Effective date: November 18th, 2020.
This Policy is governed by the laws of Russian Federation.
If you have any questions or concerns, please contact us with the information provided in the Contact Information Section of this Policy.
We as Data controller
Information and Data we Collect from you
We as Data Controller does not and will not process any special categories of personal data and ("sensitive data").
INFORMATION WE COLLECT
1) Automatically collected data (such as IP Address, your device's operating system, browser type and language)
2) Mobile device identifiers (such as your unique device ID (persistent/non-persistent), hardware type)
3) General location information for the purpose of providing you with the correct version of the application
4) Applications and games data (such as your interactions with the application or game and with the other users or players inside the application or game respectively via server log files, your user or player ID)
Here you can find more about the collected information:
Registration, account, and sign-up information. We collect Information in the course of your use of, or registration with, us. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal information. This type of personal information can include email address.
Product/service purchase. Where you make a purchase on our site, we provide you third party services for purchasing and your payment data (e.g. credit/debit card, billing information and delivery address) is not collected by us.
Location information. We have access to certain Information about your location, such as your country or address, when you provide it or via device information (such as an IP address). With your consent (where required by law), we can also collect Information about your device's precise location (e.g. geolocation via mobile devices).
Technical and usage information . We also collect certain technical and usage information such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this Information.
Customer enquiries. Where you contact us through one of our customer helpdesks or customer support centers, we can have access to the application, or product/service that you have purchased, your purchase history, your previous correspondence with us or your contact details.
Tracking Technologies. We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify a user's computer/device and to "remember" things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable all cookies apart from the cookies necessary for the functioning of the site and/or an app.
Mobile Applications. When you use any of the applications or games on a mobile platform, we may record certain information and data, such as your application usage, access, session times and in-app purchases, your unique device ID (persistent / non-persistent), hardware type, the version of your operating system ("OS"), your device name, and your location (based on your Internet Protocol ("IP") address). This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest based advertising as described elsewhere in this Policy.
We may occasionally send you push notifications through our mobile applications to send you application or game updates, new content availability and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
Our Policy Regarding Children
We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal information. In the event that we learn that we have collected personal information from an individual under 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us by sending an email to email@example.com.
HOW WE USE THE INFORMATION
Providing and marketing products and services. We use the Information we collect about you in order to analyze your use of our products, applications, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use Information collected on our sites to enable you to:
get entertainment news and updates,
get information about our products, services, and content,
enter promotions, contests, and sweepstakes.
1) Fulfilling contractual obligations
2) Legal obligations
3) Your consent (where required)
4) Our legitimate interests:
- Improving and developing new products and services
- Being more efficient
- Preventing fraud
- Retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you will also be interested in
Communicating with you and others. We use Information about you to communicate with you, in order to:
to notify you when you win one of our contests or sweepstakes, or when we make changes to our policies or user agreements,
to respond to your inquiries,
to communicate with you about your purchases or transactions,
to contact you about your account, or
to send you information about promotions, offerings, and our features. You can also choose to receive push notifications from us on your mobile device. If you choose to submit content for publication online or in other forums, we can publish your screen name and other Information you have provided to us, in the Internet, or elsewhere.
1) Fulfilling contractual obligations
2) Legal obligations
3) Your consent (where required)
4) Our legitimate interests
- Communicating important information
- Improving and developing actual and prospective products and services
- Compiling statistics
Use of technical and usage information. We use technical and usage information to improve our design, functionality and content and to enable us to personalize your experience with our content and offerings. We use this Information in order to:
to provide, develop, maintain, personalize, protect, and improve our products, applications, services and video games, and to operate our business,
to perform analytics, including to analyze and report on usage and performance,
to protect against, identify, and prevent fraud and other unlawful activity,
to create aggregate data about groups or categories of our users, and
for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.
1) Legal obligations
2) Our legitimate interests:
- Protecting our business interests and rights, privacy, safety and property, or that of the public
- Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain
INFORMATION SHARING AND DISCLOSURE
We share and disclose Information for the following purposes:
Law enforcement bodies and courts. We disclose Information when provided by law, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose such Information to third parties:
in connection with fraud prevention activities,
where we believe it is necessary to investigate, prevent, or take action regarding illegal activities,
to protect our rights and the rights and safety of third parties, and
as otherwise required by law.
Change of control . We transfer Information in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
Service providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, conduct marketing, handle payments, email and order fulfillment, administer contests, conduct research and analytics, or customer service.
Linked sites. Some of our sites may contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the other sites' Privacy Policies or notices and terms before submitting any Information, as we have no control over Information that is submitted to, or collected by, these third parties.
Advertising networks. We share certain Information with third parties to provide advertising to you based on your interests. For more information, please see:
our Cookies and Other Technical Information and
Ad Choices sections below.
Marketing communications and sharing with third parties . We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at firstname.lastname@example.org. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please contact email@example.com.
You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
See also Cookies and Other Technical Information for more choices about managing other technical and usage information.
COOKIES AND OTHER TECHNICAL INFORMATION
Cookies and other technologies . We, and our affiliates, third party service providers, and trusted partners send "cookies" to your device or use similar technologies in order to analyze and enhance your user experience with us, as well as for advertising purposes and social features.
Cookies are small text files placed in your browser. We may also use pixels or "web beacons" that monitor your use of our sites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server. We may also integrate "Software Development Kits" ("SDKs"), java script or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app. Our sites may use locally stored objects ("LSOs") to provide certain content, such as video on demand, video clips, or animation, and better user experience.
to provide, develop, maintain, personalize, protect, and improve our sites, products, apps, services and video games, and to operate our business,
to perform analytics, including to analyze and report on usage and performance of our content and marketing materials,
to protect against, identify, and prevent fraud and other unlawful activity,
to create aggregate data about groups or categories of our users,
to synchronize users across devices, affiliates, and trusted partners, and
for us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us.
Managing cookies and other technologies.
Websites and mobile applications
Strictly necessary cookies or similar technologies : They are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
Performance cookies or similar technologies : They collect information about how you use our sites or apps, so that we can analyze traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our site or app.
Functionality cookies or similar technologies : They allow our sites or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Social media cookies or similar technologies : They are used when you share information using a social media sharing button or "like" button on our sites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
Advertising cookies or similar technologies : Some of our sites or apps may use a third party advertising network to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and Social Media Sites.
HOW YOU CAN ACCESS OR CORRECT INFORMATION
Under conditions, you have the right to ask us for a copy of your Information, to correct it, erase it or restrict its processing, and to obtain the Information you provide in a structured, machine-readable format.
You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process Information, you have the right to withdraw this consent at any time.
In cases permitted by law we reserve the right not to allow access to your Information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your Information even if you withdraw your consent.
We operate internationally, this means Information we collect will be processed by us in states where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.
When we transfer your Information to our group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your Information to third parties outside the EEA or we may adopt other means to ensure that adequate safeguards are applied to your Information (e.g. Privacy Shield, BCRs, etc). You may obtain a copy of the documents we use to protect your Information when it is transferred outside the EEA by contacting us via email at firstname.lastname@example.org.
NOTIFICATION REGARDING UPDATES
HOW TO CONTACT US
Privacy Notice for California residents
Effective date: November 18th, 2020.
1. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
1.1. In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
Examples: A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Commercial information.
Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
C. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
1.2. Personal information does not include:
Publicly available information from government records,
De-identified or aggregated consumer information,
Information excluded from the CCPA's scope, like:
1) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
2) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
1.3. We obtain the categories of personal information listed above from the following categories of sources:
Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
Directly from you when you provide it to us. For example, if you share your name and contact information to ask a question about our site or app.
Indirectly from you. For example, from observing your actions on our Applications.
From third parties, for example, our service providers.
2. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our site, app or product we will use that personal information to respond to your inquiry.
To provide, support, personalize and develop our site, apps and products.
To process your requests and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To notify you about changes to our site, app or any products or services we offer or provide through it.
To notify you about changes to our policies and/or user agreements.
To maintain a record of our dealings with you.
To understand and analyze the usage trends and preferences of our users, to improve the site, the app and other products and to develop new features, and functionality.
To engage features of third party social networks.
For testing, research, analysis and product development.
To help maintain the safety, security, and integrity of our site and app, and our databases, other technology assets and business.
To diagnose or fix technological problems in relation to our site, app and products.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
3. SHARING PERSONAL INFORMATION
3.1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
3.2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Commercial information.
Category C: Internet or other similar network activity
3.3. We disclose your personal information for a business purpose to the following categories of third parties:
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Law enforcement bodies and courts.
3.4. We share your personal information for the following general purposes:
Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
Protecting our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
In the preceding twelve (12) months, we have not sold any personal information.
4. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
4.1. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting and selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
4.2. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4.3. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
Emailing us at email@example.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
4.3.1. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
4.4. Personal Information Sales Opt-Out and Opt-In Rights
If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a variable notice to firstname.lastname@example.org.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on our Site and update the Privacy Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
7. CONTACT INFORMATION
If you have any questions or comments about this Privacy Notice, the ways
in which the Company collects and uses your information described here and
wish to exercise your rights under California law, please do not hesitate
to contact our representative responsible for personal information as