Privacy Policy

OF THE WEBSITE earlyaccess.fun-crafters.com

I. DEFINITIONS

  1. Personal data controller - Fun Crafters Ltd. With its registerred office at Ra'anana, HaSheizaf 4 Street, Izrael, entered in the register of companies under number: 516791498.
  2. User – any natural person using the Website.
  3. Personal Data – means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  4. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

II. GENERAL PROVISIONS

This Privacy Policy sets forth the rules for the processing of personal data within the Website owned by the Data Controller, including the rules for processing in connection with the registration in the Player Database and the conduct of the promotional campaign described in §4 of the Terms and Conditions.

III. SCOPE AND COLLECTION OF DATA IN CONNECTION WITH THE USE OF THE WEBSITE BY THE USER

In connection with the User's use of the Website, the following data concerning Users are collected: email address and Player ID linked to the email address provided by the User, concerning individuals playing mobile games previously offered by the Data Controller.

In the event that consent is granted for the processing of data by the Data Controller, the Data Controller may also process certain information related to the granting of such consent, including the version or name of the browser or operating system, the User's IP address, or the type of terminal equipment through which the user granted the consent.

IV. CONTACT WITH THE DATA CONTROLLER

Should you have any questions regarding the processing of Users' personal data by the Data Controller, you may contact us at the following email address: support@fun-crafters.com.

V. DATA PROTECTION OFFICER

In the event of any questions or concerns regarding the processing of personal data by Fun Crafters Ltd., the Data Protection Officer may be contacted at the following address: iod@fun-crafters.com.

VI. SCOPE OF PERSONAL DATA PROCESSED

While using the Website, the User may be requested to provide personal data if they wish to receive information regarding new game, which shall be offered by the Data Controller. The scope of mandatory and optional data is specified in each case according to the requirements of the specific service that the User intends to use. Data are collected via the Website by the Data Controller directly from the data subjects.

The provision of data is voluntary but necessary to exercise the option of receiving notifications regarding premiere of Data Controllers' new game. Failure to accept the provisions of this Privacy Policy shall result in the inability to use the provided functionalities of the Website, and the User should refrain from submitting personal data via the forms if they do not accept the provisions of this Policy.

VII. PURPOSES AND LEGAL BASIS FOR DATA COLLECTION

The Data Controller shall collect and process the Users' personal data solely in accordance with the provisions of this Privacy Policy. Any data provided by the User shall be used by the Data Controller exclusively for the purpose of:

  • marketing purposes, provided that the User has consented to receive commercial or marketing communications from the Data Controller – notifications about the new game and the launch of the related Promotion for individuals who have registered on the Website – the legal basis for data processing is Article 6(1)(a) of the GDPR;
  • providing customer service and contacting the User, including for the purpose of informing about any changes regarding the offer provided by the Data Controller – the legal basis for data processing is Article 6(1)(b) or (f) of the GDPR;
  • processing of personal data to comply with legal obligations – the legal basis for data processing is Article 6(1)(c) of the GDPR;
  • for analytical purposes, as well as the administration, maintenance, technical support, and security of the Website, which constitutes our legitimate interest in processing data – the legal basis for data processing is Article 6(1)(f) of the GDPR;
  • the potential establishment, exercise, or defense of legal claims, enforcing or investigating potential violations of the Website's terms of use or other actual or alleged unlawful activities, protecting the rights, property, or safety of the Website, the Users, the Data Controller's customers and employees, and other third parties, which constitutes our legitimate interest in data processing – the legal basis for data processing is Article 6(1)(f) of the GDPR;
  • for the purpose of using and managing the registration form provided by the Data Controller on the Website – the legal basis for data processing is Article 6(1)(f) of the GDPR;
  • for the purpose of verifying the eligibility to grant the User the Welcome Package upon the launch of the Promotion – the legal basis for data processing is Article 6(1)(b) of the GDPR;
  • for the purpose of verifying Users' submissions via the registration form provided on the Website and linking the submitted email addresses with User's PlayerID – the legal basis for data processing is Article 6(1)(f) of the GDPR;
  • for the purpose of fulfilling the terms of the Promotion and granting Welcome Packages to its participants upon the fulfillment of the conditions set forth in the Terms and Conditions – the legal basis for data processing is Article 6(1)(f) of the GDPR;

VIII. RECIPIENTS OF PERSONAL DATA

User's Personal data may be transferred by Data Controller to:

  • Companies affiliated by capital with the Data Controller provided that the disclosure of such data is necessary in connection with the pursuit of the Data Controller's interests;
  • Persons authorised by the Data Controller i.e. employees, contractors, who require access to personal data in order to perform their duties;
  • Users' personal data may be transferred to external entities providing services to the Data Controller and processed by them in order to enable them to perform the services commissioned by the Data Controller, including IT service providers, providers of solutions supporting the operation of the Website, and entities providing accounting, marketing, and legal services;
  • to public authorities or bodies authorized to obtain data under applicable provisions of law, e.g., courts, law enforcement agencies, or state institutions, upon their request based on an appropriate legal ground.

In the event of a data security breach, certain personal data may be subject to disclosure to the competent data protection authorities.

In the case of cooperation with the Data Controller's partners or third-party providers, the registered offices of such external entities may be located either within the territory of EU Member States or outside the European Economic Area (EEA).

If our partners or providers are based outside the EEA, the Data Controller ensures that the transfer of data outside the EEA is carried out in compliance with the applicable provisions of law in this respect. The level of data protection in countries outside the EEA may differ from that guaranteed by European law. We may transfer data to our partners outside the EEA, in particular, on the basis of decisions issued by the European Commission or standard data protection clauses.

All external entities are obliged to comply with the Data Controller's guidelines and to implement appropriate technical and organizational measures to protect the Users' personal data. Data recipients may act as our data processors (in which case they are fully subject to our instructions regarding personal data processing) or as independent data controllers (in which case it is necessary to additionally review the personal data processing rules of those entities).

IX. RIGHTS OF DATA SUBJECTS

The User of the Website is entitled to the following rights regarding personal data processed by the Data Controller:

  • the right of access to the User's personal data;
  • the right to rectification of the User's personal data if the data are inaccurate or incomplete;
  • the right to erasure of personal data;
  • the right to object to the processing of the User's personal data. The right to object applies when the data processing by the Data Controller is based on its legitimate interest, e.g., for the purpose of profiling data for marketing purposes. Upon receipt of the objection, the Data Controller shall cease to process the data for these purposes, unless there exist compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the User, or the User's data are necessary for the Data Controller for the potential establishment, exercise, or defense of legal claims;
  • In the event of granting consent to the processing of personal data, e.g., consenting to receive commercial information, the User may withdraw their consent to further data processing at any time. Consent may be withdrawn at any time by contacting the Data Controller at the email address provided in Section IV of this Privacy Policy. The withdrawal of consent shall not affect the lawfulness of data processing carried out by the Data Controller prior to the withdrawal of consent by the User;
  • the right to data portability regarding the User's personal data;
  • the right to restriction of processing of the User's personal data;
  • the right to lodge a complaint with a supervisory authority.

X. PERSONAL DATA RETENTION PERIOD

The Data Controller stores and processes Users' personal data for the period necessary to fulfill the processing purposes indicated in Section VI of this Privacy Policy or in accordance with mandatory provisions of law, i.e., e.g., until the User withdraws their consent or until the completion of the performance of the agreement, where the parties conclude an agreement using the functionalities of the Website and the content available therein.

Upon the achievement of the purpose of processing, the Data Controller shall delete or anonymize the personal data; however, in the event that the Data Controller intends to process data for analytical purposes, it undertakes to use the data to the extent adequate and necessary for the specified processing purposes, and in particular, in a manner preventing the identification and determination of the identity of the data subjects (e.g., by applying pseudonymization mechanisms).

XI. SECURITY MEASURES

The Data Controller implements appropriate and adequate technical and organizational measures to ensure an appropriate level of security and integrity of Users' personal data, applying proven technological standards to prevent unauthorized access to Users' personal data or other threats to the personal data.

XII. PROFILING

Data provided by Users on the Data Controller's Website may be subject to automated decision-making regarding the linking of the email address with User's playerID for the purpose of verification of the User's compliance with the terms and conditions of the Promotion; however, the Data Controller stipulates that Users' data shall not be profiled for marketing purposes.

XIII. FINAL PROVISIONS

To matters not regulated by this Policy, the relevant generally applicable provisions of law shall apply.

The User shall be informed of any changes to this Policy by the publication of the new text of the Policy on the Website and by the display of a notification upon accessing the Website.

This Policy is effective as of 1st February 2026.