GENERAL PRIVACY POLICY

(Last Updated: Fri, February 28, 2022)

Introduction

This Privacy Policy describes how I, Evgeniy Ivon (hereinafter “I”) collect, use, and share information about you when you use my games and applications (collectively, the “Services”). This Privacy Policy does not apply to information collected by third parties that may interact with my Services (e.g., an Apple leaderboard plug-in). It is a General Privacy Policy and applies to information collected through the Services regardless of your location and includes specific notices required by law in certain locations.

Please take the time to read this Privacy Policy, as it explains how I collect, use and protect your personal data.

HOW & WHEN I MAY COLLECT YOUR PERSONAL DATA

From the moment you begin interacting with my products, I am collecting personal data. Sometimes the personal data I collect is provided by you and sometimes it is collected automatically.

You give me data when you: use one of my applications, play one of my games, enter one of my tournaments, opt-in to receive marketing messages, subscribe to my mailing lists, email me, live chat with me online, chat to me in-game, make a purchase from me, enter one of my prize draws or competitions, answer one of my surveys, fill in a form, interact with other users or players, ‘follow’, ‘like’, post to or interact with my social media accounts.

I may collect your data automatically when you: interact with other users or players, open an email from me, sign in to my apps and games, play my games, leave your comments or make a purchase from me.

TYPES OF PERSONAL DATA I MAY COLLECT

Depending on the specific services you use and how you interact with me, I may collect various types of personal data as further described in this section.

Contact details Your name, address, telephone number and email address.

Account profile data Your name, email address, birth date, gender, username and password.

Financial information Your bank account number, credit/debit card details, electronic payment processor details and billing address.

Information that identifies you Your birth date, IP address, login information, social media username(s), browser type and version, time zone setting, browser plug-in types, geolocation information, operating system and version, cookies, Google AdID, Apple IDFA and other unique device IDs.

Information on how you purchase and use my Services Your gaming platform, game version, mobile and hardware identifiers, device event information, crash reports, language or subtitle options, game scores, game metrics, achievements, rankings, play time, feature usage, player performance and progression, purchases, time zone, timestamp, session duration, challenges or gifts sent to other players and number of friends on the platform.

Survey information Any information that you decide to provide to me when you complete one of my surveys.

Information provided to me by third parties Game Platforms Nickname, username, user ID, friends list, email address, geolocation, language, user preferences, date of birth and games you have played. Mobile Platform Providers and App Stores Username, device ID, purchase history and geo-location. When you log in with your Facebook account Account ID, email address and friends playing the same game.

What about children’s data?

You must be at least 13 years old (for EU and US citizens) or of the legal age in accordance with the laws of your country to accept this Privacy Policy. If you are under 13 years old or not of the legal age, please ask your parent or legal guardian to explain this Policy to you and accept it on your behalf. If you think I have unintentionally collected personal data from someone under the age of 13, please let me know by contacting me at (ivoneug@gmail.com).

WHY & HOW I USE YOUR PERSONAL DATA

I will use your personal data only for certain specified reasons and only when I have a lawful basis to do so. Which of the following reasons is applicable to you depends on the type of relationship I have with you and how I interact with you. For example, I will not use your personal data for the purpose of processing payments unless you’ve made, or attempted to make, a purchase from me.

Keeping my Services running

Providing you my Services, login authentication, age verification, remembering your settings, populating leaderboards, hosting and back-end infrastructure and keeping my Services secure.

In the EU and UK, my lawful bases for this use of your personal data are: performing our contract with you, to comply with my legal obligations and legitimate interests to keep my Services running.

Processing payments

I do not process your payments. Your payments are processed by the platform.

In the EU and UK, the platform’s lawful basis for this use of your personal data is: performing your contract with them.

Targeted advertising

Through cookies, clear GIFs, web beacons and tracking pixels certain third parties may use your information to deliver relevant advertisements and offers to you and measure the effectiveness of the advertising and offers. These technologies connect your behavior across different websites, mobile apps and devices and enable tailored advertising to be served to your game, web browser, or mobile device.

In the EU and UK, the lawful basis for this use of your personal data is: your consent.

Customer support

When you apply for customer support with me, I may use your information for handling enquiries or complaints, troubleshooting and solving technical issues over, phone, email, making necessary changes to my Services.

In the EU and UK, my lawful bases for this use of your personal data are: performing my contract with you, my legitimate interests to provide you with customer service, my legitimate interests in providing the correct products and services to my users or to comply with my legal obligations.

Improving and continually developing my Services

I carry out analytics and research on in-game data collection and related metrics to understand how my customers are playing games and the effectiveness of my marketing campaigns. I also use your information to undertake player segmentation (profiling), cheat detection and prevention, machine learning (I sometimes use carefully selected third parties to do this on our behalf), traffic optimization.

In the EU and UK, my lawful bases for this use of your personal data are: performing my contract with you and my legitimate interests in learning about the types of people who are interested in my Services, to keep my Services updated and relevant, and to develop my business, understand how my customers play my games and inform my marketing strategy.

Contests and tournaments

When you participate in my contests, tournaments or other promotional events I run from time to time, should you decide to participate in them, I will use your information to process your entry as well as to communicate with you and reward you either digitally or physically, if you qualify to receive the reward. In some cases my promotional events may have a “leaderboard,” entry list, or similar element, in which case I may display your name or other information you submitted on such a publicly accessible list. Some contests, prize draws, and tournaments will also involve publicly displaying your entry in media throughout the world.

In the EU and UK, our lawful bases for this use of your personal data are: your consent or contract.

WHAT THE DIFFERENT LAWFUL BASES MEAN

This section explains what the lawful bases I rely on for processing your personal data actually mean.

Consent

You have provided clear and unambiguous consent for me to process your personal data for a specific purpose. You have the right to withdraw this consent at any time.

Contract

I need to process your personal data for me to fulfill my contractual relationship with you.

Legitimate interests

I need to process your personal data for my legitimate interests, or the legitimate interests of a third party, in conducting and managing my business and my relationship with you. When I use your personal data for my legitimate interests, I try to take into account any potential impact that such use may have on you.

Legal obligation

I have a legal obligation under applicable law to process your personal data.

KEEPING YOUR PERSONAL DATA SECURE

I treat your personal data with care and take reasonable steps to protect it, including the use of physical, technical and administrative safeguards to protect your personal data from unauthorized access, use or disclosure.

If you believe your personal data has been breached, please contact me immediately at (ivoneug@gmail.com).

WHO I SHARE PERSONAL DATA WITH

Depending on the purpose for which I collect your personal data or the nature of my interaction with you, I may use third parties to process some of your personal data.

I require that these third parties use only the information they need to perform their specific services as specified in my contract with them. If I stop using any such third party’s services, I require that your personal data held by them is either securely and permanently deleted or rendered irreversibly anonymous. In all cases, I apply measures to keep your data safe and your privacy protected.

I may share your personal data with Google, Facebook and other third-party advertising partners so they can show you my products and services that might be of interest to you while you are on a social media platform, browsing the internet or playing our mobile games. This is based on your consent to marketing or my legitimate interests to provide you with marketing communications where I may lawfully do so.

Under very specific circumstances, I will share your personal data with third parties (including law enforcement bodies) in order to respond to or investigate fraudulent, unauthorized or criminal (or potentially fraudulent, unauthorized or criminal) activity on or related to my systems, services, or events, including the unauthorized disclosure of non-public information related to current or future services. I may also be required by law to disclose your personal data to the police or to another law enforcement, regulatory or government body in your country of origin or elsewhere, including upon receiving a legally valid request to do so. I may also be required by law to disclose your personal data to third parties in response to a court order, subpoena, or other compulsory process.

COOKIES

I use cookies and similar technologies for analytics, to allow our services to operate effectively, to enhance your experience when using my Services and to bring you relevant advertising.

Some features of the Services may not function properly if you choose to disable cookies, and some types of cookies may not be disabled using browsers. In some instances, especially with respect to mobile apps, I may require you to uninstall/not use the Services rather than have a poor experience from disabling cookies.

LOCATION DATA

For my mobile apps, you can turn off our collection of precise location data through the settings on your device. You can stop collection of all location data through a particular app by uninstalling that app.

HOW LONG I HOLD YOUR DATA FOR

I will retain your personal data for only as long as you are a customer or are using my Services and for no longer than is necessary after that. I will securely destroy or irreversibly anonymize your personal data once it is no longer necessary for me to retain it.

YOUR RIGHTS OVER YOUR PERSONAL DATA

This section describes the various rights you have over your personal data under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) and the UK Data Protection Act 2018, how you can invoke these rights with me and where you can find more detailed information about these rights.

Your right of access

You have the right to request copies of your personal data. This right always applies. However, there are some exemptions, which means you may not always receive all the personal data you request.

Your right to rectification

You have the right to request that I rectify information you think is inaccurate or complete information you think is incomplete. This right always applies.

Your right to erasure

You have the right to request that I erase your personal data in certain circumstances.

Your right to restriction of processing

You have the right to request that I restrict the processing of your personal data in certain circumstances.

Your right to object to processing

You have the right to object to me processing your personal data under certain circumstances, including when I do so based on my legitimate interests.

Your right to data portability

You have the right to request that I transfer your personal data to another organization, or that I provide a copy of it to you. This right applies only to personal data you have given me and that I am processing based on your consent or my contract with you.

You are not required to pay any charge for exercising these rights.

To exercise your above rights, or any other rights available to you under applicable law, please email me at (ivoneug@gmail.com).

Customers in the EU or UK may also lodge a complaint regarding my use of your personal data. If you have such a complaint, I ask that you please tell me first so I can have a chance to look into your concerns. If you remain unsatisfied, you can contact your local Supervisory Authority or the Information Commissioner’s Office.

YOUR CALIFORNIA PRIVACY RIGHTS

This section describes the various rights California residents have over their personal information under the California Consumer Privacy Act of 2018 (“CCPA”) and how you can invoke these rights with us.

Notice of collection

We may collect the following personal data from you:

  • Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
  • Customer records, including phone number, billing address, and credit or debit card information.
  • Characteristics of protected classifications under California or federal law, including gender.
  • Commercial or transactions information, including records of products or services purchased, obtained, or considered.
  • Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
  • Geolocation data.
  • Employment and education information.
  • Inferences drawn from the above information about your predicted characteristics and preferences.

I do not generally sell information as the term “sell” is traditionally understood. To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, I will comply with applicable law as to such activity. I disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review “Who I share personal data with” above for further details about the categories of parties with whom I may share information.

Your right to know and delete

For more information on this, please see the above section “Your rights over your personal data”.

Your right to opt-out

To the extent I sell your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by me to third parties at any time. You can submit a request to opt-out by sending me an email to (ivoneug@gmail.com).

Authorized agent

You can designate an authorized agent to submit requests on your behalf. However, I will require written proof of the agent’s permission to do so and verify your identity directly.

Your right to non-discrimination

You have the right not to be discriminated against in service or price if you exercise your privacy rights.

Shine the light

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by my to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom I disclosed such information.

ANY QUESTIONS?

I hope the above Privacy Policy is clearly understandable and I commend you on your dedication to understanding how I handle your personal data and your rights to control it. If this Privacy Policy hasn’t answered all your questions, or if you have any comments or ideas about how I could improve this Privacy Policy, please don’t hesitate to contact me at: (ivoneug@gmail.com)