Privacy Policy

 Last updated: May 17, 2021.  

  1. Terms and definitions

Project First LLC, having the headquarters located at 19-14, 1st Spasonalivkovskiy pereulok, Moscow, 119049, Russia («Company») is dedicated to protecting the privacy rights of our online users. This Online Privacy Policy (the “Policy”) is a document developed to help Users understand the methods the Company collects, processes, uses, discloses, and manages Personal Data.

Users are people using any digital products or services produced/provided by the Company on the Platform (hereinafter the “User” / “Users” or “you”).

The Platform is an Internet platform that hosts applications, games or any other digital products produced by the Company (hereinafter the “Platform”).

Personal Data is information relating to an identifiable person that can be obtained by the Company when the user is using digital products or services produced/provided by the Company (hereinafter “Personal Data”). Aggregated and otherwise non-identifiable Personal Data is information that cannot be used to identify a User.

Personal Data Processing is an action performed by Controllers or Processors (under GDPR), including automatic and non-automatic operations with Personal Data of Users.

Data Controller is an organization that collects Personal Data from citizens of the European Union.

Data Processor is an organization that processes Personal Data on behalf of the Data Controller.

Application(App) is software developed by the Company that performs a specific function directly for a User.

Game is a game developed by the Company.

 

  1. General Terms

Our Company is committed to protect and respect your privacy. This Policy has been developed to inform you about the ways we collect, process, use, and manage the information you provide in connection with any game or application or any other digital products or services produced/provided by the Company (hereinafter referred to as “Products” or/and “Services”). Please note that the scope of this Policy is limited only to information collected by the Company through use of the Products. This Policy shall not apply to any practices of third parties that the Company will neither own nor control.

We process your Personal Data subject to your consent. Any use of the Products shall be construed as your acknowledgement and agreement with this Policy and our terms of use specified below. If you do not agree to these terms, please do not use the Service.

In respect of the use of Personal Data our Company complies with the regulations of the Russian Federal Law on Personal Data (No. 152-FZ), enacted as of July 27, 2006 and (where applicable) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal Data and on the free movement of such Data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).

 

  1. Personal Data collected by our partners

Please note that this Personal Data is collected automatically by third parties (controllers or processors under GDPR) due to the fact that you’re using our Products/Services:

  • Data on your game progress;
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
  • Data on your device, such as device name and operating system, browser type and language;
  • General location data;
  • Information on your use of our application or game, such as gameplay data and your interactions with other players (if applicable).
  • Some of our software products include features from our partners, such as social media interaction tools and in-game advertising. The list of these partners is available below. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

The list of third parties collecting Personal Data under this paragraph include:

 

  1. Personal Data that we can obtain from other sources and/or share with third parties

We may also cooperate with third parties (including, e.g. partners, technical contractors, payment services, analytics providers, search information providers), and may receive Personal Data from them as part of the service we provide to you, or for legal reasons and share Personal Data with such third parties. Such third parties will not collect Personal Data, except for the persistent identifiers (such as IDFA, IDFV, Advertising ID, or IP address) which are able to uniquely identify your device, but they do not identify you personally.

By accepting the terms and conditions of this Policy you agree that we may disclose any aggregated and non-identifiable Personal Data to third parties without restriction for any purpose.

 

  1. Why your Personal Data is collected and processed

Our Company collects Personal Data for some or all of the following reasons:

  • To provide you with Products and Services under the terms and conditions specified herein;
  • For legal reasons, e.g. if you have entered into a contract with us;
  • To provide you with information on our Products and Services, if you have consented to receive them;
  • To provide playing experience tailored to Users for the best quality of the Products or the Services.

 

Your Personal Data may be processed because:

  • We have a contract with you;
  • You have given us permission to do so;
  • We should provide Services to you after you have purchased any Products from us;
  • To comply with laws.

 

  1. Rights and Options

Pursuant to GDPR you have certain data subject rights among other things changing or deleting your Personal Data, requesting access to your Personal Data and its rectification, obtaining restriction of processing your Personal Data, asking for a copy of your Personal Data, objection to processing of your Personal Data.

 

Please note that we do not collect and store your Personal Data. Pursuant to paragraph 3 of the Policy your Personal Data is collected automatically by third parties (controllers or processors under GDPR). If you wish to request access to your Personal Data, to rectify your Personal Data, if you want to remove your Personal Data just send us an e-mail request to: policy@projectfirst.ru. We will make every reasonable effort to help you and shall forward your request to our partners (controllers or processors under GDPR) which may access your Personal Data and operate under their own privacy policies. We will respond to all your requests within reasonable time.

We assure you that we will use your Personal Data in accordance with this Policy to the extent deemed to be reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure security, integrity, accuracy and privacy of the information you have provided to us.

 

If you have any questions, comments, or concerns about this Policy, please contact our Company by email: policy@projectfirst.ru.

 

  1. Сhildren’s data

The Company understands that the target audience of the Products include children.

The Company takes many precautions to protect the online privacy of children. Whenever we refer to “children”/ “child” in this Policy, we mean children/child under the age of 13 (unless different age limitations apply in their country).

We follow the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children in Internet. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the Federal Trade Commission’s website of the United States of America.

Parents or any other legal guardians who wish their child to use our Games and Apps shall comply with the terms of this Policy and provide consent to the terms of processing of the Personal Data. Parents or other legal guardians will be responsible for the accuracy of the data submitted according to the Policy.

Acceptance of this Policy means that parents or any other legal guardians understand that the Personal Data referred to in this Policy may be collected and processed as described in the Policy, and have consented to this.

In our Apps and Games directed to children the Personal Data as described in this Policy is collected solely for the purposes of providing functionality and support for our internal operations of our Services and Products, to maintain or analyze its functioning.

The Company doesn’t permit behaviorally-targeted advertising to children in our Games and Apps.

Currently the Company doesn’t intentionally collect and/or process Personal Data or any personal information from children except and if otherwise outlined in this Policy. If we were to collect and store other personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exception that is permitted under COPPA.

When you download and use our Apps and Games, we don’t require you to provide any information about you or your child, except the age of the User. However, this information doesn’t allow to identify you or your child and is not collected by any third parties as described in this Policy. Please refer to the relevant sections of this Policy to learn what third parties may get information about Users and for what purposes.

If you believe that we may have unintentionally collected your child’s personal information without your prior consent, you may contact us by e-mail: policy@projectfirst.ru

 

  1. Changes in the Policy

The Company may change this Policy from time to time. Any such changes will be posted here in the present Policy, and we advise you to check back frequently to look for any updates or changes. We shall reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Policy will indicate the data it was last updated. Your continued use of our Platforms will acknowledge your acceptance of changes in our Policy.

 

  1. Company’s contact information

Project First LLC
Registered address: 19-14, 1st Spasonalivkovskiy pereulok, Moscow, 119049, Russia

Contact information:

https://www.projectfirst.ru/index.en.html

Email:  policy@projectfirst.ru

 

If you contact us via e-mail, we will collect your name and e-mail address, as well as any other information included in the e-mail, in order to respond you. We may only use your Personal Data submitted in your communications to contact and respond to you.