Our primary purpose in collecting information is to provide you with a safe, efficient and customized experience and to provide you with Services and features that better meet your needs or requests.
We collect information about you, including:
Age: We log your age as indicated by you in the age gate upon downloading the App.
Log Information: We log information about your use of the App, including the type of device you use, your mobile operating system, the features you use, access times and your IP address.
Device Information: We collect information about the device you use to access the App, including unique device identifiers (i.e. Device ID and advertising ID) and mobile network information.
Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements.
Microphone sensor information: We collect the sound level from the microphone sensor data.
Age is being processed:
•to identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data.
Our processing for the above purpose is necessary for compliance purposes, see Article 6(1)(c) of the GDPR. 1
Log-, device-, usage- and microphone sensor- information 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;
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 personalize and improve the App and provide tailored content and features;
•to monitor and analyze trends, usage and activities in connection with the App;
•to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in 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 non-child 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).
We will store your personal information for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules. Your information are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes.
We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
We accept advertisements from Third Parties ad networks which may be displayed in our Apps. We may share certain information with third-party advertisers, ad networks and ad platforms (“Advertising Entities”) to develop and deliver targeted advertising in the Apps. We may also allow Advertising Entities to collect personal information within the Services which they may share with us, including your device identifier, device type, device brand, device model, network type, device language, and IP address. Advertising entities may also collect information related to the performance of the advertisements, such as how many times an advertisement is shown, how long an advertisement is viewed, and any click-throughs of an advertisement.
If you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners' sites or apps” located at https://google.com/policies/privacy/partners/
Our applications are for a general audience. In order to comply with the legislation, you will be presented to an age screen, when launching the App. When presented with this age screen, it is important that you state the correct age. Based on your age information and your device settings, we do not process personal data of children under the minimum age limit that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement. If such personal data have been processed without our knowledge, we will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from our records. We do not store the year of birth of users who have identified themselves as below the age of 13 in our Apps, but only the information that their device ID did not pass the age gate.
The only personal information we collect from users who have identified themselves as below the age of 13 for the purposes of offering our services are persistent identifiers (such as device ID, advertising ID, IP address). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to place contextual advertisement (including frequency capping), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.
Opting Out of IBA:
1. Via third party IBA providers
•For FB Ads please visit https://www.facebook.com/settings?tab=ads;
•For Google (AdMob) please visit https://www.google.com/ads/preferences/html/mobile-about.html;
•For Vungle please visit https://vungle.com/opt-out/;
•For AdColony please visit https://www.adcolony.com/privacy-policy/#targetingchoices.
If you choose to opt out by following one of the third party IBA provider’s opt out mechanisms, you should stop receiving ads based on your interest via the selected third party IBA provider, but you may continue to receive interest-based or targeted ads via other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options 2. and 3. below.
2. Via “Do Not Track Settings” in mobile phone
For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:
Open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”
3. Via our apps
We have created an opt-out option within some of our Apps. You may choose it by visiting ''Info Screen'' and ticking the ''Withdraw Consent''. Choosing this option will mean that you will still be served ads, but they will not be tailored to your preferences.
If you wish to use any of the rights described below, you may contact us at any time by emailing us at email@example.com.
Right to request access
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
• the purposes of the processing
• the categories of personal data concerned
• the recipients or categories of recipient to whom the personal data have been or will be disclosed
• the envisaged period for which the personal data will be stored Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
The right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-ofinterest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.
Right to rectification and erasure
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• if you have withdrawn your consent and there are no other legal grounds for the processing,
• if you have objected to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
• the personal data have been unlawfully processed or
• the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, xercise or defense of a legal claim or to protect a person or important grounds of public interest.
The right to withdraw consent
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your user license to use the App will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
The right to data portability
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
Dmitsoft reserves the right to share your information with third parties if we believe such action is necessary in order to: (1) conform with the requirements of the law or to comply with legal process served upon us; (2) protect or defend our legal rights or property (3) investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or violations of the terms and conditions of using our Apps and Services.
Your continued use of the Apps and Services following the posting of changes will mean you accept those changes.
If you have any questions regarding privacy while using the Apps, or have questions about our practices, please contact us via email at firstname.lastname@example.org