Ranked #25 of 30 in Game Strategy
Red Flags
2"Messages, forum posts, comments, and other content shared on our platforms, private messages or invitations sent to other users, and customer service inquiries including user ID, in-game activities, and communication history are collected. Content of Communications including audio, speech to text chat transcription, information submitted in forums, chat, or message boards, communications with customer service are collected to improve our service and provide personalized service to you."
37Games collects and retains all user-generated content including private messages, chat transcriptions, audio, and forum posts, using broad justifications like service improvement and personalization that go beyond what's needed for communication features.
Warnings
7"Third-party advertising companies and third-party analytics technologies integrated into our Services may (including SDK [Software Development Kit] and API [Application Program Interfaces] integrations) combine the information they collect in connection with your use of our Services with information they have independently collected over time and/or across different platforms. Many of these companies collect and use information pursuant to their own privacy policies. They collect the information directly from you, independent from the information we affirmatively share with third parties."
Third-party SDKs embedded in the app collect data directly from users independently of what 37Games itself shares, and these companies combine it with data collected across other platforms under their own privacy policies โ giving users limited control.
"Device identifiers (e.g., Google Advertising ID (GAID) or Identifier for Advertising (IDFA), subject to consent) and IP address are shared with Marketing and Advertising Partners to provide personalized advertising and promotional offers and to measure the effectiveness of our advertising campaigns. Third-party advertising companies may combine the information they collect in connection with your use of our Services with information they have independently collected over time and/or across different platforms."
37Games shares advertising identifiers and IP addresses with marketing partners who combine this data with information collected across different platforms over time, enabling cross-service user profiling and tracking.
"Approximate location information is shared with Marketing and Advertising Partners. We collect Geolocation Data (e.g. coarse geolocation based on IP address, IP address) from you both directly and through your use of our games and services. We collect such category of your personal information to support the functionality of our service."
While 37Games states they don't collect precise GPS location, they collect IP-based approximate location data and share it with marketing and advertising partners for ad targeting purposes.
"Automatically Collected Technical and Usage Data includes IP address, device information (computer/mobile type, operating system version, browser type, browser language), device identifiers (e.g., Google Advertising ID (GAID) or Identifier for Advertising (IDFA), subject to consent), referring and exit pages, URLs, platform type, click behavior and page interactions (e.g., pages viewed, time spent, game state, date and time of activities), domain names and landing pages, cookies."
37Games automatically collects extensive device and behavioral data including advertising identifiers, full click behavior, page interactions, and browsing patterns โ much of which goes beyond core game functionality and is used for advertising purposes.
"This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you by posting the change on our websites or in this Privacy Policy and, if necessary, give you additional choices regarding such change prior to the change becoming effective. Your continued use of the websites or other 37Games' products or services will signify your acceptance of these changes."
37Games can change the privacy policy at any time, and merely continuing to use the service is treated as acceptance of the new terms. Additional choices are only provided "if necessary," giving the company discretion over whether affirmative consent is needed.
"We will keep your information as long as reasonable and necessary for providing service to you. Generally, it is life time your use of our service. But in some jurisdictions, we are legally required to keep some information longer. In addition to that, we need to keep the records of your payments, use of virtual currency and items, and consumer service for the period of statute of limitations in your jurisdiction."
Data is retained for the entire lifetime of service use by default, with additional retention after that based on vague criteria like statute of limitations periods and "legitimate interest," and deletion requests can be refused on broad grounds.
"If you want to stop us from actively using your information, or delete your information, or delete your child's information, please send an email to global.support@37games.com. We will respond to your request within one (1) month. We could not delete the information we are required to retain by applicable law or reasonably necessary for our legitimate interest."
There is no self-service account or data deletion option โ users must email customer support and wait up to one month for a response, and 37Games reserves the right to retain data it deems necessary for its "legitimate interest."