Privacy Policy

Last Updated: April 8, 2023

Aged Studio Limited built the Aged Color app as an ad-supported app. We, Aged Studio Limited (“Aged Studio Limited”, “We” or “Us”), are committed to respecting your privacy and the integrity and security of your personal data. This Privacy Policy (“Privacy Policy” and “Policy) explains how we collect, use, and share your personal information when you access or use the Aged Color or any associated features, content, or pages owned or operated by Aged Studio Limited (collectively, “Services”). This Privacy Policy does not address the privacy practices of any third parties that we do not own or control. The Services is provided by Aged Studio Limited at no cost and is intended for use as is.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Aged Color unless otherwise defined in this Privacy Policy.

Please read this Privacy Policy carefully before you access or use our Services. We will notify you the Policy and request your agreement before you start to use our Services. Once you accept our Policy, it means that you agree to the collection and use of information in relation to this Privacy Policy. The personal information that we collect is used to provide the Services and improve your experience when you are using the Services. We will not use or share your information with anyone except as described in this Privacy Policy below. If you have any concerns about providing personal information to us or other information being used by us, it is advised you do not download, install, access, or use the Services. If you have used the Services, please cease your use.

1.WHAT DATA WE COLLECT

Based on the circumstances and the Services you are using, the personal data we collect will differentiate. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from our partners. We do not knowingly collect (d) special categories of information.

2.WHAT DATA WE COLLECT

A. DATA YOU PROVIDE TO US

• Account information: username, email, password, etc. You are solely responsible for ensuring your account information is correct and up to date.
• Contact information: name, email, phone, and address.
• Your messages to the Services (such as chat logs)
• Other data you choose to provide us when you contact us (through the Services, social media, email, or any other channels). You may also choose to create an account with us using your Facebook or Google account credentials. Your personal information such as your name, profile picture, email address, language preference, and other information as listed in the authorization will be provided to us.
• Information to be registered for accessing your Account from multiple devices or transferring your Account from one device to another.
• Information required for communication and transaction.

When you wish to use a specific service by subscribing to our membership or make an inquiry, we may ask you to provide information required for communicating with you and conducting transactions with you depending on the nature of the transaction, and we collect and store such information.

For example:

• In order for us to answer any requests or questions that you send to our customer support, we may ask you to provide information required for identifying and investigating the event or resolving the problem, such as your contact information including your phone number or email address, and details of the trouble that you have encountered.
• If you subscribe to our membership, you will be required to provide information for making the payment of subscription. Since credit card settlements are processed by appropriate third-party payment agencies (such as Google Play, Apple Appstore, Amazon Appstore, etc.), we will not retain your credit card number or security code.

B. DATA WE COLLECT AUTOMATICALLY

• Data and analytics about your use of our Services (e.g. your game progress, the date and time you used a Service, session length, features you have used, your interaction with advertisements)
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
• Non-identifying data about your device, such as device name and operating system, browser type, language and other technical data like screen size or processor, or combination of this data available for a developer for checking the device compatibility with a particular Service.
• General location data (e.g. country or city-level location) inferred from your IP address
• Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services
• Note that we do not use such data to learn your personal information or contact details, but mostly to understand how our users typically use and interact with our Services, so that we could carry out maintenance and improvement of them.
• Information related to your status of use of our Services such as the text, image, video, audio, sticker, emoji and any other user-generated contents (“UCG”) that you post, and your access log

C. DATA WE COLLECT FROM OUR PARTNERS

• Third-party tools. You acknowledge that we may receive your data via the link of a third-party tool with the Services (such as Facebook, Google or Apple). The information we receive from such third-party tool will exactly depend on your privacy settings, typically with your basic profile information included, such as your user ID, username, gender, picture, email and your friends playing the same game. We do not get access to or store your logins or passwords for any of these third-party tools.
• Advertising partners. From time to time, we may receive non-personal information from our advertising partners concerning the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of our Service originated from or data necessary to fight fraud (such as refund abuse in games or click fraud in advertising).
• Third-party service providers. Our analytics providers may provide us with information concerning your use of our Services (such as in-game events, your interaction with the Services and in-game advertisements, software errors, etc.) to improve our Services. In providing Personal Data, we may transfer Personal Data to a third country without any data protection laws which are equivalent to those of the country or region where you live. In the foregoing case, we will adopt standard contractual clauses or other means pertaining to data protection approved in your country or region and transfer Personal Data to a third country according to the requirements of Applicable Laws.

For more information about third-party tools, partners and service providers we use or cooperate with, please check Section 3 below.

D. NO SPECIAL CATEGORIES OF INFORMATION

We do not request or intend to collect any “special categories of information” such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please sharing this information about yourself (or others) in our Services with caution.

3.Third-party Tool, Partner and service provider

For a better user experience, while using our Service, we may require you to provide some personally identifiable information and other information (Listed on Section 2, C). However, the information is automatically collected by our third-party tools, partners and service providers, and the information will not be collected, retained and stored by us.

These third-party tools, partners and service providers are governed by their own privacy policy. Note that we do not own or control these third-party tools, partners and service providers. You should read their privacy policies before you use our Services. Their links to privacy policy are listed below:

• Google Play Services
• Facebook
• Apple
• Admob
• Facebook Audience Network
• Firebase
• Google Analytics
• AppsFlyer
• Game Analytics
• Google Cloud Platform
• AWS

4.WHY WE COLLECT AND USE YOUR DATA

TO MAKE OUR SERVICES WORK

Before you can access or use any features of our Services, you are required to allow us to collect and use data from you. The data you provide to us are necessary for us to process in order to:

• Allow you to use our Services
• Facilitate, operate, provide and maintain our Services
• Recognize you when you return to our Services
• Verify and confirm payments in our Services
• Provide and deliver subscription of membership you pay
• Send you Services-related communications
• Sync your painting history across your devices logged into your account
• Respond to your comments and questions and provide player support

TO MAKE OUR SERVICES MORE SUITABLE FOR OUR PLAYERS

To provide great experience of our Services to our players, we process personal data based on our legitimate interest to improve our Services in the following situations:

• Develop and improve the Services and player experience
• Manage our relationship with you
• Provide social features as part of the Services
• Customize your Services experience
• Provide you our special offers in the Services
• Send you related information or notifications, such as updates, security alerts, recommendations, and support messages
• Enable you to communicate with other players
• Show you contextual advertisements in our Services

TO SERVE YOU ADVERTISING

Our games may include advertising for third party products and services. Advertising is provided by our third-party advertising partners. Advertising includes serving you generic non-personalized advertisements and providing you with personalized advertising experience.

NON-PERSONALIZED ADVERTISEMENTS

To serve you generic non-personalized advertisements in the Services using third party advertising networks, it is generally necessary to process some data that may be considered as personal, such as your IP address or certain device identifiers. To do this, we rely on our legitimate interest in monetizing our Services.

PERSONALIZED ADVERTISEMENTS

To serve you personalized advertisements in the Services using third-party advertising networks we will rely on your consent to process necessary data to:

• Track the content you access in connection with the Services and your online behavior
• Deliver, target and improve advertising in our Services
• You can opt out of personalized advertising by following the instructions in section 6 below.
• You can withdraw your consent at any time by contacting us using the details given in section 14 below.

TO KEEP OUR SERVICES SAFE AND FAIR

In order to keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyze, monitor and moderate use of the Services and its social features
• Take action against fraudulent or misbehaving players
• Track how our advertising campaigns perform and identify and prevent fraud for our advertising campaigns

TO ANALYZE, PROFILE, AND SEGMENT

In all of the above cases and purposes, we may analyze, profile and segment all collected data and create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data, which we and our partners may use to provide and improve our Services.

TO COMPLY WITH OUR LEGAL OBLIGATIONS

In limited cases we pay process your data where we need to do so to comply with a legal obligation, or if we receive an order from a court or regulatory authority. For example, we process your personal information to pay our taxes, to fulfill our business obligations, and to manage risk as required under applicable law.

5.HOW WE SHARE YOUR DATA

Apart from Aged Studio, your data can be accessed by others in the following situations:

OTHER PLAYERS AND USERS

Social features are a core component of our Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted. Also, about reshare about you. You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products.

OTHER COMPANIES AND PUBLIC AUTHORITIES

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of ours, our players or others.

OUR SERVICE PROVIDERS AND PARTNERS

We use third parties to help us operate and improve our Services These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services such as: to process payments and complete transactions you request, such as payments for our subscription service, which is processed by Apple (App Store) or Google (Google Play Store); to process and store data, including your personal information; to provide security for our Services; and to conduct market research. We share your personal data with these third parties only where we have a legal basis as set out above or where such third parties process data on our behalf based on a data processing agreement, which may restrict further subcontracting by such third parties.

MERGER, ACQUISITION, OR OTHER BUSINESS TRANSACTION

We may disclose and transfer your data to a subsequent owner, co-owner, or operator of Aged Color Limited or the Services, or in connection with a merger, acquisition, consolidation, restructuring, or the sale of substantially all our interests and/or assets (i.e., a bankruptcy proceeding). We shall require the subsequent owner, co-owner, or operator in possession of your data to continue to be subject to this Privacy Policy; otherwise, we shall request that they obtain the necessary consent from you.

SAFETY AND LEGAL OBLIGATIONS

We may disclose your data if it is reasonably necessary to:

Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.); Comply with valid requests or investigations by public authorities; Comply with applicable laws or regulations; Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise; Protect our legitimate interests, including legal interests; Protect the security or integrity of the Services; or Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.

We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.

6.INTERNATIONAL DATA TRANSFERS

Our Services are global by nature and your data can therefore be transferred and processed in other countries other than the country in which you are resident. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection for personal data of EU residents or standard contractual clauses approved by EU Commission.

7.YOUR RIGHTS AND OPTIONS

OPT-OUT OF PERSONALIZED ADVERTISING

You can opt-out of personalized advertising on mobile applications by checking the privacy settings of your Android or iOS device.

Apple devices:

For iOS 14 and newer:

1.Open Settings

2.Select Privacy

3.Select Tracking and disable “Allow Apps to Request to Track”

For iOS 13 and older:

1.Open Settings

2.Select Privacy

3.Select Advertising and enable "Limit Ad Tracking"

Android devices:

1.Open Settings

2.Select Google

3.Select Ads and enable "Opt out of Ads Personalization"

If you are interested in more information about personalized advertising and your choices in this regard, you may visit the following websites:

• Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
• Your Online Choices website for EU-based advertising.

All of the opt-out tools described in this subsection are provided by third parties, not by us. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that opting out does not mean that you will stop seeing advertisements in our Services, rather third-party advertising networks will show you contextual advertisements not tailored to your interests. Please, be aware that such actions may result in decrease of advertising quality and less enjoyable user experience.

DATA SUBJECT RIGHTS

In case we process personal data about you and if you are an EU resident or the resident of another jurisdiction that affords you the below rights you:

• have the right to access data we hold on you;
• may request us to make any changes and corrections to your personal data or restrict the processing if it is inaccurate or incomplete;
• may request that your personal data is erased where we do not have a compelling reason to continue to process such personal data in certain circumstances;
• may ask to transfer your personal data in accordance with your right to data portability;
• may withdraw your consent where you have previously given your consent to the processing of your personal data. Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent.
• have the right not to be subject to a decision based solely on automated processing, (including profiling), which produces legal effects or could significantly affect you;
• have the right to object to or restrict how we use or process your data in certain circumstances. Please, note in case of such a request we may not be able to provide you with all of our Services or the quality of our Services may be decreased;
• right to lodge a complaint with a data protection supervisory body.
• To submit a request, please, use the contact details in section 14 below.
• Please, note that your request must:
• provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
• contain sufficient details describing your request to allow us to properly understand, review and respond to it;

We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.

8.HOW WE PROTECT YOUR DATA

SECURITY SAFEGUARDS

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures, such as limitation of access to personal information by personnel, utilizing Firewalls encryption, backup systems, bastion host to access cluster, RBAC to manage cluster resources, to protect your data from unauthorized access or against loss, misuse or alteration.

Although we use commercially reasonable efforts to assure that your data remains secure when maintained by us, please, be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

DATA RETENTION

In general, we keep your information for as long as necessary to achieve the purposes stated in this Policy or to comply with the applicable law. Otherwise we will try to delete your personal information upon your request or when we no longer need it for the purposes it was originally collected, although we reserve the right to retain such information indefinitely for the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes. We will not delete any personal information that also relates to other individuals, unless such other individuals also wish to delete their personal information at the same time.

We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.

Account information:We will retain information associated with your account as long as your account remains active or as necessary to provide you with the requested services.

Information collected from tracking technologies: we generally retain such information for as long as necessary for usage analytics, the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.

Marketing data:Any contact information you provide to us for marketing purposes, such as your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. If you unsubscribe, we will add your contact information to our do-not-contact list to respect your unsubscribe request.

We keep your information only so long as we need it to provide our Services to you and fulfill the purposes described in this Privacy Policy. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either destroy it or depersonalize it so that we cannot identify you.

The procedure and method of destroying the information is as follows:

Destroying Procedure: Your personal information will be destroyed without delay after the end of retention period or after its purpose has been achieved.

Destroying Method:Printed personal information will be shredded through a paper shredder. If the information is stored as a data file, it will be deleted safely in an irreversible way.

In case of request for removal of personal data, we will process the same in compliance with the legal obligations.

You can: Request access to the Personal Data we hold on you by emailing support@agedstudio.com.

9.Log Data

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

10.AGE LIMITS

We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 11 and over. We do not knowingly collect personal information from children under 16 years of age(Europe)/13 years of age(America)/11 years of age(Thailand). We will not knowingly collect personal information directly from children under the age of 16(Europe)/13(America)/11(Thailand) without parental consent. If you are under the age of 16(Europe)/13(America)/11(Thailand), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of 16(Europe)/13(America)/11(Thailand), please contact us immediately at support@agedstudio.com.

11.Service Providers

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Service;
• To provide the Service on our behalf;
• To perform Service-related services; or
• To assist us in analyzing how our Service is used.

We want to inform users of this Service that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

12.Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated or owned by us. Therefore, we strongly advise you to review the privacy policy, terms of use and cookie policy of these websites before your use and access. We have no control over and assume no responsibility for the content, privacy policies, terms of use, cookie policies or practices of any third-party sites or services.

13.Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will post posting the new Privacy Policy on this page if any changes. These changes are effective immediately after they are posted on this page.

14.Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@agedstudio.com.