Effective Date: January 10, 2025
We are Word Journey, and thank you for playing our game! We respect your privacy and recognize the importance of protecting the information collected about you. This Privacy Policy is designed to clarify what information we collect, how we use it to provide a better gaming experience, and how you can exercise your privacy rights. In this policy, we may refer to Layton as "we," "us," or "our."
When you play our games, we obtain and store some personal data about you, which we use for different purposes as described in this policy. Most of this data is necessary for us to provide you with games and for you to play our games.
However, in some cases we may ask you to provide us with other personal data or use personal data for purposes that are not necessary to play our games. In these cases, you do not have to provide us with that personal data and have the right to opt out of such use (if the same type of data is also used for other purposes). For example, we may ask you for your e-mail address in order to retrieve a password. As your e-mail address is not required to play our games, you do not have to provide it if you do not want to. We will never use the e-mail address for any other purpose unless we explicitly notify you in advance and provide you with the right to opt out or ask for your consent (if applicable).
Some of our games also display advertisements, and on many devices, the advertisements you see are personalized with the help of a specific advertising identifier on your device. You can opt out of all personalized ads for apps by turning off the ad identifier on your device. However, you will still receive ads, but they will not be personalized.
Please note that we will have no possibility to know if you delete a Game from your device and your personal data will thus be stored by us even if you delete a Game. If you want to request the data we have about you or want us to delete personal data we have about you.
These are examples of personal data that we will collect when you use the Games:
Data related to your device (such as your IP-address, device identifier and advertising ID). We use this data for example to be able to provide the Games to you. In Games that contain advertisements we may also you the use this to provide more relevant ads (unless you have opted out from personalized advertisements through your device settings).
Game History When you play one of our games, we save information about the games you have played, general activity in the game, and the length of time you have played the game. This information is used for data analysis of how the game works and allows us to improve the game.
Below follows a more detailed description on how we use personal data.
This Policy applies to everyone who uses the Game, or who communicates with us by email, phone or through our websites such as https://wordsonjourney.com/.
This policy applies to Word Journey's processing of personal data. The term "personal data" means any information that, alone or in combination with any other information, can be used to identify a living individual, as well as any other personal data that complies with our applicable laws, including the General Data Protection Regulation ("GDPR").
What legal basis do we rely on when processing your personal data?
We can only use personal data where there is a legitimate reason to do so, and we relies on the following legal grounds:
Legitimate Interests: Certain types of use of personal data are based on interests that we considers legitimate. For example, we rely on this legitimate reason to improve our games, to display personalized advertisements, and to prevent fraud and other unlawful activities. Our use of this legitimate reason is subject to the condition that this legitimate interest will not be overridden by the interests, fundamental rights or freedoms of the user, and that the user has the right to object to the use in question. You may contact us at any time to request more information about how we have concluded that our use of personal data based on legitimate interests does not override your interests.
Legal Obligations: We rely on personal data when we must process it to comply with legal obligations applicable to us, for example, financial information that needs to be stored for bookkeeping and financial reporting purposes.
Consent: When we ask you to consent to certain types of processing and you agree to provide your consent, we will use your personal data for the use of the data to which you have consented, for example, if we require the use of your email for any of the purposes for which consent is required. You can withdraw your consent at any time, at which point we will stop using your personal data based on that consent in the future.
Right to object:
You have the right to object to our processing of personal data on the basis of legitimate interests relating to your particular situation. If you object and the processing is based on legitimate interests, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for such processing that outweigh your privacy interests.
You can also object at any time to us sending you direct marketing information or to our use of personal data for analytics related to direct marketing and we will cease such use. You can also opt out of personalized advertising based on your personal data.
Please note, however, that even if you object to certain processing, we may continue such processing if it is based on other legal grounds, such as providing you with games (if you still want to use them) or fulfilling legal obligations.
Right to restriction:
You may request that we restrict the use of certain personal data, for example if the personal data is incorrect, or if you believe that we no longer needs the personal data to fulfill the purposes set out in this policy, or if you object to our use of the personal data on the basis of legitimate interests.
Right of Access and Correction:
Upon your request, we will inform you in more detail about how we use your personal data. The information you have the right to receive includes what personal data we processes about you, where we collect the data from and for what purposes the data is used. We may charge a reasonable administration fee for repeat requests. We may also refuse to fulfill a request if it is manifestly unfounded or excessive, particularly due to its repetitive nature. We may also ask you to specify the information you wish to access.
You also have the right to correct any inaccurate or incomplete personal data at any time.
Right to be Forgotten:
You may request that we delete your personal data, for example, if you have terminated your account with us and the personal data is no longer necessary for the purposes for which it was collected, you withdraw your consent and there are no other legitimate grounds for processing, or you object to our use of your data on the basis of legitimate interests. In other cases, your personal data may also be deleted. Please contact us for more information about the erasure of your personal data.
Right to withdraw consent:
If you have consented to our processing of personal data, you may withdraw such consent at any time for any future processing based on such consent.
Right to Data Portability:
You have the right to receive personal data relating to you in a commonly used and machine-readable format, which you have provided to us and which we use in accordance with your consent or under contract with you, and to provide this information to another controller where technically feasible.
If you have any questions, please contact Customer Support.
Advertisements
Some of our games display advertisements. This may be banner ads, full screen ads or short videos. In addition to this, you can sometimes earn additional revenue such as coins by watching short advertisements.
The ads you see are served by third parties. A full list of our advertising partners is available here: Marketing and Advertising Partners.
Advertising identifiers:
An advertising identifier is an identifier provided by a device, such as a cell phone, to an advertising partner to identify that device. Advertisers use this identifier to provide more relevant and personalized advertisements in Apps and Games.
You can opt out of receiving personalized ads on your phone by turning off the ad identifier on your device. The exact steps vary by device, but generally you can change this in the Privacy section of your device's preferences. Please note that if you turn off the advertising identifier, you will still see ads, but they will not be based on your personal data and therefore may be less relevant to you.
Partner companies:
Your personal data will be transferred to and processed by publishers, third party providers and suppliers which perform services for us (data processors). Such companies will be located both within and outside the EU.
Third Parties:
All third party providers and suppliers must follow our instructions and when applicable, written data processor agreements and any other agreements that are in place between us and its third party publishers/providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data.
The third parties can be grouped into:
Core infrastructure:
We host our server infrastructure using Amazon Web Services. Your personal data will be stored with these parties, either within EU or in the United States.
Customer Support:
We use Global Step to handle customer support cases for some of our apps, so if you contact customer support, personnel from either of these companies will see your support case.
Marketing:
We use other companies in our own marketing activities. So if you see an advertisement for one of our Games, some information such as your IP address or advertising identifier will be seen by our marketing partners.
A complete list of our marketing partners, and their privacy policies can be seen here: Marketing and Advertising Partners.
Advertisements:
In some Games we show advertisements. Those advertisements are provided by our advertising partners. When you see or interact with an advertisement, some data, such as an IP-address or and advertising identifier will be sent to them.
A complete list of our advertising partners and their privacy policies can be seen here: Marketing and Advertising Partners.
Authorities:
We may need to provide personal data to relevant authorities (e.g. tax authorities or the police) in accordance with applicable law and in order to fulfill legal mandatory obligations in each jurisdiction where we operates to the extent allowed under applicable data protection law. In the event of data breaches, certain personal data may need to be provided to the relevant data protection authorities.
Links to third party websites and third-party advertisements:
The advertisements that we show in the Games will market not only ours but also third parties’ products and service. We is not responsible for the privacy policies and practices of other sites or apps even if you access them using links from the Games, advertisements in the Games or from advertisements on a webpage when you are playing the Games. We recommends that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you link to the Games from a third-party site or via a social network (e.g. Twitter, Facebook), we are not responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Your personal data will be transferred to companies in other countries both within and outside the EU that we have engaged to, among other things, be able to provide Games to you and to allow you to play our Games. The relevant countries outside the EU may not ensure the same level of protection for personal data as your country. In such cases, we will ensure that the personal data is adequately protected by the receiving parties in such countries. Adequate protection may typically be to impose on the receiving party contractual obligations in accordance with model clauses that have been approved by the European Commission that ensure that such party maintains the same high level of privacy and data security as practiced by us. You will find more information here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Security:
We have implemented technology and policies to safeguard your privacy and personal data from unauthorized access and improper use. All user data is stored securely using Amazon Web Services. All communication between the cloud service and the games are safe and encrypted using SSL. To secure your data, only a few people have access to the user data and to the cloud services. These people are well educated in handling personal data. Also, we do not aim to collect information about you which makes it possible for us to identify you directly, however in some games you are able to provide your name, email address or username. However, you don’t have to provide this information if you don’t want to.
Children:
You need to be over a certain age to play our Games or use our services. The minimum age varies depending on your country of origin. For information about the minimum age in your country, see below. We do not to our knowledge collect information, or ask for personal information, or serve personalized ads to any person under the minimum age requirements below. If you think that we might have information about a user younger than the minimum age requirements, please contact us.
Minimum ages:
16 years: France, Germany, Hungary, Lithuania, Luxemburg, Netherlands, Slovakia
15 years: Finland
14 years: Austria
13 years: All other countries
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy by clicking on the above links.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Policy. You may make such a “request to know” by contacting us at the email address showed in the app.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, you may email us at the email address showed in the app.
Right to Opt-Out/Do Not Sell or Share My Personal Information. You have a right to opt out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.
Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” under those definitions. In the past 12 months, we have sold or shared all of the above categories of personal information. To opt-out from “sales” or “sharing” of personal information, please use the Global Privacy Control as described herein, or email your request to the email address showed in the app. We do not knowingly sell the personal information of minors under 16 years of age.
Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. We collect process the contents of your communications on our Services for the purpose of facilitating those communications, to provide customer service and respond to user complaints regarding violations of our Terms of Service. If you have any questions regarding our use of such sensitive personal information, please contact us using the contact information provided at the bottom of this policy.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send your request or confirm your request from the email address associated with your account or requiring you to provide information necessary to verify your account.
Finally, you have a right not to be discriminated against for exercising these rights set out in the CCPA.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by e-mailing the email address showed in the app. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To request that we remove content or information you have publicly posted, email us at the email address showed in the app. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you have any complaints on how we use your personal data, or would like further information, we would ask you to first contact us using the contact details set forth below or the functionality for contacting us as provided in our Games.
If at any time you would like to contact us about your views on this Policy or any enquiry relating to your personal information or for any matters referred to in this Policy, you can do so by sending an e-mail to us at the email address showed in the app.
This Personal Data Policy may be modified at any time. Notice of any such modifications will be provided on our website or through popups in our Games.