FISH FLY INTERNET LIMITED. and its subsidiaries and affiliates (collectively, "FISH FLY", "we", "our" or "us") develops, publishes and operates social games for web and mobile environments ("Games"), as well as web and mobile applications (each, an "App") for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).
We also operate the websites https://flyfishinternet.com/ , their subdomains, and related features, as well as an online store (collectively, "Sites", and together with the Games and App, collectively - the "Services").
FISH FLY respects your privacy and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your personal data, and it applies whenever you visit our Sites, install our App and play our Games, interact with us or otherwise access or use any of our Services.
We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Privacy Policy at any time.
1. Data Collection
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Data automatically collected or generated:
When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services, including through the use of "cookies" and other tracking technologies (as further detailed below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, game statistics, game preferences, non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, in-App or Game activity (such as game play content/product interaction ); diagnostic data (i.e. crash data and game performance data). We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services.
Data received from you:
You may provide us Personal Data voluntarily, such as when you set up an account with us, contact us (through Facebook, Messenger, e-mail, in-game chat or any other channel, including any support services), when you post on our public forums or groups, when you provide us your e-mail address (such as when you sign-up to receive e-mail updates or gifts), when you participate in competition, contest, tournaments and other promotions, when you place any purchases in any of our Games, when you interact with other users through the in-game chat or when you choose to connect your Facebook, Google, Apple or similar account to any of our Games.
Data received from Facebook and other channels:
Once you connect the Games to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you defined it as "public"), as applicable, your full name, e-mail address(es) provided to Facebook, Google or Apple, gender, profile picture or similar photo, location, time zone, and a list of your friends playing the Games (along with their photos and other public profile information). This will also allow us to present your and your friends’ public profile pictures inside the Games and to create your in-game friends list. If you access our Services through a third party such as Facebook, Google or Apple, or connect our Services to any third-party account, you should also read their terms and conditions and privacy policies. If you are unclear about what information a third-party application is sharing with us, please visit that third-party application's website in order to learn more about their privacy practices.
Transaction Data:
In-Game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
2. Data Uses
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
Performance of a contract. We will use this basis for processing necessary to make the Games, including social gaming when you choose to log in with Facebook, Google or Apple, and support services, available to you, and to send you service communications, gifts and awards.
Consent. In limited cases (where you choose to sign up to receive direct marketing emails, where you accept cookies on our Sites, we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 10.
Legitimate interests. We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.
Compliance with a legal obligation. In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.
The purposes for which we use Personal Data are described in more detail below:
To facilitate, operate, and provide our Services;
To authenticate the identity of our players, and allow them access to additional features;
To provide our users with customer care, assistance and technical support services;
To enable you to interact with other players in the game;
To enable you to identify other players in the game who are listed in your phone "contacts," provided that you have authorized upload of your contacts for that purpose;
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties, including by personalizing your profile and friends list;
To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Games updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our Service Providers may use to provide and improve our respective services; and To comply with any applicable laws and regulations.
3. Storage and Retention
While privacy laws may vary between jurisdictions, FISH FLY has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.We retain your Personal Data in order to maintain our relationship and to provide you with our Services. We will retain your Personal Data for only as long as necessary to fulfil the purposes for which we collected it. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy. If you have any questions about our Data Retention Policy, please contact us at https://flyfishinternet.com/.Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered Personal Data within the meaning of this Privacy Policy.
4. Personal Data Deletion and Closure of Accounts
In addition to any other rights set out in this Privacy Policy (except as set out in the Candidate Privacy Addendum), you at any time may direct that FISH FLY delete your Personal Data by accessing the "Account Deletion" button in the applicable Game and following the instructions. Selection of this option will result in closure of your Account and deletion of all of your playing history, purchase information, social media log-in and other information associated with you in connection with the Game. Deletion is irreversible. If you maintain accounts with multiple games, you should request closure of each.Upon receipt of your request, we will comply promptly but please allow some time for processing. We also reserve the right to retain a copy of any Personal Data that we are required by applicable law to retain.
5. Data Sharing
We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates. The circumstances in which we share data are summarised below:
Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies, contractors and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and tools, data and cyber security services, fraud detection and prevention services, payment processing services, customer support partners, external moderators and testers, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers are contractually bound to protect your Personal Data and may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services. Typically, these Service Providers process your Personal Data for the purposes for which we have instructed them; however, in some cases, Service Providers may process your Personal Data for their own purposes based on their legitimate interests, such as fraud prevention, which are not necessarily related to our Services but compatible with our Services. We may also share anonymous, statistical or aggregated information with our Service Providers for legitimate business purposes.
Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook, Google or Apple account to a certain Game, Login with Google, Facebook or sign in with Apple or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) - so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of FISH FLY, any of our users or any members of the general public.
FISH FLY Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Privacy Policy. In addition, should FISH FLY or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
For the removal of doubt, FISH FLY may share your Personal Data in additional ways, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
6. Communications
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: If you have signed up to receive such communications from us, we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
You have the right to withdraw your consent to receiving such promotional communications at any time. You can do this by contacting us at https://flyfishinternet.com/ or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us and our Service Providers, we use appropriate physical, procedural and electronic security measures, including encryption where deemed appropriate.. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. If you discover any security or vulnerability issues related to the Services you should send an email to: kiwik5131@gmail.com .
8. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole. To learn more, please visit our Cookie Policy.
9. Minors
The following games are available to individuals who are sixteen (16) years of age and over: "Duel".All other games and services are available only to individuals who are the greater of eighteen (18) years of age or the age of legal majority in your jurisdiction.We reserve the right to request proof of age or parental consent at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.If you believe that we might have any such data, please contact us at https://flyfishinternet.com/ .
10. Amendments and Controlling Version
We may amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you. If you do not agree to be bound by the terms of the new or modified Privacy Policy, you are required to stop using the Services.The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English-language version, the meaning of the English language version shall prevail.
11. Contact Us
If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Privacy, or to contact FISH FLY’s Data Protection Manager, please use the link https://flyfishinternet.com/.
Last modified: May 2024