Privacy Policy

Effective Date Nov 19, 2023

Last modified: Nov 19, 2023

Dramaton Ltd., a company registered in Israel with its office located at 8 Balfour Street, Tel Aviv Israel 6521118 and our registration number is : 515592095 (“Dramaton”, “us” “we”, “our”) are committed to maintaining the privacy of our users (“user”, “you”). We are the data controller under applicable privacy laws. This Privacy Policy (“Privacy Policy”) describes how we collect and process your Personal Information (as defined below). When you use our website at www.dramaton.com (“Website”) or one of our mobile game applications (“App”). When you use the Mobile Games or the Website (collectively, the “Game”), you accept our rules and policies which describe how we handle your Personal Information, and you understand we collect, process, use and store your Information as described in this Privacy Policy.

We do not collect any personal information if you visit our website www.dramaton.com.

Our Privacy Policy explains:

• What information, including Personal Information, we collect and how and why we collect it.
• How we use that information, including Personal Information.
• Your rights with regard to the collection of Personal Information.

Revisions and Modifications to our Privacy Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time.  If we make a material change to this policy that affects the way we intend to collect, use or share personal information we will post notice at the top of this policy prior to making the change. If we have your contact information on record, we will also use that to notify you of the change before it is made.

Children’s Privacy

Dramaton offers its  Super Slime Simulator and Squishy Magic apps (“Apps”) to users of all ages.

Super Slime Simulator enables users to enjoy the creation of a virtual slime and offers a selection of slime types, decorations and colors to create with. The Super Slime Simulator App also allows users to engage in a variety of activities such as Lu-Lu's Slime Quest, guessing games, turn their photos into slime, experience slime painting and send slime gifts to friends.

In Squishy Magic, users can create and colour their own cute soft DIY toys. Users can then press, squeeze and crush their new toy and watch it take back its original form time and time again. The app also includes mini-games such as Squishy Rain and Memory Game.

The U.S. Children's Online Privacy Protection Act (“COPPA”) and the regulations implementing it (the “COPPA Rule”), require that we inform parents and legal guardians about how we collect, use, and disclose Personal information from children under 13 years of age (“child” or “children”), and that we obtain the consent of parents and guardians in order for children to use certain features of our App, when we use the term “parent” below, we mean to include legal guardians. Dramaton has developed this App to be an enjoyable experience for our users, including children. We recognize the need to provide further privacy protections with respect to Personal Information that we may collect from children on our Apps and structured the features to minimize the requirement to collect Personal Information, and to maximize your control over the collection, use and disclosure of any Personal Information.

Types of Information we collect

We automatically collect information about you when you use our Apps and when you use the activities available in the apps. Some of this information is non-personal and includes your session durations, the content you accessed on our Apps, the frequency and scope of your use of the Apps and information about your Device and internet connection including the operating system you use.

We also collect the following personal information to help us learn more about how you use the app, the ads you interact with in the app or make a purchase in the app:

• Device ID
• Advertising IDs (IDFA, AAID/GAID, IDFV)
• IP Address
• Dramaton user ID

Dramaton does not use this personal information for any other purpose except as described and will not share personal information collected from a child with any other third parties. In the event we discover we have collected information from a child in a manner inconsistent with applicable laws requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

We encourage parents to be aware of and participate in their children’s online activities. We do not knowingly collect the Personal Information of children except as otherwise outlined in this Privacy Policy. Parents are requested to review this Privacy Policy and discuss its main features with their children in a manner that the child will understand. Parents must exercise the privacy rights of their children. For more information, please refer to the “Exercising the Rights of Your Child” section of this Privacy Policy.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

Dramaton Ltd is a member of the PRIVO Kids Privacy Assured COPPA safe harbor certification Program (“the Program”). The Program certification applies to the digital properties listed on the certification page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA safe harbor certification Seal posted on this page indicates Dramaton Ltd has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at privacy@dramaton.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

Children are invited to participate in a restricted version of the app that does not facilitate sharing or gifting as described below in the ‘User Generated Content and Content Sharing Feature’ section below.

Service providers used in relation to children

Dramaton uses restricted versions of service providers in our apps to help provide you with the best experience possible. Personal information collected by these service providers is not used for any other purpose other than outlined and is not shared with any other third parties.

We use the following ad networks in our apps. These ad networks may collect an IP address, advertising ID and device ID to serve contextual ads and for ad frequency capping.

• Chartboost
• Digital Turbine
• Google AdMob and Ad Manager
• IronSource
• KIDOZ
• Unity
• Liftoff (formerly Vungle)
• Mintegral

In addition, our Apps may display contextual advertisements served by SuperAwesome Trading Limited (“SuperAwesome”), a provider of kid-safe advertising services that are designed specifically for the compliance requirements of younger audiences, including those aged under the age of digital consent. SuperAwesome is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. Please go to www.kidsafeseal.com for more information. SuperAwesome is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, SuperAwesome has voluntarily undertaken this privacy initiative, and its services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, SuperAwesome’s services are subject to frequent audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified. SuperAwesome also provides advertising services in compliance with the General Data Protection Regulation (EU 1996/679) and the California Consumer Privacy Act (CCPA). Adopting an approach of 'privacy by design and by default', SuperAwesome utilises proprietary technologies so that it neither collects, stores nor shares your personal data to provision advertisements or target advertising to you. SuperAwesome acts as a service provider, as defined by the CCPA, and does not use data collected from children under the age of 16 for any purpose other than to provide contextual advertising for our app. You may contact SuperAwesome directly at privacy@superawesome.com or by post: Privacy Team, SuperAwesome Trading Limited, Octagon Point, 5 Cheapside, London, EC2V 6AA, United Kingdom.

We use Google Firebase for analytics to help learn more about how you use the app or interact with our ads.

We work with AppsFlyer to help us better understand how our users interact with ads.

Exercising the Rights of Your Child

We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age.

If you are the parent of a child who is under 13 years of age (or under another age specified by applicable regulations) you may at any time, contact our customer service department to access, change or delete the Personal Information that we have collected from your child by emailing us at legal@dramaton.com        

If you have any questions about this privacy policy or our collection and use practices in relation to children, please contact us at legal@dramaton.com.

 

General privacy policy

Types of Information we collect automatically or that is generated about you when you play the Games

Please note that the scope of this Privacy Policy is limited only to information collected by Dramaton and through your use of our App. Some information may be automatically collected, and some is collected when you interact with our App. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the App, the frequency and scope of your use of the App and information about your Device and internet connection including the operating system you use and browser type. 

Dramaton offer a variety of activities. We may collect Personal Information when you use the App, including without limitation, to play our games or using game-related services, watch advertisements within our App, make a purchase within our App, create user-generated content, and share or contribute to social-media channels.

Information from which you can be personally identified such as your Device IP address, device ID, advertising IDs, IDFVs and Dramaton specific ID may also be collected (hereinafter: “Personal Information”). When anonymous information is directly or indirectly associated with Personal Information, this anonymous information also is treated as Personal Information.

User Generated Content and Content Sharing Feature

Certain activities on our App allow users to create or manipulate content and save it on their Device, post the content publicly on social networks or share it with a third party for the third party’s own use. Examples of created content that may involve the collection of Personal Information are:  

• The ability to “Send Slime Gifts to Friends” feature, which can be loaded and played on a third party’s device.  Gifts may be sent by clicking the gift icon and sharing a gift link via 3rd party messaging and social apps.
• The ability to share images of slime from the app.

Please note that when you choose to share content through a third party platform such as Facebook or WhatsApp, we will not continue to collect the information included in that followed interaction. Also, any use of a third party platform will be subject to such third party’s terms and conditions and privacy policy practices.

As the App enables the user to interact with other users via third party platforms, we encourage parents to review the sharing feature our App includes, and assure that they approve any interaction that may be initiated by their child when using this feature.

Customer Support

We may use your or your child’s information to send questions or requests to customer support. If you reach out to us for support, we will use your Personal Information to open a support ticket, respond once to your email and resolve your queries and complaints and to facilitate support (e.g., retrieval of Game level). The Personal Information we process when doing so includes your identifiers, Dramaton specific ID, where you are located and any other information about you collected via our player support channels. All support emails and user information will be deleted immediately after replying to the user.

Geolocation Data

We may collect and store your Device's source IP address which may disclose the location of your      Device or take other applicable measures in order to disclose your Device’s location, all provided and subject to the App being installed on your Device.  Advertisements and certain content related to our App could be directed to you as a result of this information.

Information We Obtain From Our Affiliates

Your Personal Information will be collected by our billing partners if you make an in-game purchase. Please note that we only sell Dramaton in-app virtual items related to the applicable App, and we don't sell or market any third-party products. If making such a purchase, your credit card or other payment information will be collected and processed by the third-party service provider (e.g., Google Play, Apple App Store), but will never be passed on to us.    

Use of Information

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for one or more of the following purposes which may apply simultaneously:

1. Providing the Requested Services:

• We collect Information to perform our contractual obligation towards you to allow you to play the Games, we process necessary Information including Information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, information regarding your use of the Games and information regarding your in Game purchases
• Such collection of information will enable us to allow you enjoy our apps app as well as provide you with technical assistance, with regard to the App or your use of the apps.

We process the Personal Information where it is necessary for the adequate performance of the contract regarding the requested services available via the App.

2. Improvement and Development of the App:

It is in our legitimate interest to improve our Games for our players. When doing so:

•  We collect Personal Information to improve, develop and understand feedback regarding the App and to help provide more information on the use of the App quickly and easily.    
• We collect Personal Information for ongoing review and improvement of the information provided on our App to ensure it is user friendly.
• We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.    
• We and research, test features in development, and analyze the information we have to evaluate and improve our App, develop new features, and conduct audits and troubleshooting activities.     We certainly research anonymous user data.

We process this information in light of our legitimate interest in improving the App, to allow our users to have the best experience.

3. Maintain a Safe and Secure Environment

We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;

• Verify and authenticate your identity and prevent unauthorized or illegal activity;
• Enhance the safety and security of our App;
• Conduct security investigations and risk assessments;
• Prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.

We process this information in light of our legitimate interest in improving our App and enabling our users to engage in a secure environment.

4. Personalize Content, Advertising and Marketing

• We do not provide for personalized content, advertising and marketing materials for children under the age of 13, or users of unknown age.          
• If you are not a child using our App, and you have used our App in the past, we have a legitimate business interest for matching the data we collect with other data we had already collected.          
• This enables us to understand your needs and interests, optimize the content we send you and make it more suitable and relevant to your needs.      .
• This also enables us to improve your experience on the App by providing you with personalized content, recommendations, and features.

We process this information in light of our legitimate interest to personalize your experience and customize our content.

Disclosure of Information and Transfer of Data

Except as otherwise provided in this Privacy Policy or as required under applicable law, we never intentionally disclose any of your Personal Information, to any third party without having received your permission.

In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may share your Personal Information with our affiliates, parent, subsidiaries or any third party service providers and individuals to facilitate the services of our App or any portion thereof, such as marketing, data management or maintenance services. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer or mobile device, through which they can collect information about your usage of our App. This helps us compile aggregated statistics about the effectiveness of our App.

For users above the age of 13 we may disclose information to the following third parties:

• AppsFlyer  for mobile measurement, fraud prevention and analytics. More information at https://www.appsflyer.com/legal/services-privacy-policy/
• Google for Google Firebase analytics (analytics) and Google Admob (advertisement). More information can be found at https://policies.google.com/privacy
• AdColony, Inc. for advertising. More information at https://www.adcolony.com/privacy-policy/
• AppLovin Corporation for advertising. More information at https://www.applovin.com/privacy/
• Chartboost for Advertising. More informatoion at: https://answers.chartboost.com/en-us/articles/200780269
• IronSource Mobile Ltd for advertising. More information at https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
• Digital Turbine (formerly Fyber) for ads. More information at https://www.digitalturbine.com/fyber-website-privacy-policy/
• Meta for ads. More information at https://www.facebook.com/privacy/explanation
• Snap Inc. for advertising. More information at https://www.snap.com/en-US/privacy/privacy-policy/
• TikTok Inc. for advertising. More information at https://www.tiktok.com/legal/privacy-policy
• Unity Technologies for analytics and advertisement purposes. More information can be found at https://unity3d.com/legal/privacy-policy
• Liftoff (formerly Vungle), Inc. for advertising. More information at https://vungle.com/privacy/
• Mintegral for advertising. More information at https://www.mintegral.com/en/privacy/

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive (see “Where we Process Your Personal Information” below). When such third party service providers process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the App to perform an unlawful act or omission or take any act or omission that may damage Dramaton, its property and goodwill, or if there is an attempted breach of the security of the App or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

Where we Process your Personal Information

Our service is global by nature and your Information can be collected from players anywhere in the world. Currently your Information is processed by our employees and service providers in the European Economic Area (“EEA”), the UK, Israel and the USA. Israel and the UK are countries which the European Commission has decided offer an adequate level of data protection. Because countries outside of the EEA may have different data protection laws, we take steps to ensure that all transfers are protected by adequate safeguards, including the use of standard contractual clauses approved by the European Commission.

Your Rights

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at privacy@dramaton.com .

For Californian residents, please refer to Addendum 1 – California Privacy Rights. 

In some jurisdictions, in particular those located within the European Union (the "EU") or within the European Economic Area (the "EEA"), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Withdraw your consent where you previously provided such consent.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. You have a right in certain circumstances to stop us processing Information other than for storage purposes.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it.
6. Receive your Personal Information and to receive an explanation of how we use it and who we share it with. The right is not absolute. For example, we cannot reveal trade secrets or give your Personal Information about other individuals.  or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our App, Dramaton is a "Data Controller". Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request. Note that where the Personal Information is held by a third party data controller, such as an advertising partner, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your Information containing personal data is erased.

If you wish to file a request regarding any of the above, you may contact us at: privacy@dramaton.com        

Opt In or Opt Out

You are always in control of your data/personal information, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to support@dramaton.com. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

Links to Other Websites

This App may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Dramaton. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

Data Security

We deploy industry standard, or better measures to ensure the security, confidentiality, integrity and availability of personal data we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our site or to group companies, and transmission is at the users own risk.    

Data Retention

Generally, Dramaton does not retain information longer than necessary to provide its services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your data, we will erase your Personal Information from our systems, unless the data is required for Dramaton to establish, exercise or defend against legal claims or it is necessary for the performance of the requested services.          

Questions Regarding Our Privacy Policy

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at privacy@dramaton.com 

Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel, to the exclusion of any other jurisdiction.

Contacts and complaints

We welcome questions, comments and requests regarding this Privacy Policy. These should be addressed to privacy@dramaton.com. If you wish to make a complaint about how we process your Personal Information, please contact us at privacy@dramaton.com and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

ADDENDUM 1 – CALIFORNIA PRIVACY RIGHTS

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act (“CCPA”) and related applicable laws. Collection and Disclosure of Personal Information Over the past 12 months, through your use of the Games, we may have collected and disclosed the following categories of personal information, as defined in the CCPA, from or about you:

• Identifiers, including IP address, device identifiers, advertising ID and Dramaton specific ID. This information is collected directly from you or your device.
• Internet or other electronic network activity information, including your use of in-game features and events and information on your in-game activity, and information on your interactions with advertising shown in on our Games. This information is collected from our selected third party analytics providers and advertising partners.
• Geolocation data, including city level location data. This information is collected directly from your device.

We collect personal information for the following purposes:

• To operate and administer the Games;
• To improve the Games;
• To communicate with you;
• To serve advertising;
• For security and verification purposes, including to prevent and detect fraudulent activity; and
• To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see How we use your personal information in the main portion of the Privacy Policy.

We may disclose personal information to the following types of entities:

• Other players and users should you choose to share chat data via a Game with a chat feature;
• Our affiliate companies within our corporate group who process personal information in order to operate the Games;
• Marketing and advertising partners who use your information to serve you ads in the Games and on other sites;
• Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us;
• Regulators, judicial authorities and law enforcement agencies;
• Entities that acquire all or substantially all of our business.

SALES OF PERSONAL INFORMATION [Do Not Sell My Personal Information]

Over the past 12 months, we have used third party advertising and other tracking technologies on our Games to collect information about you, your device(s), and your use of our Games. We share that information with selected third parties such as advertising partners who use it to target advertisements to you online. To opt out of sale of personal information please contact us at privacy@dramaton.com.

Rights under the CCPA

The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:

• Request we disclose to you, free of charge, the following information covering the 12 months preceding your request:

• the categories of personal information about you that we collected;
• the categories of sources from which the personal information was collected;
• the purpose for collecting personal information about you;
• the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
• the specific pieces of personal information we collected about you;

• Request we delete personal information we collected from you; and
• Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

You can exercise your rights, including opting out from the sale of personal information (Do Not Sell My Personal Information) by emailing us at privacy@dramaton.com

BRAZIL PRIVACY RIGHTS

The Lei Geral de Proteção de Dados (the “LGPD”) provides residents of Brazil with certain legal rights; these rights are not absolute and are subject to exemptions. For Brazilian players, these provisions supersede any other possibly divergent or conflicting provisions contained in this Policy.
This part of the document uses the term “personal information” as it is defined in the LGPD.

Categories of personal information collected and processed

To find out what categories of your personal information are processed, please refer to the main portion of the privacy policy.

How we use your personal information

To find out how we process and use your personal information, including on what grounds, you can read the section titled Use of Information.

Your rights under the LGPD

You have the right to:

• Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
• Request that personal information be corrected.
• Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
• Obtain information on the possibility of refusing consent and the consequences of doing so.
• Obtain information about the third parties with whom we share your personal information.
• Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
• Revoke your consent at any time.
• Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.

How to file your request

You can file your request to exercise your rights free from any charge, at any time, by contacting us at privacy@dramaton.com.