Privacy Policy

Privacy Policy

Effective from 25th May, 2018

General

Scrillap is committed to protecting your privacy. We have developed this Privacy Policy so that you may easily understand the way in which we protect your data we collect from you and other related information.

This Privacy Policy applies to Scrillap Inc., which is referred to in this Privacy Policy as “we,” “us,” “our” or “Scrillap.” Scrillap provides engaging contents (hereinafter referred to as “Service” or “Website”) for its users, including articles (of which brands include “Smalljoys”, “Maisvibes”, “Vaargustarme”, “Vonjour”, “Newsnack”, “unnibege”, “Hachi8” and “Voncho”) and casual games (“Playbrain”) such as “odd one out” and “spot the differences”.

The Privacy Policy is available to the public at all times so you may read the full text of the Privacy Policy on Scrillap’s website whenever you need or want to do so. Scrillap will notify you of any changes to the Privacy Policy by posting an amended version or amendments to its website.

Definitions

2.1. Personally Identifiable Data – This kind of data can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual (e.g. names, e-mail addresses).

2.2. Pseudonymous Data – The pseudonymous data identifies a holder, that is, one or more human beings who possess but do not disclose their true names (e.g. “user 1234”, instead of user Mike Miller).

2.3. Cookies – Cookies are small text files of information sent to your browser by the website operating server, which are then stored there for later retrieval. When you visit a website, cookies are accessed by the server to ensure that your preferences are maintained, which helps you view and use our Website more efficiently. Moreover, cookies tell us how often your visit the website, how you use the website and what information interests you. In this way, we can provide content and services optimized for your needs.

Most browsers automatically accept cookies, but if you do not want cookies stored in your computer, you can refuse cookies or selectively accept certain cookies by adjusting the preferences in your browser. If you turn off cookies, there may be some features of our website that will not be available to you and some web pages may not display properly. You have an option to enable or disable cookies. You may opt-out from many ad-serving cookies by using the service provided by http://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/your-ad-choices/ for users from European Union.

2.4. Pixel tags (or Web beacons) – Pixel tags are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring information, such as the IP address of the computer that downloaded the page on which the Web beacon appears, the URL (uniform resource locator) of the page on which the Pixel tags appear, the time the page containing the Pixels was viewed, the types of browser that fetched the Pixels and the identification number of any cookie on the computer previously placed by that server.

2.5. IP address – An Internet Protocol address (IP address) is a numerical label assigned to each device (e.g., computer, printer) participating in the Internet. We store the IP address only, if it is necessary to provide a service or if may be legally necessary.

General information for data processing and security

3.1. We collect and process personally identifiable data within the scope of your registration and the Service, and not without your required further consent only to the extent necessary for the conclusion and execution of our contractual relationship, performing requests or billing purposes.

3.2. Your personal data are used for the following purposes:

Providing you with our services
Ensuring an efficient user experience, maintenance, technical support, and security of our Service
Technical notifications concerning our service
Responding to your requests and inquiries

3.3. We take organizational, contractual and technical security measures to ensure that the provisions of data policy laws are complied with and, as a result, the data managed by us is protected from accidental or intentional manipulations, loss, destruction or access by unauthorized persons. These security measures are monitored on a regular basis and updated according to industry standard as necessary.

3.4. As provided for by applicable provisions we are entitled to disclose and submit data for criminal prosecution and risk prevention purposes.

3.5. If, within the framework of this Privacy Policy, contents, tools or other means and mediums are used by other providers (hereinafter referred to collectively as “Third-party Providers”) and whose registered office is abroad, it is assumed that a data will be transferred to the countries where those registered offices of the Third-party Providers are located. The transmission of data to third-party countries is either based on legal authorization, user consent or specific clauses in the contract, which provide for legally required data security.

Server Log-Files

4.1. During every visit of our Service, information about IP address, access-provider, referring URL, date/time, browser type and version and operating system, amount and state of transferred data is stored in the web server log files.

4.2. We use the log data without any other personal or pseudonymous profiling as required by law only for the purpose of the operation, security and optimization of our servers.

Use of Facebook Marketing / ReMarketing Services

5.1. Within our Service we use the “Facebook Pixel“, the “App Analytics” functions and advertising contents of the Audience Network (hereinafter jointly referred to as the “Facebook Marketing Functions”) provided by the social network Facebook, which is operated by Facebook Inc. The Facebook Marketing Functions allow us and Facebook to determine the relevant target audiences, in order to display advertisements (hereinafter referred to as “Facebook-Ads’) in reference to potential interests of the users, as well as to users with similar attributes (so called “Lookalike Audiences”). We use the Facebook Marketing Functions, because we want to display Facebook-Ads only to users, who displayed an interest in our Service. The Facebook Marketing Functions allow us and Facebook to determine, whether our Ads were effective and satisfactory for users by being able to comprehend users’ actions, after they were forwarded to our Service by clicking a Facebook-Ad.

5.2. When you visit our Service or other websites that are member of Facebook’s Audience Network and display Ads, that include or use Facebook Marketing Functions, your browser establishes a direct connection to Facebook servers. Facebook directly transfers the Facebook Marketing Functions content to your browser which embeds the latter into our Service, enabling Facebook to receive the relevant information and storing a cookie (or similar device related characteristics, especially for the App Analytics functions) on your device. The cookie allows Facebook to store the relevant information within your device and retrieve it for the above-mentioned purposes, whereby user profiles may be created.

5.3. The data Facebook collects is anonymous to us, thus does not reveal any personally identifiable information on you. However, Facebook may connect the data with your user profile within its network. Facebook processes your data in accordance with its privacy policy, therefore you’ll get there more information on the Facebook Marketing Functions and generally on Facebook Ads: https://www.facebook.com/policy.php.

5.4. In case you want to opt out of being subject to our and Facebook’s use of Facebook Marketing Functions for marketing purposes please use Facebook’s opt-out settings provided within your user profile: https://www.facebook.com/settings?tab=ads or for users from the EU http://www.youronlinechoices.com. Your choices are irrespective of platforms and devices and will be considered while using desktop or mobile device.

In case you want to opt out of being our and Facebook’s user of Facebook Pixel, please go to https://www.smalljoys.me/cookies_en/

5.5. Users are referred to Facebook’s privacy policy https://www.facebook.com/about/privacy/your-info-on-other for more information about the consent process, consent granted and ways of revoking such consent within their Facebook profile.

5.6. Users have the option in the Facebook application settings to end their use of the Service at any time: https://www.facebook.com/settings?tab=applications.

Use of Facebook plugins

6.1. Our Service uses social plugins (“plugins”) provided by Facebook. The plugins are usually identifiable by a Facebook logo (e.g., letter f on blue background or a thumb up icon). For a full list of all social Plugins, please see http://developers.facebook.com/doc/plugins/ .

6.2. When you visit a page of our Service that contains a social plugin, your browser establishes a direct connection to Facebook servers. Facebook directly transfers the plugin content to your browser that embeds the latter into the Service, enabling Facebook to receive information about your having accessed the respective page of our Service. Thus, we have no influence on the data gathered by the plugin and inform you according to our state of knowledge: The embedded plugins provide Facebook with the information that you have accessed the corresponding page of our Service. If you are logged into Facebook, your visit can be assigned to your Facebook account. If you interact with the plugins, for example by clicking “Like”, the corresponding information is transmitted from your browser directly to Facebook and stored by it. Even if you are not logged into Facebook, there is possibility that the plugins transmit your IP-address to Facebook.

6.3. For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook’s privacy policy: https://www.facebook.com/about/privacy/. In case you want to opt out of being subject to Facebook’s use of your data for marketing purposes please use Facebook’s opt-out settings provided within your user profile: https://www.facebook.com/settings?tab=ads.

Use of Google Marketing and ReMarketing Services

7.1. We use the marketing and remarketing services (hereinafter referred to as the “Google Marketing Services”) provided by Google Inc., 1600 Amphitheatre Parkway, Mountian View, CA 94043, USA.

7.2. The Google Marketing Services enable us to display ads for and on our Websites and Service in a more targeted manner so that users are only shown ads which might actually be of interest to them. For this purpose, as soon as the user accesses our Websites, or other websites on which Google Marketing Services have been activated, Google immediately executes a Google code and so called re/marketing tags (invisible graphics or code) are integrated into the Website. With the help of these tags, an individual cookie, is stored on the users’ device (comparable technology can be used instead of cookies). The cookies can be set from various domains, including google.com and doubleclick.net. This file keeps a record of which websites the user visits, what content he/she is interested in and which offers he/she has clicked on, as well as technical information about the browser and operating system, referring websites, time of access and other details about the use of the website content. The users’ IP address is also recorded, whereby we, within the context of Google Analytics, would like to point out that, within member states of the European Union or in other countries that are party to the Agreement on the European Economic Area, the IP address is truncated and only transmitted in its entirety to a Google server in the US and truncated there in exceptional cases. The IP address will not be linked with any of the user’s data from other services offered by Google. The aforementioned information can also be combined with equivalent information from other sources. If the user visits other websites afterwards, he/she can only be shown the ads that directly reflect his/her interests.

7.3. Within the scope of Google Marketing Services, the users’ data is processed pseudonymously. This means that Google does not, for example, store and process the users’ name or e-mail address, instead processing the relevant data on the basis of the cookies within pseudonymous user profiles. In other words, from Google’s point of view, the ads are managed and displayed for the cookie owner, regardless of who the cookie owner is, rather than for a specifically identified person. This shall not apply where the user has expressly permitted Google to process the data without this pseudonymization. The information collected about the users via “DoubleClick” shall be transmitted to Google and stored on Google’s servers in the US.

7.4. On the basis of Google Marketing Services, we integrate third-party “DoubleClick“ ads. DoubleClick uses cookies that enable Google and its partner websites to run ads based on users visiting this or other websites.

7.5. On the basis of Google Marketing Services, we also integrate third-party “AdSense“ ads. AdSense uses cookies that enable Google and its partner websites to run ads based on users visiting this or other websites.

7.6. You can find further information on Google’s use of data for marketing purposes on the site map: https://www.google.com/policies/technologies/ads, Google’s privacy policy can be viewed at https://www.google.com/policies/privacy.

7.7. If you wish to object to the collection of data by Google Marketing Services, you can use the settings and opt-out functions provided by Google: http://www.google.com/ads/preferences.

Google Analytics and Other Third-party Analytics Tool

8.1. We use Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google uses cookies, text files that are saved on users’ computers and allow the use of our Service to be analyzed. The information generated on the user’s use of our Service by the cookie is transmitted to a Google server in the US where it is saved.

8.2 We also use the function User ID in order to track data on user interaction with our Service. This User ID is anonymized and encrypted and will be except for its pseudonymous use not be processed with other data of a user in a way that makes the user identifiable.

8.3. Google will use this information on our behalf in order to assess users’ use of our Service, in order to compile reports on the activities within our Service and in order to provide additional services for us associated with the use of our Service and Internet use.

8.4. In case IP-anonymization is activated on this Service, your IP address will be truncated within the area of Member State of European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Googler server in U.S. and truncated there.

8.5. We use the Analytics features for marketing, Google Display Network impressions, DoubleClick Campaign Manager integration and Google Analytics reports on demographics and user interests. You can prevent Google from using Google Analytics for display ads and customize ads on the Google Display Network at:https://www.google.com/settings/ads.

8.6. The IP address that your Browser conveys within the scope of Google Analytics, will not be associated with other data held by Google. Users can prevent cookies being saved through the appropriate setting on their browser software, however please note that if you do this you may not be able to use the full functionality of this Service. You can opt-out being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en.

8.7. You can find further information on Google’s use of data for marketing purposes on the site map: https://www.google.com/policies/technologies/ads, Google’s privacy policy can be viewed at https://www.google.com/policies/privacy. If you wish to object to the collection of data by Google Marketing Services, you can use the settings and opt-out functions provided by Google: http://www.google.com/ads/preferences.

8.8. We use other third-party analytics tools provided by other third-parties (hereinafter “Third Party Analytics Providers”) in order to improve the quality of Service through assessment of users’ behavior using our Service. Third Party Analytics Providers use cookies, pixel tags and text files that are saved on users’ computers and allow the use of our Service to be analyzed.

8.7. In the following, we will inform you on the other Third Party Analytics Providers we work with, their privacy policy with detailed information on their data collection and ways to opt-out from their data collection.

Facebook Pixel, privacy policy:https://www.facebook.com/about/privacy/your-info-on-other , Pixel opt-out: [link], Facebook application settings: https://www.facebook.com/settings?tab=applications
Twitter Analytics, privacy policy:https://twitter.com/privacy, Twitter setting changes: https://twitter.com/personalization , https://twitter.com/settings/

Third-Party Content

9.1. Third party content, such as videos from YouTube, RSS feeds, tests, games, texts, or graphics from other Services, for example, can be embedded in the Service.

9.2. This always presupposes that the Third-party Provider of this content uses the user’s IP address. This is because without the IP address, they cannot send the content to the respective user’s browser. The IP address is thus required for displaying this content.

9.3. We endeavor only to use content of which the respective Third-party provider uses the IP address only for distributing the content. Third-party Providers might also use Pixel tags to collect information for statistical or marketing purposes. Through the use of Pixel tags simple actions such as the visitor traffic to the Website can be pseudonymously recorded and collected, whereby user profiles may be created. The pseudonymous information might also be stored in cookies on your device, includes technical information like your Browser or OS, details of how you used our Service and interacted with Contents displayed by the Third-party Provider. This information might be combined with such data collected on other sources.

9.4. In in the following, we will inform you on the Third-party Provider we work with, their privacy policy with detailed information on their data collection and ways to opt-out from their data collection.

Cloudflare (a Content Delivery Network which helps us to deliver contents of our Service faster, especially big media files like images or scripts using a world-wide distributed server network): https://www.cloudflare.com/security-policy/
YouTube, Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, video-content, Privacy Policy: https://www.google.com/policies/privacy/ , Opt-Out:https://www.google.com/settings/ads/.

Service, Notices and Deletion of Data

10.1. In compliance with legal requirements we will at any time provide you with information on your personally identifiable data stored by us, free of charge and without undue delay. Please refer to the contact information on our Website.

10.2. Furthermore, you are free to revoke the approvals granted by confirming this Privacy Policy, to complain to the competent supervisory authority, as well as correct, erase or block your personally identifiable data at any time and with future effect.

10.3. We delete the stored personal data, as soon as it is not needed for its purposes anymore and as this is in compliance with all legal storage obligations.

Amendments of Privacy Policy

11.1. We have right to amend or modify this Privacy Policy from time to time and, in such case, we will make a public notice of it on this Privacy Policy page and obtain consent from the users if required by relevant laws

11.2. Please check back periodically, and especially before you provide any new personally identifiable information.

Person in charge of protection of information

In order to protect information and handle their complaints related to the Scrillap’s use of information, the Scrillap designates the relevant department and Personal Information Management Officer as below. If you have any complaints in regards to personal information while using the service, please report it to the Personal Information Management Officer, we will review your complaint. Our privacy team will look into your complaint and provide a response. You will need to provide sufficient information for us to evaluate your complaint and we may ask you to provide additional information as a condition of evaluating your complaint.

E-mail: [email protected]