Privacy policy

Last updated: 8 June 2023

This Privacy Policy explains how your personal data is collected and processed by Only One Percent Inc. ("Only One Percent", “we”, “us”), when you use our mobile applications (the "Apps") or our website https://www.only1p.com (the “Site”), together – the “Services”.

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.

Collection of information

1. Information we collect automatically through the app

When you access or use the App, we automatically collect general information about you, including:

• Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times, your IP-address and geolocation (determined by IP-address).
• Device Information: We collect information about the device you use to access the App, including information about the device manufacture, device model, device's OS, time zone of device, language of device.
• Device identifiers: We collect online identifiers of the device you use to access the App, including IDFA, Google Ads ID, Google Device ID, Game Center ID, Google Play Account ID.
• Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements and interactions with other players.
• Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

2. Information we collect through the Site

The information we collect and process about you when you visit our Site includes:

• Information that you provide us with when you fill in forms on our Site;
• Details of your use of the Site (for example, information about how and when you use the Site, or what device you use to access the Websites);
• If you contact us or respond to messages and communications that we send to you, we will keep a record of that correspondence;
• Your interactions with us on our social media channels; and
• Information we collect via cookies*, and other similar technologies*.

*What are: Ad identifiers, cookies and similar technologies
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.

Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to:

• Recognize you and your device;
• Provide interest-based advertising to you;
• Allow our Services to interact with a third-party social network or platform (where you have chosen to allow such interaction);
• Allow us to understand how you interact with our Site (for example, where we use cookies such as the Google Analytics cookie on our Site);
• Allow our payment processors to process your payment instructions; and
• Enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.

‍Our Site uses the following types of cookies:

STRICTLY NECESSARY COOKIES
These cookies are essential in order to enable Users to move around the site and use its features. These are known as “First Party” cookies. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided. GTM Cookie helps make tag management simple, easy and reliable by us to deploy website tags all in one place. In this case, tags are most often JavaScript and non-JavaScript code.

PERFORMANCE COOKIES
These cookies provide information about how visitors use the site so that we can analyze traffic and understand how our Users and/or visitors use our site.

FUNCTIONALITY COOKIES
These cookies allow our site to remember choices our Users and/or visitors make (such as the region they are in) and provide enhanced, more personal features. These cookies will also be used to remember changes our Users and/or visitors have made to text size, fonts and other parts of web pages that they can customize. They may also be used to provide services our Users and/or visitors have asked for such as watching a video or commenting on a blog. The information these cookies collect is anonymized and they cannot track our Users and/or visitors browsing activity on other websites.

SOCIAL MEDIA COOKIES
These cookies are used when our Users and/or visitors share information using a social media sharing button or when they link their account or engage with our content on or through a social networking site such as Facebook, Twitter or Google+. The social network will record that our Users and/or visitors have done this. This information may be linked to targeting/ advertising activities.

To find out more about cookies, please visit the relevant website set out next to your country of origin below:
‍
United Kingdom
Your Online Choices:
www.youronlinechoices.com/uk

Other European Countries
Your Online Choices:
www.youronlinechoices.com

Any Country
All About Cookies:
www.allaboutcookies.org

3. Information we collect from other sources

If you log into the Apps using a third-party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third-party site or platform provided that you have given the third-party site in question such consent.
You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:

• Facebook: https://www.facebook.com/privacy/policy
• Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
• Google Play Games: https://policies.google.com/privacy

If you log into the Apps using a third-party site or platform, you represent and warrant that (i) your access and use of such features in connection with the Apps will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third-party site or platform by the legislation in the individual jurisdictions.

Use of information – purpose and legal basis

We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

1. Information we collect in the Apps is being processed:

a) for the performance of a contract to which you are party in order to support the operation of the Apps, facilitate the delivery of requested products and services and enable maintenance and update of the Apps, and namely:

• to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
• to provide and maintain the Apps and the game experience; and
• to send you technical notices, updates, security alerts, and support and administrative messages;

b) for the fulfilment of our legitimate interest in providing advertisements and content of interest to you and improving our services:

• to provide news and information about the Apps that we think will be of interest to you;
• to personalize and improve the Apps and provide tailored content and features;
• to monitor and analyze trends, usage and activities in connection with the Apps;
• to provide users that have given us consent to share their advertising IDs with our ad network partners for the purpose of serving them with personalized advertisement in the Apps (behavioral advertising).

*The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent

2. Information received through the Site is being processed:

a) for the fulfilment of our legitimate interest in providing advertisements and content of interest to you and improving our services, namely:

• as necessary in order to provide the Site and related services to you for the purposes of contacting you, for example as part of customer service or to send you updates about the Site;
• for improving your experience when you use the Site;
• for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;
• for the purposes of marketing and promotion of our products, for example sending you communications (including by email) for these purposes;
• to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with the Site;
• as otherwise expressly set out in this Privacy Policy or as required by law.

3. Information from other sources is being processed:

a) for the performance of a contract to which you are party, namely to provide and deliver the products and services you request and send you related information;

b) for the fulfilment of our legitimate interest in providing content of interest to you and improving our services, namely:

• to link or combine information we get from others to help understand your needs and provide you with better service;
• to provide news and information about the App we think will be of interest to you.

We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of information

Only One Percent will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with Only One Percent has ceased.

Sharing of information

We disclose information about you to the following categories of recipients:

• Social networks, see more under "Social Sharing features";
• Third parties, if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• The authorities, if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Only One Percent or others;
• Other players in order to provide certain in-app features, such as leaderboards, if you log into the Apps using a third-party service;

Furthermore, if you have given your consent, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the Apps.

The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.

Only One Percent does not, and will not, provide your personal data in direct exchange for money. Therefore, Only One Percent does not sell your data. At the same time, we may disclose some categories of personal data we collect to third parties for business purposes, as explained under “Use of information – purpose and legal basis”.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at privacy@only1p.com to exercise your right to withdraw your consent on sharing your personal data with third parties.

Social sharing features

The App offers or can offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

Children

Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.
If you have additional questions about Only One Percent's privacy practices related to children under the applicable minimum age, please contact us at privacy@only1p.com.

Transfer to third countries

In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EEU.
We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.
Consequently, the transfers will only occur based on the following safeguards:

• If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at https://www.privacyshield.gov/), or
• If we have entered into standard data protection clauses adopted by the European Commission with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.

Security

Only One Percent takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Push notifications

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

YOUR RIGHTS

We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total.

The right to request access

You have the right to request access into the data that we are processing on you, including information about:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed;
• the envisaged period for which the personal data will be stored.

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

The right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule. In this case, we will cease the processing, unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.

The right to rectification

You have the right to have inaccurate personal data rectified.

The right to restriction

You have the right to obtain restriction of processing in certain circumstances. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

The right to withdraw consent

If you have given your consent to our processing of your data, you have the right to withdraw your consent at any time.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance.

The right to deletion

You can request us to delete the personal data we have collected on you in the past 12 months.
We fully recognize you right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for a certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.ve a different price or rate for services or a different level or quality of the App.

How to exercise my rights

If you wish to use any of the rights described below, you may contact us at any time by emailing us at privacy@only1p.com.

Mandatory verification: We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods. To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, changed the device you used to access the App or you already requested us to delete your personal data.

Contact

Only One Percent has the following contact information:
Only One Percent Inc.
Address: 919 North Market Street, Suite 950, Wilmington, DE 19801, USA
E-mail: privacy@only1p.com
You may also contact your local data protection authority for unresolved complaints.