Last updated January, 29th 2019
The data controller is Noob Studio, a simplified joint stock company and having its registered office at
Room1907, 19/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Wan chai District, Hong Kong.
Protection of your personal data is fundamental to us. This confidentiality policy outlines information
pertaining to the manner in which we collect a process this data.
“Personal data” or “Data” shall mean any information relating to an identified or identifiable natural person.
“Data controller” shall mean the person that determines the purposes and means of the processing.
Remit of the personal data protection policy
This personal data protection policy is applicable to all of our applications.
What data is collected?
With your prior consent, we are likely to collect and process the following data in whole or in part when you use
Identity-related data: for some of our applications, we are likely to collect data from your Facebook account,
when you login using Facebook connect: Public profile (surname, forename, age, gender, email address, profile
photos, hobbies), friend list
- IDFA publicity identifiers (for IOS devices) and GAID (for Android devices)
- Data pertaining to your activities on our applications and notably the way in which you interact with our
applications (for instance, how and when you use our applications) and with the publicities we display (for
instance, time spent on these, potential clicks)
- Data pertaining to your geographical position (IP address)
your device when you access our applications.
This data is collected via external tools (Software Development Kit or « SDK ») implemented by our partners,
which are an integral part of the application.
You will find hereafter the list of our partners implementing SDKs through our applications:
- Games Analytics (analytical SDK)
- MixPanel (analytical SDK)
- Oath (SDK advertising)
- Ogury (SDK advertising)
- MoPub (SDK advertising)
- InMobi (SDK advertising)
- AppLovin (SDK advertising)
- Admob (SDK advertising)
- Vidcoin (SDK advertising)
- Vungle (SDK advertising)
- UnityAds (SDK advertising)
- Ironsource (SDK advertising)
- Tapjoy (SDK advertising)
- Adcolony (SDK advertising)
- Facebook Audience Network (SDK advertising)
- Mobvista (SDK advertising)
- Fractionnal (SDK advertising)
- Apponboard (SDK advertising)
- Fyber (SDK advertising)
Purposes of processing UNDERTAKEN by Noob Studio and legal basis for processing
Data collected by Noob Studio is used to:
- Provide our applications
- Guarantee use and improvement of our applications
- Develop new applications
- Understand your centers of interests and, thanks to this profiling, propose you targeted and relevant
advertisements (SDK advertising),
- Make statistics on your use of the games, including the number of games played, your duration of use or the
advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).
- Communicate with you, notably when you contact us by any means whatsoever
We collect the data listed hereinabove, in whole or in part, only once we have your express consent for the
purposes for which they are to be processed, through a pop-up in our applications.
At any time you can withdraw your consent from the "Settings" page in our various applications.
Term of data storage
Noob Studio stores your personal data for a maximum duration of 13 months after collection. Beyond this term,
data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature
Categories of recipients of data collected
The recipients of the Data are the teams of Noob Studio that need to have access as well as the partners
mentioned above in article 2. We may however share Data collected with our technical service providers for the
aforementioned purposes. We stringently request that our partners always act in compliance with Data protection
legislation applicable and grant special attention to confidentiality of this Data. By application of the
applicable regulation, any sub-contractor who may process this personal data for Noob Studio undertakes as
- to solely process data for the purpose(s) which is/are sub-contracted,
- to process data in pursuance with Noob Studio instructions,
- guarantee the security and confidentiality of Data.
Noob Studio may also disclose/transfer your personal data to third parties in the following particular
- by virtue of legislation, as part of legal proceedings, a dispute and/or request issued by the public
authorities in your country of residence or otherwise;
- if disclosure is necessary for national security, application of legislation or any other matter of public
- in the event of restructuring, transfer, merger or sale to the third party concerned.
In such instance as your Data is transferred outside of the European Union, we ensure that:
- the personal data is transferred to countries recognized as offering an equivalent level of protection.
- Personal data is transferred via certified entities under the Privacy Shield.
Personal data concerning children
Noob Studio does not knowingly collect any personal data concerning children under 15 years old.
Your rights concerning data collected
You have all of the following rights concerning the data we collect:
- Right to confirmation of the existence of a data processing
You are entitled to obtain from the controller confirmation as to whether or not data related to you are
- Right to access your Data
You are entitled to receive confirmation that your personal data is or is not processed and, when processed,
you are entitled to access said data. This right also includes that of receiving a copy of data processed.
- Right to request rectification of your Data if incorrect.
You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect,
incomplete or obsolete.
- Right to request deletion of your Data
You are entitled to request deletion of your data solely on those grounds for which provision is made by
applicable regulation and in particular when:
- Data is no longer necessary in light of the purposes for which it is collected or processed in any other
- you withdraw consent over which processing is based, and there is no legal basis for processing;
- you object to processing and there is no overriding legitimate ground for processing;
- you consider that your data has been processed illicitly;
- your data should be deleted to respect a legal obligation.
- Right to limit processing
You are entitled to request that the data controller limit the use of your data solely on those grounds for
which provision is made by applicable regulation and in particular when:
- you object to the accuracy of your Data;
- you consider that processing is illicit and you object to deletion of your data;
- data is still required for exercising or defending your rights in court even though Noob Studio no longer
requires this data,
- The right to object to processing by withdrawing your consent (with it being reiterated that this
withdrawal may not harm the legality of processing based on the consent granted prior to its withdrawal),
- The right to benefit from data mobility
You are entitled to reclaim your data provided to Noob Studio, in a structured format, commonly used and
machine-readable, and the right to transfer this data to another data controller, for instance so as to
change service provider.
- Post-mortem guidelines
You have the right to provide specific or general guidelines for the retention, erasure and disclosure of
personal data to designated third parties after your death.
- Terms for exercising rights
You may exercise the aforementioned rights by sending an email to the following address:
You may exercise the aforementioned rights with a written and detailed request to the following address:
Room1907, 19/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Wan chai District, Hong Kong
Due to the obligation of security and confidentiality in Data processing incumbent upon Noob Studio, you are
hereby informed that your request will be processed subject that you provide proof of your identity, notably by
producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
Noob Studio will determine whether this is admissible or not within one month following receipt of the claim.
In such instance as it is deemed admissible, Noob Studio will provide all information requested or implement
the rights claimed within the aforementioned deadline.
If, given the complexity of the claim or the number of requests received, the aforementioned deadline cannot be
respected, Noob Studio will notify you prior to expiry of this deadline, of this deadline being pushed back by
a maximum of two months following its decision.
Noob Studio hereby notifies you that it will be entitled, where applicable, to object to any requests which are
clearly abusive (in their number, repetitive nature, or systematic).
Personal data security
We take all necessary security measures so as to prevent as far as practically possible any alteration or
loss of your data or any unauthorised access thereunto.
In such instance as we should be aware of any illegal access to personal data concerning you and corresponding
to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if
this fulfils a legal requirement.