Privacy Policy (LEGO Hill Climb Adventures)

Updated January 18, 2023

In this Privacy Policy we explain:

• The ways we collect personal data about you and why we do so
• How we use your personal data, and
• The choices you have about your personal data.

This Privacy Policy applies to Fingersoft’s LEGO Hill Climb Adventures game (“Service”). Other Fingersoft games, websites and other related services are bound by their separate Privacy Policy which can be found here. Please note that we may from time to time update this Privacy Policy by posting a new version on fingersoft.com. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

How to contact us

If you have questions about data protection or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through our games so we can reply to you more quickly.

Name of the company collecting the personal data (the controller): Fingersoft Oy

Address: Aleksanterinkatu 4-6, 90100 Oulu, Finland

Email: support@fingersoft.com

The personal data we PROCESS

Any use of online services requires the processing of some personal data. We’ve decided to limit such data to its minimum, only processing personal data necessary for the provision and development of the Service. Further, we do not store or collect any personal data that is not strictly necessary for providing you with the Service.

For example we only process your IP address while you are playing the LEGO Hill Climb Adventures game. When you close the application the IP address is no longer available to us or stored anywhere on our servers. It will be only available to us again when you relaunch the application. I.e. we do not need to store you IP address anywhere but we need to access it while you use the Service.

We collect data from different sources. The following sections explain to you what data we collect from which source. The uses for the data are explained below in section “Why We Process Your Data”.

Data we process automatically

• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address and IMEI)
• Data about your device, such as device name and operating system, browser type and language
• Coarse location data (country or city-specific)
• We may also create a Fingersoft and/or game-specific ID for you when you use the Service

Data we collect from our partners

• Data we receive if you link a third-party tool with the Service (such as login using a separate LEGO account)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud (such as purchase refund history)
• Data from platforms that the games are run on or distributed through (such as to verify installation and/or payment)

Data you provide us

• Any data you choose to give us (such as information via player support tickets)

Why we process your data

Any personal data that is processed by us in the delivery of the Service is processed only for the purpose of delivering you a functioning and enjoyable Service.

Below we explain in more detail for what purposes your personal data is being processed by us. What personal data is being processed is explained above in Section “The Personal Data We Process”.

To make the Service functional (performance of contract)

We process personal data in order to:

• Connect your device to the Service’s servers in order to deliver you the Service
• Identify your device and/or game account in order to save and load your game progress to and from our servers
• Verify and confirm payments

To make the Service more enjoyable for our players (legitimate interests)

We collect and process necessary data to:

• Develop and improve the Service and player experience
• Manage our relationship with you
• Customize your Service experience such as by selecting a default language based on your location
• Respond to your comments and questions and provide player support
• Send you related information, such as updates, security alerts, and support messages

To keep the Service safe and fair (legitimate interests)

Ensuring a level playing field in the Service is a top priority for us.

In order to keep the Service safe and fair, to fight fraud, and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

• Analyze and monitor the use of the Service
• Take action against fraudulent or misbehaving players

Who can access your data

Apart from Fingersoft, your data can be accessed by others in the following situations:

Partners working for Fingersoft

Fingersoft has partners to perform certain services on our behalf. These partners process your data only at and according to Fingersoft’s instructions in order to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

Fingersoft’s development partners

Fingersoft’s development partners and service providers may process your personal data for the purposes described herein, and where applicable, working as joint controllers of the processed data together with Fingersoft. A list of these partners is available at Fingersoft Partners (LEGO Hill Climb Adventures).

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

International data transfers

The Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards to ensure your rights include utilizing and enforcing the Standard Contractual Clauses approved by the EU Commission.

Your rights and options

Your rights regarding your personal data

You have the right to a copy of your personal information to be supplied to you in an electronic format upon request.

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and the right to restrict how we use or share your data. If certain personal data is processed based on consent given by you, such consent can also be withdrawn by you at any time, for example in the applicable game’s settings.

We will respond to all requests within a reasonable time frame. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority within the European Economic Area for unresolved complaints.

You can contact us at support@fingersoft.com or by using the “Contact support” feature available in some of our games’ settings.

How we protect your data

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and anonymize or delete unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your personal data is deleted or anonymized automatically after two years of account inactivity. Certain data such as payment data may be stored for periods longer than this in accordance with applicable accounting laws.

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