Effective date: May 26, 2018
of the new edition of July 12, 2021
- Terms and Definitions
The term «Application» within the framework of this Policy means software developed by us and performing a certain function directly for the user of the software.
The term «Products» within the framework of this Policy means our Games and Applications that we have developed or any other digital products produced/provided by us.
The term «Game» within the framework of this Policy means the Game, which is also an Application, developed by us.
The term «Users» within the framework of this Policy means individuals who use the Application and/or the Game in any way or use our Services/Products.
The term «Services» in this Policy applies to Games, Applications, other digital products developed by us, and their properties that we directly control.
The term «Personal Information / Personal Data» in this Policy means information collected by Us for the purpose of supporting internal resources, information that cannot identify a specific User and is provided in section 3 of this Policy.
For the purposes of this Policy, the term «GameId» means a unique alphanumeric code (identifier) assigned automatically to each User in a particular Game.
- General Provisions
We strive to protect the confidentiality of your Personal Data that we collect and process. During data processing, we undertake to take all necessary measures in strict accordance with applicable law and exclusively on legal grounds that allow such collection and processing.
All our Products available for use on mobile devices, personal computers or any other platforms, including the website, to the extent that they are related to the collecting, processing and protecting your Personal Data, are governed by this Policy. Thus, by using any of our Products and/or Services, you agree to this Policy.
If you do not want Us to collect and process information about you in accordance with this Policy, you, unfortunately, cannot use our Products and/or use our Services.
Also, if you do not agree with the provisions of this Policy, you must stop using our Products and/or Services and delete the Application and/or the Game from all your devices.
When We collect your Personal Data and determine the purposes and methods for which this data is collected and used, we become a «Data Controller» for the purpose of complying with the provisions of the EU General Data Protection Regulation («GDPR») and any other European legislation on personal data protection. We may also be a «Data Operator» in accordance with the Children’s Online Privacy and Protection Act of 1998 («COPPA»).
Your Personal Data, in accordance with Article 28 of the GDPR, is processed by Personal Data Processors — persons who process your Personal Data in our name (on our behalf) for our purposes. The data processors/ persons who process your Personal Data are listed in clause 6 hereof.
Please note that the Personal Data collected by us, as provided for in this Policy, is non-identifiable Personal Data, that is, information that does not allow identifying your identity.
Regarding the use of your Personal Data, we comply with the provisions and requirements of the following laws and regulations:
- Federal Law of the Russian Federation «On Personal Data» (No. 152-FZ) which became effective on July 27, 2006;
- Order No. 274 of the Ministry of Communications and Mass Media of the Russian Federation, the Federal Service for Supervision of Communications, Information Technologies, and Mass Media as of March 15, 2013 on approval of the list of foreign states that are not parties to the Council of Europe Convention on the protection of individuals with automated processing of personal data and provide adequate protection of the rights of personal data subjects;
- Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (Strasbourg, 28 January 1981);
We also take into account the provisions of local legislative acts and regulatory documents of other jurisdictions whose citizens may be potential Users of the Product, including:
- EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 On the protection of natural individuals with regard to the processing of personal data and on the free movement of such data, as well as on the repeal of Directive 95/46/EC General Regulation on the Protection of Personal Data (EU) (further — «GDPR»);
- GDPR — Children;
- Children’s Online Privacy Protection Act abbreviated as «COPPA»- the American federal law on privacy which entered into force on April 21, 2000;
- CCPA — California Consumer Privacy Act, a law on the protection of personal data of users of the state of California which entered into force on January 1, 2020;
- Among other things, we follow the rules for Product developers established by the Google Play and Apple App Store online application stores. The texts of these rules are listed below:
- Information We Collect
We can collect two types of information.
The first is the information provided by you when you contact Us electronically or in writing in order to obtain technical support. This information may include: information about your name, email address, device type as well as any other information that you voluntarily provide to Us. This information is used by Us solely for the purpose of providing you with technical support and for contacting you, and only for the time of providing you with assistance and replying to you. We do not store this information.
The second type of information is non-personal information about your use of Applications that does not directly identify you and is collected by Us solely to help Us improve the quality of our Products and/or Services or for other purposes as described in section 4 of this Policy.
In accordance with the GDPR requirements, we register your consent to use our Products. This information is stored on the servers of Processors located in the EU and is used exclusively for the GDPR compliance. Your device ID is saved along with your consent status.
Please note that if you accept this Policy, the following data is collected automatically by third parties in connection with your use of Our Products — by Processors in accordance with the GDPR:
- Information about your use of our Products/Services: data about the gameplay and your interactions with other players (if applicable), your gaming success data;
- Your IP address and mobile device IDs (for example, device ID, advertising ID, MAC address, IMEI);
- Your device data such as the device name and operating system, browser type and language;
- General location data (up to the definition of the city/region, etc.)
We may also collect your GameId in cases when you contact our support service using the email client on your device. When contacting Us by sending letters through your email client, you also provide Us with information about your email address, which is information that allows us to identify you. Therefore, by sending us emails, you automatically agree to provide Us information about your GameId as well as your email address.
- The Purposes of Processing (Collecting) Personal Data
We collect your Personal Data for some or all of the following reasons:
4.1. to provide You with Products and Services in accordance with the terms defined in the User Agreement;
4.2. to provide You with information about our Products and Services, if You have given your consent to receive them;
4.3. to improve the gaming experience, taking into account the individual requirements of the particular User, to ensure the best quality of our Products or Services as well as to ensure the functionality and support of our internal operations.
- How Your Personal Data Is Processed:
5.1. We collect Your Personal Data for the implementation of the provisions according to paragraphs 4.1., 4.2 of this Policy;
5.2. Your Personal Data is transferred to the Personal Data Processors for the implementation of the provisions according to clause 4.3. of this Policy.
- A list of persons who process your Personal Data as well as information about how your Personal Data is processed:
- Analytical services, i.e. systems that register user behavior. You can view reports in their consoles:
- Unity and Unity Analytics
- Yandex.Metriсa Service (AppMetrica)
- GameAnalytics Service
- Firebase and Google Analytics
- Advertising aggregators, i.e. systems that display ads in applications through the connection of various advertising networks:
- Clever Ads Solutions
- Individual advertising networks are networks with which We do not interact directly. They are connected via an aggregator:
- Admob (GoogleAds)
- We may also cooperate with payment services if you purchase Paid Products.
- By accepting the terms of this Policy,
you agree that We may disclose the Personal Data provided by you to Processors on our behalf for the purposes defined in paragraph 4 of this Policy, for the purposes defined in the Processor policies referred to in paragraph 6 of this Policy (privacy policies).
- By accepting the terms of this Policy,
you agree to the cross-border transfer of your Personal Data to the territory of foreign states that are not parties to the Council of Europe Convention (Convention for the Protection of Individuals with Automated Processing of Personal Data (Strasbourg, January 28, 1981) and not included in the list of foreign states that are not parties to the Council of Europe Convention on the protection of individuals with automated processing of personal data and provide adequate protection of the rights of personal data subjects.
- Storage of Your Personal Data
Your Personal data collected by us, as described in this Policy, is stored on servers of the Processors and is available on the territory of the Russian Federation where Our company is registered. By accepting this Policy and the terms set out therein, you agree that your Personal data is stored and processed in these countries.
- Terms of Personal Data Storage
Your Personal Data is not stored for longer than necessary to achieve the purposes for which it is collected and processed (section 4 of this Policy). The duration of the processing of the Personal User Data of our Products and/or Services is specified in the Privacy Policies of the respective Processors, but in any case, your data is stored as long as you use our Products and/or use our Services.
As soon as the purpose of collecting and processing your Personal Data is achieved and/or the statutory retention period expires, your data will be deleted or blocked.
We have implemented commercially reasonable technical, physical, administrative, and organizational measures designed to protect Your Personal Data from accidental loss and from unauthorized access, use, modification, or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to cancel these measures or use, disclose or modify Your Personal data for improper purposes. Please also note that email and messaging systems are not considered secure, so we do not recommend sending your personal information to us using these means.
In the event that the use of your Personal Data has been violated as a result of a security breach, we will immediately notify the persons whose Personal Data was violated, in accordance with the notification procedure set out in this Policy, or in accordance with the requirements of the current legislation of the Russian Federation.
- Rights and Opportunities
12.1. In accordance with the regulations listed in paragraph 2 of this Policy, You are entitled to change or delete Your Personal Data, request access to Your Personal Data and correct it, obtain restrictions on the processing of Your Personal Data, request a copy of Your Personal Data, send an objection to the processing of Your Personal Data.
12.2. If you want to request access to Your Personal Data, make corrections to Your Personal Data, if you want to delete Your Personal Data, just send us a request by email to: firstname.lastname@example.org. We will make every reasonable effort to help You, and we will send Your request to our partners (Processors) who can access your Personal Data, and who work in accordance with their own privacy policies, the links to which we have listed in paragraph 2 hereof. We will respond to all your requests within a reasonable time.
We assure You that we will use Your Personal Data in accordance with this Policy to the extent that it is reasonably necessary for our legitimate commercial purposes, and we will use appropriate security measures to ensure the security, integrity, accuracy and confidentiality of the information that You have provided to us.
12.3. If you have any questions, comments or doubts about this Policy, please contact us by email: email@example.com.
Note for California residents
If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended («CCPA») You are entitled to certain rights in relation to your data. In addition to the rights set forth in this Policy, California residents have the following rights:
- The right to refuse to sell your information that can identify you. We inform you that We do not sell information about you for money.
- Non-discrimination. You have the right not to be discriminated against for exercising your rights under the CCPA.
- Minor Users
We offer our Users Products that are primarily aimed at children, and therefore We take many precautions to protect confidential information about children on the Internet. When We talk about «children» in this Policy, We mean children under the age of 13 (thirteen) years – for the United States, as well as children under the age of 16 (sixteen) years for the EU member states unless a member state has set a different age limit.
This Policy complies with COPPA, a US law made to protect the privacy of children on the Internet, as refers to our Applications designed for children. If you want to learn more about COPPA, you can refer to the «Children’s Privacy» section on the Federal Trade Commission website — https://www.ftc.gov/.
This Policy also complies with the GDPR, an EU law designed to protect and empower the personal data owners («Data Subjects») with regard to the privacy of children.
We do not knowingly collect any information about children except for that Personal Data that we need to support internal operations. We may collect that personal information about children that parents, legal representatives or persons over the age of 13 voluntarily provide in our Applications.
If we were to collect and store information about children that can identify the child, We would obtain the consent of the parent or legal representative prior to such collection.
In our Products designed for children, we collect information that includes persistent identifiers, such as the device ID («device ID») or the Internet Protocol address («IP address»). This information is collected solely for the purpose of providing functionality and supporting our internal operations and optimizing the gaming experience of our Users.
We do not allow behavioral targeting ads in our Applications for children (we do not use personalized ads).
If you believe that we may have inadvertently collected personally identifiable information about your child without your prior consent, you can contact us:
By email: firstname.lastname@example.org
By mail: 19-14 Spasonalivkovsky 1st Pereulok, Moscow 119049, Russia
- Policy Changes
However, if you do not agree with the Policy updates, you must stop using our Products and/or Services and delete the Application and/or Game from all your devices.
If you contact us by email, we will use your name and email address, as well as any other information included in the email, to respond to you. We may use your Personal Data provided in your messages to contact you and send a response.