The provision of our applications (hereinafter "App"), whether via websites or through various app stores, is brought to you by FREEON Corp. registered at WellPark Office BD, 32, Migeumil-ro 90beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea (the "Data Controller" of your personal data). Consequently, "We", "Us" and "Ours" refers to the Data Controller.
We have a designated data protection officer (DPO) to help us comply with the requirements of the General Data Protection Regulation (EU) 2016/679. You may contact the DPO directly by emailing email@example.com
In the alternative, you may email Us with regards to queries of any nature ( in particular, to exercise Your Rights) at firstname.lastname@example.org
2. What personal data is processed and the legal basis for processing
There are different types of information we obtain, whether directly from you or automatically via your device when you use the App. Essentially, we only obtain what is strictly necessary to provide you with our services, no more, no less.
Information, relating to you or your device, is either identified automatically by Our systems, provided to Us by the operating system of your device or is input by you manually when filling out certain fields, authorizing certain actions in the Apps.
Information you provide Us with:
Legal basis for processing
1. Email address when you log in to use the App as a registered user.
2. Social Network information via the "OAuth" method for secure login (read more about OAuth by following the link https://oauth.net/
Essentially, this is information from your public profile (with, for instance, Facebook) that you can control at any stage.
3. Your name and avatar (an image of your choice to be shown when playing the App)
4. Your date of birth when you provide it to our support team to get some freebies.
5. Messages and communication with support
Performance of the contract with you.
Unless you sign up via other means (SNS, see below), We could not provide you with our services as a logged in user other than through some means of unique identification. You may still access Our App as a guest and link your account later.
We may contact you for marketing purposes of similar products and/or services. It will be in Our legitimate interests to do so, but you will always have a chance to opt out of such marketing communications prior to any such communication.
We will store just enough information to honour your opt-out preference in the future.
Your consent at the time of provision of the same. You can always change or replace your name and avatar within the App settings.
Your consent to receive freebies on that special day each year. We do not store the year of your birth, only the DD.MM. so to minimize the extent of personal data We hold about you.
Performance of contract to respond to your queries and provide customer support. We do not use this information for anything else (for instance, we do not build your profile or target you based on your communication with us or with other users of the App).
Strange, but that is it. The rest is the technical stuff that must be processed in order to provide you with our services
Information collected automatically or assigned by Us to you
1. The server that hosts the App may record requests your device makes to the server, the details on device and browser you use, your IP address, date and time of access, city and country, operating system, browser type, mobile network information.
Legal basis for processing
Performance of the contract.
The App would not operate otherwise, you need this to connect to the Internet.
This data is used only for technical purposes - that is, to ensure the proper functioning and security of the App and to investigate possible security incidents.
2. Advertising identifiers provided by the operating system of your handheld device (such as, for instance, IDFA, GAID)
Your consent to the provision of such identifiers given by default through the operating system of your device (Apple or Android, for instance). You are free to withdraw your consent by resetting those identifiers or opting out of interest based advertising.
This may be done via the settings of your handset and/or your browser. We respect those choices you make through the settings of your device.
3. Various device identifiers, provided by the operating system (device ID or a vendor ID, for instance) or allocated by Us (your in-App ID, for instance)
Our legitimate interests in fraud prevention and potential unauthorized access from multiple devices/locations, ensuring the technical availability and security of the App.
4. App version, OS version information, browser type, language used, make/model of your device
Performance of the contract.
We need to know this technical information so the App functions properly on your device.
5. All the events that naturally occur during your usage of the App (such as logs, events, hands played, purchase history, crashes of the App, system reports and so on). Statistical information with regards to App usage.
Partly, performance of the contract and partly our legitimate interests in fraud prevention and potential unauthorized access, ensuring the technical availability and security of the App.
Analysis of statistical information helps us to optimize the App in future updates, such usage does not affect your rights and freedoms and does not disclose any personal data of yourself or your contacts.
3. What we do with your personal data
We protect your data and do not treat your personal data in any way that would surprise you (unless We told you about it and you made an informed decision to consent to such usage). For instance, We encrypt the password created by you at the sign up stage and then store your personal data on secure servers that would prevent unauthorized access or destruction of your personal data. We use the advertising identifiers in strict compliance with the requirements of the operating systems (for otherwise We would be in breach of their usage terms). Thus, We only use those advertising identifiers to meet our contractual obligations towards the parties that brought you to Us and vice versa (whether by you clicking on an advertising banner in our partners' apps, watching the ad or otherwise). Unless you have asked us not to, We may rarely contact you by email about similar products and services to the App. Whenever We contact you, We would always give you the right to opt out prior to the first communication and at any time thereafter (see the section "Your Rights" below).
The purposes for processing the data provided by you include:
Providing you with Our services
Improving our services
Notifying you of any changes in our services
4. How long personal data is stored for
Depending on the type, your personal data is stored either until you delete the App or after six months of inactivity. Some data (such as IP addresses or blacklisted email addresses used for fraud) may be held for longer in our legitimate interests to protect our business from losses and also to respect your choice of opt-outs from marketing emails. We are required by law to delete any information that is no longer necessary to provide Service to you. We assume that if you have not used our App for over six months ("Period of Inactivity"), you have left us indefinitely. We will delete any Personal Data that we have in our possession following the Period of Inactivity. But do not worry, you are always welcome to use our App again if you decide to come back.
5. Security measures used by Us
Your data is stored on one of the secure servers that we rent and We use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. We currently use KT IDC (the " Hosting providers") to store your personal data. Those Hosting providers are in possession of various international security certificates that ensure safety of your data with them.
Thus, having the appropriate security with the Hosting providers when storing your data, We have to ensure that access to such data is provided on a need-to-know basis. Access to the Hosting providers is controlled via various technical and organizational measures that include:
Two-factor authentication to access the Hosting providers;
Following the principle of least privilege;
All servers and services are subject to continuous monitoring. This includes the logging of personal access in the user interface.
Each employee has access to the systems/services only via his/her own employee access. The access rights involved are limited to the responsibilities of the respective employee and/or team.
6. Categories of recipients and Data Processors
We do not share your personal data with any third parties, except where We have to comply with Our legal obligation. Some of the data of our users is aggregated for statistical purposes and processed in the legitimate interests as stated in section 2 above. This does not mean that We blindly follow disclosure orders. We will check each request to ensure it satisfies the relevant safeguards, contains a court order or is issued under a legislative measure for the prevention, investigation, detection or prosecution of criminal offences. As stated above, We share your advertising identifiers with third parties to meet our contractual obligations and pay their dues or protect ourselves against claims for payment.
7. Transfer of your data abroad
While your data may be accessed from different parts of the world on our behalf, We do not actually transfer your personal data outside the EEA. To any extent that data is accessed from abroad, We follow set contractual safeguards and protections to ensure that your data is as safe abroad as it is within the EEA.
Where a third party accesses your data on our behalf or upon our instructions (be it inside or outside the EEA), We use the relevant legal basis to comply with the data protection legislation. In cases where there is no finding of an adequacy decision by the European Commission, we use model contracts to safeguard your rights and data.
8. Social Network Services (SNS)
When you log in to use any of Our Apps via an SNS (such as Facebook) you provide Us with certain information from you profile for that site. The information provided via SNS varies and depends on a particular SNS (for instance, Facebook provides information on your user ID, User Token). You can untick the boxes for information you prefer not to share with us during the sign up process.
You can find out more about these settings at the SNS where you play Our App (for instance, you can edit the privacy and settings of your apps with Facebook by following the link https://www.facebook.com/help/218345114850283?helpref=about_content - last accessed on 21 May 2018).
9. Your rights
You are entitled to the full spectrum of the rights under the General Data Protection Regulation and We will go out of our way to accommodate any valid request. You can either exercise your rights by deleting certain features through your device or by emailing us at email@example.com to exercise all the other rights.
You have a wide array of rights that we respect. Among those the right to:
Require access to your personal data;
Require rectification of your personal data;
Require erasure of your personal data;
Withdraw consent to processing of your personal data, where applicable;
Lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been breached
You may be required to provide certain proof of identify so that We do not disclose personal data to those that are not entitled to it. If your personal data is erased at your request or in accordance with our data retention policy, We only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.
Please note, all requests should be emailed to Us at firstname.lastname@example.org or sent to us by post. Due to the sheer volume of messages, in-App customer support messages cannot be regarded as an effective method of notice to Us.
10. Legal - Privacy - Data Use and Sharing
PLEASE READ THE FOLLOWING APPLE DEVELOPER FORUMS TERMS AND CONDITIONS CAREFULLY BEFORE DOWNLOADING OR USING THE APPLE DEVELOPER FORUMS. THESE TERMS AND CONDITIONS CONSTITUTE A LEGAL AGREEMENT BETWEEN YOU AND APPLE. BY CHECKING THE BOX AND CLICKING “AGREE”, YOU ARE AGREEING TO BE BOUND BY THE TERMS OF THIS AGREEMENT. IF YOU DO NOT AGREE TO THE TERMS OF THIS AGREEMENT, PRESS “DISAGREE” AND YOU WILL BE UNABLE TO USE THE APPLE DEVELOPER FORUMS.
Apple Developer Forums Agreement
10-1. License and Account
This Apple Developer Forums Agreement (the “Agreement”) allows You to access and use one or more discussion forums that are hosted and made available by Apple to Apple developers through (the “Apple Developer Forums”). Apple is providing the Apple Developer Forums to You for the purpose of allowing You to engage in technical and other related developer discussions with other Apple developers (“Participants”) and in some cases with Apple employees, related to development for Apple platforms and technology only. Subject to the terms and conditions of this Agreement, Apple grants You a non-exclusive, non-transferable, revocable right to access and use the Apple Developer Forums. No licenses to any Apple intellectual property rights, expressly or by implication, estoppel or otherwise, are granted by Apple under this Agreement.
You acknowledge and agree that You will not access, or attempt to access, the Apple Developer Forums other than through Your Account. You will not, and will not assist another person with, circumventing or otherwise tampering with security components (if any) of the Apple Developer Forums. Your use of the Developer Forums, including any Content submitted or posted by You, will be Your sole responsibility. You will comply with all applicable laws in Your use of the Apple Developer Forums. You will not submit or post Content that is libelous, defamatory, indecent, harmful, harassing, intimidating, threatening, discriminatory, inflammatory, or offensive, or that is intended to promote or commit an illegal act. You agree not to exploit the Apple Developer Forums in any unauthorized way, including but not limited to, by trespass or burdening network capacity.
10-1-4. Usage Guidelines
Apple is committed to providing a respectful and harassment-free experience for everyone on the Developer Forums. You agree to comply with the Apple Developer Forum Usage Guidelines at in connection with Your use of the Apple Developer Forums. Apple reserves the right to suspend or remove any Participant from the Developer Forums (or any part thereof) at any time in its sole discretion and without notice to You, including but not limited to Participants behaving in an inappropriate or disrespectful manner. Apple reserves the right, at any time and from time to time, to update, revise, supplement, and otherwise modify the Apple Developer Forum Usage Guidelines and Your continued use of the Apple Developer Forums will constitute Your acceptance of such updated Apple Developer Forum Usage Guidelines.
The Apple Developer Forums may allow You to submit or post information, materials, data, text, images, documents, code, content or links to third party sites or third party content (“Content”). By posting Content, You grant Apple and its affiliates a perpetual, royalty-free, non-exclusive worldwide right and license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, play, make available to the public, and exercise all copyright and publicity rights with respect to the Content. If You provide any ideas, suggestions, or recommendations on this site regarding Apple’s products, technologies or services (“Feedback”), Apple may use such Feedback and incorporate it in Apple products, technologies, and services without paying royalties and without any other obligations or restrictions. If You do not want to grant Apple the rights set out above, do not submit Your Content to the Developer Forums.
Apple retains the right, but not the responsibility, to edit or remove any Content, including those submissions or posts deemed by Apple to violate this Agreement. Apple will have no liability for editing, moving, removing, or continuing to permit the display of any Content. Apple may monitor Content posted by You or otherwise available on the Apple Developer Forums to investigate any reported or apparent violation of this Agreement, and may take any action that Apple deems appropriate, including, without limitation, under Apple’s Intellectual Property policies ( However, Apple makes no warranty to You that it will edit, remove, or continue to permit the display of any specific Content, whether or not subject to such allegations, and will have no liability whatsoever for editing, removing, or continuing to permit the display of any Content.
10-1-6. Confidential Forums; Restricted Forums
Apple may provide You with access to confidential or private restricted forums within the Apple Developer Forums for discussion of certain Apple Confidential Information or other information, such as the discussion of features or technical information about pre-release software or the discussion of pre-announced Apple products. For purposes of such confidential forums, Apple is providing a limited exception to Your Apple Developer Agreement(s) (as defined below) by allowing You to discuss Apple Confidential Information that You have obtained from Apple under such agreement(s) with other Participants who are also on such confidential forums, but only within these confidential forums. Except for the limited purpose of discussions with other Participants within these confidential forums, You acknowledge and agree that this Agreement does not grant You the right to copy, reproduce, publish, blog, disclose, transmit, or otherwise disseminate any Apple Confidential Information. In addition, You acknowledge and agree that certain Participants may not have access to the same Apple Confidential Information as You may have access to, and You agree not to disclose Apple Confidential Information on non-confidential Apple Developer Forums. For purposes of this Section 5 and Section 6, “Apple Developer Agreement(s)” means the Apple Developer Agreement, Xcode and Apple SDK Agreement, Apple Developer Program License Agreement, Apple Developer Enterprise Program License Agreement, any applicable MFi agreements, and any other Apple developer agreements.
10-1-7. Term and Termination
This Agreement will commence on the date You first accept this Agreement and will continue to apply until terminated as set forth in this Section. If: (a) You fail, or Apple suspects that You have failed, to comply with any of the provisions of this Agreement or any of the Apple Developer Agreements, (b) there has been an extended period of inactivity in Your account, or (c) Your Account is used by any third parties, then Apple may, in its sole discretion and effective immediately upon notice from Apple: (i) terminate this Agreement; (ii) suspend or remove Your access to the Developer Forums (or any part thereof); and (iii) delete Your Account and/or all related information and Content associated with Your Account (or any part thereof). Apple may also terminate this Agreement for its convenience, for any reason or no reason, upon written notice of its intent to terminate. Apple will not be liable to You or any third party for any termination of Your Account, or access to the Apple Developer Forums and Content. If You want to terminate the Agreement, You may do so by notifying Apple at any time, closing Your Account and ceasing all use of the Apple Developer Forums. Upon any termination of this Agreement, You shall promptly discontinue use of the Apple Developer Forums. The following sections of this Agreement shall survive any expiration or termination of the Agreement: the restrictions of Section 2 and Sections 4 through 10.
APPLE DOES NOT PROMISE THAT THE APPLE DEVELOPER FORUMS, OR ANY INFORMATION, CONTENT, SERVICE OR FEATURE OF THE FOREGOING (COLLECTIVELY, THE “SERVICE” FOR PURPOSES OF SECTIONS 7 AND 8) WILL BE ERROR-FREE OR UNINTERRUPTED, THAT ANY DEFECTS WILL BE CORRECTED, OR THAT YOUR USE OF THE SERVICE WILL PROVIDE SPECIFIC RESULTS. THE SERVICE IS DELIVERED ON AN "AS-IS" AND "AS-AVAILABLE" BASIS. APPLE CANNOT ENSURE THAT ANY FILES OR OTHER DATA YOU DOWNLOAD FROM THE SERVICE WILL BE FREE OF VIRUSES OR CONTAMINATION OR DESTRUCTIVE FEATURES OR THAT ANY CONTENT POSTED WILL NOT BE OFFENSIVE, INDECENT OR OBJECTIONABLE. APPLE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES OF ACCURACY, NON-INFRINGEMENT, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. APPLE DISCLAIMS ANY AND ALL LIABILITY FOR THE ACTS, OMISSIONS AND CONDUCT OF ANY THIRD PARTIES IN CONNECTION WITH OR RELATED TO YOUR USE OF THE SERVICE. YOU ASSUME TOTAL RESPONSIBILITY FOR YOUR USE OF SERVICE AND ANY LINKED SITES. YOUR SOLE REMEDY AGAINST APPLE FOR DISSATISFACTION WITH THE SERVICE IS TO STOP USING THE SERVICE. THIS LIMITATION OF RELIEF IS A PART OF THE BARGAIN BETWEEN THE PARTIES. Apple reserves the right to modify, suspend, or discontinue the Developer Forums (or any part or content thereof) at any time without notice to You, and Apple will not be liable to You or to any third party should it exercise such rights, including for removing access to any Content.
10-1-9. Limitation of Liability
TO THE EXTENT NOT PROHIBITED BY APPLICABLE LAW, IN NO EVENT WILL APPLE BE LIABLE FOR PERSONAL INJURY, OR ANY INCIDENTAL, SPECIAL, INDIRECT, CONSEQUENTIAL OR PUNITIVE DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, LOSS OF DATA, BUSINESS INTERRUPTION OR ANY OTHER COMMERCIAL DAMAGES OR LOSSES, ARISING OUT OF OR RELATED TO THIS AGREEMENT OR YOUR USE OR INABILITY TO USE THE SERVICE, HOWEVER CAUSED, WHETHER UNDER A THEORY OF CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), PRODUCTS LIABILITY, OR OTHERWISE, EVEN IF APPLE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND NOTWITHSTANDING THE FAILURE OF ESSENTIAL PURPOSE OF ANY REMEDY. In no event shall Apple’s total liability to You under this Agreement for all damages (other than as may be required by applicable law in cases involving personal injury) exceed the amount of fifty dollars ($50.00).
10-1-10. Governing Law
Any litigation or other dispute resolution between You and Apple arising out of or relating to this Agreement, the Developer Forums, or Your relationship with Apple will take place in the Northern District of California, and You and Apple hereby consent to the personal jurisdiction of and exclusive venue in the state and federal courts within that District with respect any such litigation or dispute resolution. This Agreement will be governed by and construed in accordance with the laws of the United States and the State of California, except that body of California law concerning conflicts of law. Notwithstanding the foregoing, if You are an individual entering into this Agreement solely as part of Your employment for one of the entities listed below, then the following exceptions shall apply:
(a) If You are employed by an agency, instrumentality or department of the federal government of the United States, then this Agreement shall be governed in accordance with the laws of the United States of America, and in the absence of applicable federal law, the laws of the State of California will apply. Further, and notwithstanding anything to the contrary in this Agreement, all claims, demands, complaints and disputes will be subject to the Contract Disputes Act (41 U.S.C. §§601-613), the Tucker Act (28 U.S.C. §01346(a) and §31491), or the Federal Tort Claims Act (28 U.S.C. §§91346(b), 2401-2402, 2671-2672, 2674-2680), as applicable, or other applicable governing authority. For the avoidance of doubt, if You are an agency, instrumentality, or department of the federal, state or local government of the U.S. or a U.S. public and accredited educational institution, then Your indemnification obligations are only applicable to the extent they would not cause You to violate any applicable law (e.g., the Anti-Deficiency Act), and You have any legally required authorization or authorizing statute;
(b) If You are employed by a U.S. public and accredited educational institution or an agency, instrumentality, or department of a state or local government within the United States, then (a) this Agreement will be governed and construed in accordance with the laws of the state (within the U.S.) in which Your entity is domiciled, except that body of state law concerning conflicts of law; and (b) any litigation or other dispute resolution between You and Apple arising out of or relating to this Agreement, the Apple Software, or Your relationship with Apple will take place in federal court within the Northern District of California, and You and Apple hereby consent to the personal jurisdiction of and exclusive venue of such District unless such consent is expressly prohibited by the laws of the state in which Your entity is domiciled; and
(c) If You are employed by an international, intergovernmental organization that has been conferred immunity from the jurisdiction of national courts through Your intergovernmental charter or agreement, then any controversy or claim arising out of or relating to this Agreement, or the breach thereof, shall be determined by arbitration administered by the International Centre for Dispute Resolution in accordance with its International Arbitration Rules. The place of arbitration shall be London, England; the language shall be English; and the number of arbitrators shall be three. Upon Apple’s request, You agree to provide evidence of Your status as an intergovernmental organization with such privileges and immunities.
This Agreement shall not be governed by the United Nations Convention on Contracts for the International Sale of Goods, the application of which is expressly excluded.
This Agreement constitutes the entire agreement between the parties with respect to Your participation in the Apple Developer Forums, unless otherwise agreed in by Apple in writing. Apple may send You notice with respect to the Apple Developer Forums by sending an email message to the email address listed in Your Account or by a posting on the Apple Developer Forums. You consent to receive notices by email and agree that any such notices that Apple sends You electronically will satisfy any legal communication requirements. Notices will be deemed given when sent to You at the email address listed in Your account or when posted on the Apple Developer Forums. No delay or failure to take action under this Agreement will constitute a waiver unless expressly waived in writing, signed by a duly authorized representative of Apple, and no single waiver will constitute a continuing or subsequent waiver. This Agreement will bind Your successors but may not be assigned, in whole or part, by You without the written approval of an authorized representative of Apple. Any non-conforming assignment shall be null and void. If any provision is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that this Agreement shall otherwise remain in full force and effect and enforceable. No addition to or removal or modification of any of the provisions of this Agreement will be binding upon Apple unless made in writing and signed by an authorized representative of Apple.
11. Do Not Track (California OPPA)
There is no consensus on how mobile application companies should interpret the DNT signals. For the purposes of the OPPA, We do not currently respond to DNT signals whether that signal has been received on a computer or a mobile device.
12. Cookies and similar technologies
13. Children's privacy
We never knowingly collect or solicit any information from anyone of 13 years and younger. The App and its content are not directed at nor made look to appeal to such persons. Parents or guardians that believe that We hold information about their children aged 13 and under may contact Us at
14. Our commitment
We will only collect and use your data where We have a legal basis to do so;
We will always be transparent and tell you about how we use your information;
When We collect your data for a particular purpose, We will not use it for anything else without your consent, unless other legal basis applies;
We will not ask for more data than needed for the purposes of providing our services;
We will adhere to the data retention policies and ensure that your information is securely disposed of at the end of such retention period;
We will observe and respect Your rights (in section 8 above) by ensuring that queries relating to privacy issues are dealt with promptly and transparently;
We will keep our staff trained in privacy and security obligations;
We will ensure to have appropriate technological and organizational measures in place to protect your data regardless of where it is held;
We will also ensure that all of our data processors have appropriate security measures in place with contractual provisions requiring them to comply with Our commitment;
We will obtain your consent and ensure that suitable safeguards are in place before personal data is transferred to other countries.
Performance of the contract with you.
Same as above, We could not otherwise provide you with our services as a registered user.