to process your request. You may submit such a request once per year.

If you are a California resident, California law also provides you with the following rights with respect to your personal information:

    • Right to Request Access to Your Personal Data. The right to know what personal information we have collected, used, disclosed and sold about you.  To submit a request to know, we prefer that you contact us through the contact form on our website. However you may also contact us at SmileyGamer BV, Rue des Poissonniers 13, 1000 Brussels, Belgium, Email: privacy@phoenixgames.com.  You also may designate an authorized agent to make a request for access on your behalf.
    • Right to Request Deletion of Your Personal Data.  To submit a request for deletion, we prefer that you may contact us through the contact form on our website. However, you may also contact us at SmileyGamer BV, Rue des Poissonniers 13, 1000 Brussels, Belgium, Email: privacy@phoenixgames.com.  You also may designate an authorized agent to make a request for deletion on your behalf.
    • Right to Request Correction of Your Personal Data
      You will have the right to request that in certain circumstances we correct personal data that we have collected about you. Some data will be exempt from such requests under law.
    • Limit Use of Your Sensitive Personal DataCalifornia residents have the right to limit our use of their sensitive personal data if we use such personal data to infer characteristics about them. To exercise this right, please contact us at Limit the Use of My Sensitive Personal Information. However, you may also contact us at SmileyGamer BV, Rue des Poissonniers 13, 1000 Brussels, Belgium, Email: privacy@phoenixgames.com.
    • Do Not Sell or Share Your Personal Information
      We support state privacy laws by allowing residents to opt out of any other future sale or sharing of their personal data for targeted advertising by clicking and making a request at Do Not Sell or Share My Personal Information. However, you may also contact us at SmileyGamer BV, Rue des Poissonniers 13, 1000 Brussels, Belgium, Email: privacy@phoenixgames.com.
  • Please see below for the categories of personal information we have sold about you in the preceding 12 months. 

When you exercise these rights and submit a request to us, we will verify your identity by asking you to log in to your account if you have one with us.  If you do not have an account with us, we may ask for your username, the last 1 to 3 AppStore receipts (assuming purchases were made) as well as specific info that only the account holder would know to confirm your identity. We also may use a third party verification provider to verify your identity.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the date of this Privacy Policy, we have sold the following categories of personal information about you:

    • identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers;
    • commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies; and
    • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.

Children’s Privacy Protection

Under Age 13

Particle Health understands the importance of protecting children’s privacy in the interactive online world. The Sites are not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.  No one under the age of 13 should submit any personal information to SmileyGamer or the Sites.

Under Age 18

Minors under 18 years of age may have the personal information that they have provided to SmileyGamer through the Sites deleted by sending an email to privacy@phoenixgames.com requesting deletion.  Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

Changes to This Privacy Policy

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve.  We display an effective date on the policy in the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change.

Contact Us

If you have any questions about this Privacy Policy or to request this Privacy Policy in another form, please contact us at SmileyGamer BV, Rue des Poissonniers 13, 1000 Brussels, Belgium, Email: privacy@phoenixgames.com.