We are LinkFly Network (“Frivcm”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you play our games and visit www.Frivcm.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you visit our Website or play a game from our Website or use any of our other services, all of which together we refer to as “Services”.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

Who is Responsible for the Processing of Your Personal Data

LinkFly Network, Tamilnadu – 623516, The India is responsible (“the data controller”) for the processing of your Personal Data in FrivCM.

What Types of Personal Data do We Process and How do We Collect it?

When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our games or Services you use and how you use them. We process the following types of your Personal Data:

Personal Data Provided by You

When you use our Services, you provide or be asked to give us certain information, including:

  • Game ratings:

    We collect rating information if you use the voting button on our Websites.

  • Favorite games:

    You have the option to easily access your favorite games.

  • Like/Dislike Button:

    We collect the data when you click like or dislike buttons to suggest games to you accordingly.

  • Your account information:

    On our Website, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, username and password).

  • Information provided in relation to our customer service:

    When you contact support, we collect information about your request (subject and content of your request) and your contact details.

Personal Data We Receive or Generate From Your Use of Our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

  • Technical information:

    We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address), browser settings, screen resolution and other technical information.

  • Cookie data:

    As further described in our Cookie Notice (“Cookie Notice“), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.

  • Your usage:

    We collect information about how you use our Services. This information includes your preferences, such as your interests in certain categories of games, the actions you take, the time and duration of your activity. Based on the time that you spend while playing the games, you will earn points and badges. Furthermore, we collect information about the websites that led you to our Website.

Personal Data We Collect From Other Third Parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:

  • Social Networks and connected third-party platforms:

    If you choose to connect our Services with Facebook or Google account by using your credentials with our log-in process, we receive certain information about you from Social Networks such as your public profile, first and last name, your profile picture, your email address, and your authentication token.

    If you choose to connect our Services with LinkFly Network, it offers a single  platform from where users can obtain the necessary login data for all participating. After registration, the SSO authentications service is available to the participating portals and to users as a single tool for logging in to the various participating specialist portals. We receive your name, surname, your e-mail address and your authentication token.

  • Other third parties:

    We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

To learn more about which data is processed, please see the section with service specific information below.

For What Purpose we process your data?

Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

Provision and Improvement of Our Services

  • to allow you to play our games, including third-party games available on our Website
  • to allow you to use our Services
  • to create and manage your account
  • to restore your account if you ever lose access
  • to communicate with you in context of account activation, password management
  • to simplify the registration process
  • to facilitate content sharing on social networks
  • to provide technical support and respond to your requests
  • to identify and correct any bugs/errors
  • to indicate the popularity of our Services
  • to assess the quality of our Services
  • to understand and improve your online experience
  • to aggregate financial reports to pay our business partners
  • to pay our business partners for the promotion of our Services

Personalization of your game experience

  • to remember your preferred game settings
  • to show you your preferred games
  • to recommend games you may like based on your preferences
  • to personalize advertising for you
  • to remember you next time you visit our Services

Marketing and analytics

  • to deliver (targeted and non-targeted) advertising in our Services
  • to pay our business partners for the promotion of our Services
  • to measure the effectiveness of advertising
  • to send you marketing communications, informing your about new content and in-game offers
  • to acquire new users on social media platforms

Prevention of fraud and illegal activity

  • to investigate fraud and illegal behaviour
  • to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

  • to determine the legal requirements for processing of your Personal Data (based on your location such as your country)
  • to respond to your requests related to your data subject rights
  • to comply with our legal obligations (e.g. tax and accounting obligations)
  • to inform you about any changes to this Privacy Notice

Please see the section with service specific information below. for a more detailed description of the purposes for which we process your Personal Data.

Do We Engage in Profiling Activities?

If you consent to this via the cookie consent pop-up, We use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to serve relevant content to you and adjust our services and ads to your interests. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.

On Which Legal Basis do We Process Your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

  • Your consent:

    We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in context of sending newsletters, personalized advertising, analytics, profiling, social media and games from external publishers. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

  • Performance of a contract:

    We process your Personal Data for the performance of a contract to which you are a party, for example, in the context of customer service, where it is necessary for the creation and administration of your account, to support the operation of our games or facilitate the delivery of requested services.

  • Compliance with legal obligations to which we are subject:

    We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.

  • Legitimate interests:

    We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience.

Please see for additional information the section with service specific information below.

With Whom do We Share Your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

  • External service providers:

    We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services, web/social analytics services, data management services, video hosting service, and user notification services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

  • Third-party game Distributors:

    On our Websites, we offer games from third-party game distributors. By playing a third-party game, your Personal Data can be processed by the third-party game distributors (directly or through the use of cookies or similar technology). Please note that by choosing third-party games, you will be able to play the game in the third-party game developer’s environment over which we have no control. We only receive anonymized statistics and revenue reports from third-party game distributors. We therefore advise you to check the privacy policies of any such game distributor before starting the game.

  • External advertising companies:

    With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you use our Services. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you are redirected to the third-party advertiser’s environment over which we have no control.

  • Connected third-party platforms:

    We have included a Facebook and Google button and pixel on our website to enable users to integrate with their social media profiles as and when they see fit to do so. Such parties may capture some of your data that way. These parties are controllers of the data for their own purposes. Learn more about our marketing activities in the service specific section below..

  • Law enforcement, government authorities or courts:

    We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.

  • Other third parties:

    We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Where Will My Personal Data be Processed?

In general, Your personal data is stored on servers within the European Union (EU) / the European Economic Area (EEA).

However, your data may also be shared outside the EU / EEA. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here).

For the transfer of Personal Data from the EEA to countries not considered by the European Commission to provide an adequate level of protection, we have taken appropriate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You can obtain an overview of these measures by clicking here.

We are aware of the ruling of the EU Court of Justice of 16 July 2020 with implications for the transfer of Personal Data. We are currently investigating how best to absorb and adapt to the consequences of this ruling. Privacy is very important to us and we will take all reasonable measures to find an appropriate solution. Once we have developed an appropriate solution, we will inform you via this Privacy Notice.

How do We Protect Your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How Long do We Store Your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for information about how long we will retain your Personal Data.

What are Your Rights in Respect of Your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

  • Access the Personal Data we hold about you
  • Request the update or correction of your Personal Data
  • Receive your Personal Data in a structured, commonly used and machine-readable format
  • Request the deletion of your Personal Data
  • Restrict the processing of your Personal Data
  • Withdraw your consent

Right to Object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

How can You Contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support support@frivcm.com

Please specify in your request, insofar as possible, to which Personal Data your request relates and what right you wish to exercise, and provide evidence to demonstrate that you are the individual to whom the Personal Data relates. We aim to respond to your request within a period of one month.

Game Distributors

On FrivCM, we offer Games from third-party game distributors which process your Personal Data. As also explained in the general information part, in that case you will play the game in the third-party game developer’s environment over which the third party is in control. It is the third-party game distributors that processes your data when you play their game and who should therefore obtain your valid consent. We only receive anonymized statistics and revenue reports from third-party game distributors.

We therefore advise you to check the privacy policies of any such game distributor before starting the game.

Advertising

On our Website, we show advertising from different advertising companies. These adverts can be personalized or non-personal content related ads. In order to show you personalized ads and only if you have provided your consent, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalized ads) through our advertising platform provider with third-party advertisers and ad networks.

We also use this information to measure how effective these ads are. In our consent pop-up which will be shown to you the first time you enter our Website, you can choose from which advertising company you would like to receive personalised ads or choose not to accept receiving personalised ads at all. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

Data Management Platform

Based on your consent, we process your Personal Data to show you relevant games and ads, based on the information about the games you are playing on our Website. For this purpose, your device information, IP address and information about the category of the game you played is collected and sent to an external data management platform provider.

Rating Function

You can rate the games on our Website, by choosing a thumbs up or thumbs down icon. It is in our legitimate interest to provide our users an overview which games are most popular and best rated. When you click on a rating button, we will store the aggregated voting data. The result of all the submitted ratings is used to generate a score between 1 and 5 for each game. In addition, a local text file will be stored to prevent multiple ratings for the same game. We will store this data in your browser’s local storage and we will not share this data with other partners.

Leaderboards

We also offer leaderboards to facilitate earning badges that show achieved milestones on the website and to compare these achievements with other players. For providing and organising leaderboards we collect user ID, username, avatar, time played per game and date and time. Players are publicly visible on leaderboards as long as their accounts exist. This process is based on the performance of a contract.

Queries, Comments, or Complaints

If you have any questions, comments, or complaints about this Privacy Notice, please feel free to contact us. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How Often do We Update This Privacy Notice?

We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.

This Privacy Notice was last updated on:05/January/2024