The term “Services” refers to the act of providing you with the opportunity to use the Games, Website, in-game account (“Account“), as well as any of our other products and services (including support services, forums) related to the Games.
1. CONTROLLER’S NAME AND CONTACT DETAILS
Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding to our Website and Games is:
- Name: GAMINGSENSE LIMITED
- Address: Themistokli Dervi 3, Julia House, 1066, Nicosia, Cyprus
- Email: email@example.com
2. GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you. Processing is necessary for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms for which require the protection of your Personal Data.
Our legitimate interests are to provide our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.
3. INFORMATION WE COLLECT
In relation to your use of our Services, we gather information either directly from you (when you provide information to us) or indirectly (e.g. through our Website’s or Game’s technology). We may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.
3.1 INFORMATION YOU PROVIDE TO US
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information.
For the purposes of registration and authorization in our Services you will have to provide the following information and data:
- Your name and e-mail address;
- Information that you post, comment or like in any of the Game forums and Website;
- Information that you send through Zendesk client integrated into the Game or using contact form https://littlereaper.zendesk.com/hc/en-us in the Game;
- Information you provide when you request information or support from us.
3.2 INFORMATION WE RECEIVE FROM FACEBOOK
There is no option to create Account within the Game, though you can access the Game and use the Services by your Facebook account. When you access our Services by your Facebook account, you provide us with information from your Facebook account, as authorized by you and Facebook based on your privacy settings. This information may include:
- Your Facebook ID;
- Your name on Facebook;
- Your gender and birthday;
- Your profile picture;
- Information in your Facebook profile which you made publicly available;
- Your location and the location of the devices you use to access Services.
3.3 INFORMATION COLLECTED AUTOMATICALLY
Our Website and Services may collect some data automatically, for example:
- Your browser type/ browser version;
- Your operating system;
- Your IP addresses;
- Referrer URL;
- Time of the server request;
- Information about model or type of device you use to connect to our Website or Services;
- Your advertising ID (IDFA, IDFV, GAID);
- Your MAC address, IMEI, Carrier, device token;
- Screen DPI;
- What parts of our Website you access on and how long you look at our Website;
- Your location and the location of the devices you use to access Services.
This information is necessary to enable you for use of our Website and Services. These data cannot be attributed to specific persons. These data is not combined with other data sources. The processing of these data for the above-mentioned purposes is required for the protection of our legitimate interests, namely the usability of our Website and Services. You can limit the collection of some of the information through the standard privacy settings of the Internet browser or via settings of your device. We will delete this information as soon as it is no longer required for your use of our Website and/or Services. These data are stored by us on our servers and are not passed on to third parties. We reserve the right to check these data at a later date if we become aware of specific indications of illegal use.
3.3.1 INFORMATION COLLECTED BY OUR WEBSITE AND THIRD PARTY ANALYTIC SOFTWARE (COOKIES)
Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as “Tracking Data”. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When you visit our Website, our servers log your computer’s IP address.
3.3.2 INFORMATION COLLECTED BY OUR SERVICES (GAME RELATED INFORMATION)
We may also collect some data regarding your activity within our Services, such as:
- Your user ID;
- Your Nickname, picture and other Game player Profile Data;
- Date of your Account registration;
- Last in-game login date;
- Information on your in-game payments and in-game purchases;
- Information on your in-game behavior (Game progress and gameplay actions).
3.4 PAYMENT INFORMATION
4. LEGAL BASIS OF PROCESSING PERSONAL INFORMATION
We may process your information in case of:
- We provide you Services;
- You have given us permission to do so;
- Compliance with the law.
We need to process your Personal Data in order to fulfil the contract with you according to Article 6(1)(b) of the GDPR. We will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
- for registration and authorization purposes in our Services;
- to provide you with the Services you request;
- for the purposes of in-game behavior analyses and improvement of our Services and indicating technical problems;
- to charge in-game currency under your in-game payments;
- to communicate with you about your Account and send you information about features on our Services or changes to our policies;
- to provide you with support including, but not limited to, product updates, product patches and fixes and other similar communications.
5. HOW WE USE YOUR INFORMATION
5.1. COMMUNICATION PURPOSES
We will use your Personal Data for our legitimate interests according to Article 6(1)(f) of the GDPR to notify you and provide you with information about features on our Services, new product releases and service developments and to advertise our products and services in accordance with this Policy. Namely, once you have created an Account we may use your email address, nickname, IP address, in order to send you emails, messages and targeted in-game and web offers about Games. Also, if you opt-in, we will send you emails, messages and targeted in-game and web offers about Gamingsense offline events, co-projects of Gamingsense and its partners, as well as about Gamingsense games.
5.2. SERVICES IMPROVEMENT PURPOSES
We analyse the Tracking Data, content data and Game-Related Information to identify how to improve the Services and our operations to make them more interesting for our players in general. You are not obligated to respond to polls or surveys and you have choices about the information you provide.
6. HOW WE SHARE YOUR INFORMATION
We may share your personal information with third parties, either because you have consented to allow us to do so or for legal reasons. For example, we may share your personal information with:
- Our group companies, which means our subsidiaries, or our ultimate holding company and its subsidiaries;
- Subcontractors and third parties for the purpose of providing you Services;
- With third parties because you have given consent.
Data regarding your activity within the Services (information on your in-game purchases and information on your in-game behavior) can be shared with our partners for the purposes of in-game behavior analyses and improvement of our Services, indicating technical problems and rendering add offers which allow you to receive in-game bounces.
If Gamingsense or substantially all of our assets are acquired by a third party, personal data held by Gamingsense about users of our Website and Services will be one of the transferred assets of the company.
In addition, we will share your personal data with third parties for the following reasons:
- If we must comply with a legal obligation;
- To protect the rights, property, or safety of Gamingsense, our customers or others;
- To prevent fraud or to reduce our credit risks.
In order to combat illegal activities, we can provide data to government authorities at their request. We may also disclose your data with your permission in order to comply with the requirements of the law or protect the rights and interests of our company or others.
We may share your personal data with the following categories of third parties:
Payment partners: we may share your device IDs, IP address, information about in-game purchases requested by you, and other information you provide to us for the purpose of fulfilling your purchase requests with such companies as Apple Inc., Google LLC.;
Advertising and advertising measurement partners: we share some of your information such as your advertising ID (IDFA, IDFV, GAID) in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, or otherwise facilitate transmittal of information that may be useful, relevant, or of interest to you, with such companies as MyTracker, AppsFlyer, Google, Facebook, IronSource, Unity Technologies APS, MRGService;
Data storage partners: your game data is stored on the servers of Google Cloud Platform, by Google LLC;
Research partners: we may provide access to some of your data, such as your Game statistics, to provide marketing-related and other research. We share anonymous data with our partners unless your personal data is necessary for the requested services or research;
Customer support partners: for some territories and products we engage third parties to provide you with appropriate customer support services. Such companies may get access to your personal data, including personal data that you may provide in your customer support requests. Such partners include Zendesk Inc;
External moderators and testers: some limited data about you (such as your nickname, content of customer support ticket) may become available to third party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games.
Gamingsense subsidiaries and affiliates: as a global company, we collect information that may be processed in our offices worldwide. Your information may also be processed outside of the European Economic Area, e.g. in the United States, the Russian Federation, or any other country in which we, our affiliates or subsidiaries maintain presence.
When your personal data is shared with Gamingsense affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, Gamingsense guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with Gamingsense affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the standard data protection clauses upon your request.
Sharing anonymous information. We also may share anonymous information, i.e. information which does not directly or indirectly disclose your identity, and aggregated information (meaning information about groups and categories of users, including game statistics and behaviour, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
7. INFORMATION SECURITY
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.
8. PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Those companies may be located outside of the European Economic Area. Read more in Section 6 “How we share your information”.
We recognise that we have a special obligation to protect personal information obtained from children. We will not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law).
10. DATA RETENTION
We will not retain your personal information for longer than required.
We will keep your personal information:
- For as long as required by law;
- Until we no longer have a valid reason for keeping it;
- Until you request us to stop using it.
For example, we keep your personal information which we received by Services, until such Services is operated by us. If we cease operation of Game all your personal information collected by such Game will be deleted by us. Although, we can keep your e-mail to send you information about our new services and products until you refuse to receive them.
We may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our user.
11. WHAT IF YOU CHOOSE NOT TO PROVIDE US WITH YOUR PERSONAL INFORMATION
If the personal information is necessary for registration and/or use of our Services and/or use functionality of our Website, then you will not be able to use our Services and/or enjoy full functionality of our Website.
12. LINKS TO OTHER WEBSITES
From time to time our Website or Services may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for any such policies. Please check these policies, where available, before you submit any personal data to these websites.
13. YOUR RIGHTS
13.1. OPT-OUT OF DIRECT MARKETING
You can opt-out of interest-based advertising on mobile applications, including our mobile Games, by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android).
13.2 RIGHT TO OBJECT
Where processing of your Personal Data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims.
13.3. RIGHT OF ACCESS
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. Normally, we provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. Once the archive with the Personal Data we retain is ready, you will be able to download in it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, website, etc.
13.4. RIGHT TO RECTIFICATION
If the information we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. Please contact us if you need us to rectify your information: firstname.lastname@example.org
13.5. RIGHT TO ERASURE
This is sometimes called ‘the right to be forgotten’. If you want us to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact us: email@example.com.
13.7 RIGHT TO RESTRICT PROCESSING
You have the right to ask us to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
13.8. RIGHT TO DATA PORTALILITY
We must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this affecting the usability of your data. This right only applies to personal data that you have provided to us as the data controller. The data must be held by us by consent or for the performance of a contract.
13.9. RIGHT TO WITHDRAW CONSENT
If you have given us your consent to process your data but changed your mind later, you have the right to withdraw your consent at any time, and we must stop processing your data.
13.10. RIGHT TO COMPLAIN TO SUPERVISING AUTHORITY
If you are of the opinion that we do not process your personal data in accordance with the statutory regulations, you have a right of appeal to a competent supervisory authority in accordance with Art. 77 of GDPR.
14. WE CAN CHANGE THIS POLICY
© GAMINGSENSE LIMITED 2019