"kanstantsinarkhipenka" (“we,” “us” or “our”) is dedicated to protecting the privacy of our users and handling any personal data we obtain from our users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.
"kanstantsinarkhipenka" may use affiliates or reputable third parties’ services for the processing of personal data collected on or through our mobile games ("Games"). By using our Games, you are accepting the practices described in this privacy policy.
1.1. This privacy policy ("Privacy Policy") explains how information about you is collected, used, and disclosed by "kanstantsinarkhipenka" when you play one of our Games.
This Privacy Policy is applicable where we acts as a data controller with respect to your data.
This is the case where we determine the purposes and means of the data processing in our Games.
1.2. The Privacy Policy applies in addition to our terms of use and other policies. In the case of a contradiction between the Terms of Use and this Privacy Policy, this Privacy Policy will prevail.
1.3 Our Privacy policy applies to all users, and others who access the App (“Users”).For the purposes of the GDPR, we are the data controller.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. BY ACCESSING OR USING THE APP, YOU AGREE TO PROCESSING OF YOUR PERSONAL DATA WHICH IS PROVIDED TO US IN LINE WITH THE TERMS OF THIS PRIVACY POLICY.
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
Log-, device-, usage-, and consumption information and device identifiers are being processed:
to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
to provide and maintain the App and the game experience; and
to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
to provide news and information about the App that we think will be of interest to you;
to personalize and improve the App and provide tailored content and features;
to monitor and analyze trends, usage and activities in connection with the App;
Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").
to provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
Information from other sources are being processed:
to provide and deliver the products and services you request and send you related information;
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
to link or combine information we get from others to help understand your needs and provide you with better service; and
to provide news and information about the App we think will be of interest to you;
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than (3) years after your interaction with us has ceased.
- Ad network providers
We uses ad network providers, ad exchanges, and ad servers ("Advertising Partners") to help present advertisements in our Games or run advertising campaigns on third party games and platforms. These Advertising Partners use certain technologies for presenting, better targeting, and measuring the effectiveness of their advertisements, using data gathered over time and across their networks of games to determine or predict the characteristics and preferences of their audiences ("Advertising Data").
We processes such information in accordance with this Privacy Policy. Our Advertising Partners may act as a data processor or data controller with regards to the Advertising Data, depending on the scope of their services. The Advertising Partners are responsible for their compliance with the applicable data protection legislation. The use of the advertising technologies by such third parties as ad network providers is subject to their own privacy policies, not this Privacy Policy. The legal basis for the processing of the Advertising Data for targeted advertisements is consent. The legal basis for optimizing and tracking conversion rates of advertising campaigns that we run with others is legitimate interest.
- Analytics Partners
We uses analytics partners in order to help get insights into the usage of the Games ("Usage Data"). These analytics partners process Usage Data, which may include, among others, your IP address, geographical location, operating system, time spent in the Games, and other information about how you use the Games. This data is used to analyze the use of the Games and to improve the Games and related services. Our analytics partners will act as a data processor in relation to the Usage Data. The legal basis for the processing of the Usage Data is legitimate interest.
- Analytic third-party partners
Request user data deletion. When you install and use our mobile applications, we can collect and process some of your data for different legitimate purposes. You will find below explanations regarding the reasons why we may collect data.
We and its third-party partners collect data:
To provide you with the services you asked for;
To run analytics and understand how users interact with our product and services to improve them continuously.
The third-party partners that we will share the data with are:
GameAnalytics;
Facebook Analytics;
Adjust.
Data deletion requests
To delete user data collected by "kanstantsinarkhipenka", please contact us from email.
If you also want to request the deletion of the data that may have been collected about you or your device by our third-party partners that are acting as independent data controllers, you will find below the contact for each partner and the link to the relevant section of their privacy policies:
GameAnalytics:
email: privacy@gameanalytics.com;
privacy policy: https://gameanalytics.com/privacy/#6-changing-or-deleting-your-information.
Facebook Analytics:
email: none, please refer to the privacy policy;
privacy policy: https://www.facebook.com/policy.php.
Unity Analytics:
email: none, please refer to the privacy policy;
privacy policy: https://unity3d.com/legal/privacy-policy
Adjust:
email: privacy@adjust.com;
privacy policy: https://www.adjust.com/terms/privacy-policy
We does not collect any of your personal data and only provides an SDK package to retrieve the data collected by the above-mentioned partners. You can still contact them to request the deletion of their access to the partners’ interfaces or email.
- Partner networks
"kanstantsinarkhipenka" may use partner network providers who assist us to distribute the Game in order to enable as many gamers as possible to play the Game.
- Developers
After the Game has been launched, it will be continuously monitored and improved to maintain and effectuate the best gaming experience for our gamers. Developers may therefore see and have access to your information, but they will only use this information for game optimization purposes. The legal basis for the processing of this data is contractual necessity.
- Other
We may supply information to other parties if we are required to do so by law or by a ruling from a court of law.
Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.
If you have additional questions about SayGames's privacy practices related to children under the applicable minimum age, please contact us at email.
- Your personal data may be stored by us and its business partners. In case the applicable data protection laws provide so, you have the right to access, rectify, and erase the personal data we hold about you and to restrict or object to our processing of your personal data. To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time.
- If you wish to exercise these rights, you can do so by sending an email.
- You can, at any time, opt-out of marketing communication messages you receive from us by clicking the opt-out link in these messages.
- We does not knowingly process personal data from anyone under the age of 16 without parental consent. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data. Parents of users under the age of 16: if you wish to have access to your child’s personal data to view, correct, or delete the information that we have collected about your child, please send an email with all such information. After verification, the copy of your passport will be shredded.
5.5. In the event you have any questions or concerns in relation to the processing of your personal data, you can send an email to our Data Protection Officer by email. If you are not satisfied with our responses and/or support to resolve your concerns, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) Member State where you work, normally live, or where any alleged infringement of data protection laws occurred.
- We has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to the Game.
- Although we allow you to set privacy options that limit access to your personal data, please be aware that no security measures are perfect or impenetrable. We are not responsible for the circumvention of any privacy settings or security measures contained in the Games.
- We reserve the right to amend our Privacy Policy. Amendments will be effective from the moment of publication, so please check regularly to be sure you are familiar with the latest version.
- In the event of a transfer of (one of our) Games to a third party, we may transfer to such third party all personal information that we collected about you in accordance with this Privacy Policy. In such an event, users who have provided email addresses to us will be notified when information about those users is transferred and becomes subject to a different privacy policy. If you have any additional questions or requests, you may send an email.