Effective Date: 19 November 2019
1.1. We are
committed to protecting and respecting your privacy. This Privacy
Policy (“Policy”) describes how we treat information that you provide to us or that we
collect about you. The data controller is Indeks Zero OOO with registered address at Belarus, Minsk, Platonova str. 31b, 220005.
1.2. By personal data,
we refer to data that relates to you as an identified or identifiable
person. Personal data include your name, your address, your telephone number, your email
address, your age, your gender and your game preferences. Anonymous information
which we are not in a position to relate to you, does not qualify as personal data.
We may collect personal data as well as other information when you use any of our services or applications provided on a mobile platform (for example iOS and Android) (together referred to as the “Services”).
1.4. We are
Indeks Zero OOO, Belarus,
Minsk, Platonova str. 31b, 220005 (“we”, “our” and “us”). We respect your right to
privacy and will only process personal data and other information
you provide to us or we collect about you in accordance with applicable privacy and
personal data protection laws.
2. Information and Data We Collect from You
2.1. Tracking Data and Account Data.
When using our Services, we may collect and process certain personally identifiable information that can be used to identify you (“Personal Data”). We avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us. We collect the following information:
a) Automatically collected data. When download and use our Services, we automatically collect application version, IP Address, your device’s operating system, time zone and language);
b) Mobile device identifiers (such as your unique device ID (persistent/non-persistent), hardware type, your device resolution);
c) General location information for the purpose of providing you with the correct version of the application;
a) – c) are together referred to as “Tracking Data”,
d) Applications and games data (such as your interactions with the application or game, your user or player ID, information about your activity through Services, i.e., date and time you used a Services, features you have used, purchase history, subscriptions and advertising you have clocked on) (“Account Data”).
2.2. Tracking Technologies
We and our partners, affiliates, or analytics service providers use technologies such as cookies to identify a user’s device and to remember things about your visit, such as 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, making the Service easier to use. You can disable cookies at any time.
2.3. Advertising networks
2.4. Information obtained from third parties
A list of third parties that operate on our Services can be found in Annex A below.
2.5. Other information
We may collect upon your permission other information such as precise using information including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it.
3. How We Use Your Information
We may use the information that you
provide to us or that we collect about you for the
a) Provision of services. Account Data
and Tracking Data may be collected
and processed by us to provide you with the Services that you request from us, including, without limitations, customer support services and to
as necessary to provide the requested Services, and comply with applicable laws.
b) Any data collected may be processed
by us to detect, investigate and prevent activities
c) Additional promotion and advertising:
We may advertise our Services and products and to send push notifications, our legal basis is legitimate interests to be able to advertise our Services and products to our users and run our business.
To opt-out of receiving advertisements for our Services and products, send us request through the in-app support feature. You can opt-out of from receiving push notifications by turning them off at the device level through the settings of the device. We rely on your consent to process Personal Data in order to provide personalized advertising to you, therefore you will be asked whether you consent to the tracking that enables personalized advertisement experience. To opt-out of receiving personalized advertisements, see below.
d) We may use Tracking Data to monitor,
improve, or modify the Services and our
4. Retention of Data
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations. We will also retain Account Data for internal analysis purposes. Account Data is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
We will delete your Personal Data after 14 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
5. Your rights
5.1. You have the right to request access to your Personal Data. Please contact us through email@example.com. Following your request, we will provide you a copy of your personal data in an electronic format.
5.2. You also have the right to correct your data, request deletion of your data, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
5.3. In order to show personalized advertisement we use specific advertisement networks to deliver advertisement that may be of your interest. For these purposes, such advertising partners use personal and non-personal information to identify your preferences, i.e. Android advertising ID and/or Apple's ID for advertising, and/or other tracking technologies to enable and optimize advertising procedure. In order to see the whole list of advertising partners, please see Annex B below. You can opt-out from personalized advertisement experience, at any time 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).
6. Sharing your information
We will not share your personal data
with anyone else unless in the following limited
a) To the extent that we are required to
do so by applicable law, by a governmental body or
by a law enforcement agency, or for crime prevention purposes.
c) Where necessary to provide you with
Services you request from us, we may share your
personal data with third parties who provide services to us (please see list of partners in Annex A and Annex B).
d) We 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 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.
We store the information on our users in the US using the services of company Pivotal Software, Inc., registered and operating in the United States, who acts as data processor.
We recognize that we have a special
obligation under applicable laws to protect personal
data obtained from children. We do not knowingly collect personal data from children
under 16 years old. If you are under 16, you may not use the Services or otherwise
provide any personal data to us. If we become aware that a child under 16 has submitted
information to us, we delete this information immediately. We encourage parents to
instruct their children to never give out their personal data, without permission, when
9.1. We take reasonable precautions
to prevent the loss, misuse or alteration of your
personal data. Our employees, contractors and agents may be given access to your personal
data which we collect, but their use shall be limited to the performance of their duties in
relation to facilitating your use of the Services. Our employees, contractors and agents who
have access to your personal data are required to keep that data confidential and are not
permitted to use it for any purposes other than those listed above or to deal with requests
which you submit to us.
9.2. We shall make our best efforts to get all reasonable technical, administrative and physical security measures to protect the security of your data.
10. Third party sites
The Services may contain links to
other websites operated and services provided by third
parties, including those retailers you enter into a transaction with. Please note that this
Policy applies only to the personal data that we collect through the Services and we cannot
be responsible for personal data that third parties may collect, store and use through their
11. International Transfer
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. We only transfer Personal Data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Policy and applicable law.
12. Changes to this Policy
13. Contact Us
Indeks Zero OOO, Belarus, Minsk, Platonova str. 31b, 220005. If you have any questions, complaints or comments regarding these Policy, please contact us at: firstname.lastname@example.org.
List of Analytics service providers
Facebook ads conversion tracking
List of advertising networks and their partners