Zenith is an international entertainment company specialized in the mobile environment. We create and publish free mobile games and applications that aim to entertain, inform and connect people by leveraging global creative power.
(i) develop and publish mobile apps (“Zenith Apps and Games”),
(ii) serve advertising that are tailored to the interests of users (“Ads”) and
(iii) run our corporate websites (“zenith.games” and/or “zenith.codes).
This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.
Should you have any questions related to this policy or our practices around privacy and data protection in general, please don’t hesitate to contact Zenith Data Protection Officer as indicated in the contact section of this policy.
When you install and use Zenith mobile applications, we can collect and process some of your data for different legitimate purposes.
You will find below explanations regarding the reasons why Zenith may collect data and the legal bases Zenith relies on in each case.
Zenith collects data:
To provide you with the services you asked for
(e.g., knowing that you completed the first level to allow access to the second one)
Legal basis – such data processing is strictly necessary for the service(s) asked
To run analytics and understand how users interact with our product and services in order to continuously improve it
(e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)
Legal basis - Express consent. Zenith only processes or shares personal data collected through Zenith apps for analytics purposes once you express your consent through the pop-up notice included in our apps.
To serve advertising tailored to the preference and interests of our users
and allow Zenith to continue to provide free services and products
Legal basis – Express consent. Zenith only processes or shares personal data collected through Zenith apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps.
For all data processing activities that rely on users’ consent, you can withdraw your consent at any time by contacting our Data Protection Officer, stated in the contact section. In app/games published by SAS VOODOO, you can manually withdraw consent through the game by clicking "settings".
Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.
For all the purposes listed above the data that Zenith collect is limited to:
The apps you are using
Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
Technical information about the device you use and your connection (user agent, type of connection, timestamp)
Zenith does not share your personal data with third parties without your prior consent.
When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:
Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:
Voodoo - https://www.voodoo.io/privacy
Adcolony - https://www.adcolony.com/privacy-policy/
Applovin - https://www.applovin.com/privacy/
Criteo - https://www.criteo.com/privacy/
Facebook - https://www.facebook.com/about/privacy
Google - https://policies.google.com/privacy
Mintegral - https://www.mintegral.com/en/privacy/
Vungle - https://vungle.com/privacy/
Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:
Unity & Unity Analitics - https://unity3d.com/legal/privacy-policy
DeltaDNA - https://deltadna.com/privacy/
OneSignal - https://onesignal.com/privacy_policy
GameAnalytics - https://policies.google.com/privacy
Google - https://policies.google.com/privacy
Mixpanel - https://mixpanel.com/legal/privacy-policy/
Tenjin - https://www.tenjin.io/privacy/
Authorities: only to the extent we are obliged to by applicable laws and regulations.
Like on most websites, when you browse on zenith.games or zenith.codes certain information about your connection and device(s) are automatically collected for the website to operate properly.
For the purposes listed above the data that Zenith and its partners collect is limited to:
Browsing events and interactions with the website’s contents and services
Cookie identifiers, IP address and technical information related to your browser and/or device (user agent)
Information you provide us with voluntarily when you contact Zenith
Zenith uses Google Analytics to collect information related to the web traffic on our website. This service allows us to measure the performance and proper functioning of our website and to provide you with a better experience. For more information on the data protection and privacy aspects of these analytics services, you can refer to Google specific policy accessible here: https://policies.google.com/privacy?hl=fr and opt-out from Google Analytics data collection here: https://tools.google.com/dlpage/gaoptout
Our website also offers communication tools allowing users to share content on social networks. When you interact with such social media widgets or “share buttons”, these social network companies may collect information about you and/or your device and connection. your interactions with these services are governed by the respective privacy policies of the companies providing these services. For more information on the data protection and privacy practices of these companies, you can refer to their specific policies listed below:
Personal data collected, received and processed for the purposes described in this policy is not kept longer than necessary for the purposes described above in this section.
In all cases, Zenith does not retain such data for more than 13 months.
Zenith never knowingly or willingly collect any personal data concerning children under 16 years of age.
Some of the partners and processors referred to in this policy are located outside of the European Union.
In such case, we ensure that:
the personal data is transferred to countries recognized as offering an equivalent level of protection or,
Personal data is transferred to certified entities under the Privacy Shield or,
For personal data transferred outside of countries recognized by the European Commission as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of the standard contractual clauses of the European Commission.
You can change your consent status at any time by contacting our Data Protection Officer
Please note that if Zenith does not sell the personal information of its users, we may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services.
Adjusting your consent settings within Zenith apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.
Upon request, Zenith will provide you with information about whether we hold any of your personal information. You may access or request deletion of your personal information directly in Zenith mobile apps or by contacting Zenith Data Protection Officer as indicated in the “Contact” section below. We will respond to your request within a reasonable timeframe.
You may request Zenith the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request Zenith to erase without undue delay your personal data when it is no longer necessary for Zenith to retain such data.
In order for your data to be erased or rendered inaccessible you can either:
reset your mobile advertising identifier (IDFA on iOS, GAAID on Androïd) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
contact Zenith Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by Zenith on you and/or your device permanently erased or anonymized
Upon request, Zenith will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract.
Data Protection Officer – Zenith Games – POLAND