Updated: October 19, 2021
ACKNOWLEDGEMENT AND AGREEMENT TO TERMS
By using or accessing the Products and Services in any manner, or otherwise indicating your agreement such as may be required for use of an app, you acknowledge having notice of this policy and agree to the collection, use, and disclosure of your information as described.
We may update our policy as we develop our practices and products. If you use any Products and Services or accept the terms after any update, you agree to the terms of the update.
PERSONAL INFORMATION WE COLLECT
We collect personal information for limited purposes, such as to provide the Products and Services, as described below.
Personal information is typically described as information used to identify you, or which can be used to identify an individual. We will describe to you the nature of the personal information and the purposes for its collection, use or disclosure at the time or before doing so. We also will use aggregated information or data from which identifiers are removed for various purposes.
Categories of Personal Information
Depending on the game you download, we may collect basic identifying information from you to establish your identity such as your first name, surname, last name, username, and email address.
If you have accessed the game through an app, it will use your Gamer ID or Game Centre ID. We also use Firebase and Microsoft Azure PlayFab cross-network identity solution for authentication. These operate in accordance with the applicable Google, Apple or Microsoft terms respectively and may permit you and the provider to link your accounts across various platforms and devices. We typically will not collect your authentication information from these services except for a unique player ID which permits game functionality.
We may collect your address, email address and telephone number to contact you regarding the Products and Services you have signed up for or requested.
Any details about payments to and from you and other details of Products or Services you have purchased from us.
In-App purchases (including in-game purchases) will typically be done through your Google, Apple or Microsoft account so we will not receive your personal details such as credit card or banking information in respect of those purchases.
As above, you will be assigned a unique player ID in relation to your Google, Apple or Firebase which we will use to enable game play. We will also collect aggregated information regarding such things as in-game events, session activities, and game performance to improve games, advertising attribution tracking, and to make games more interesting to you.
If you access our website, we may collect your internet protocol (IP) address, your applicable login data, browser type and version, timestamp, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website. This information is collected by Google Analytics and other similar service providers for us.
User Generated Content
Any personal information that you provide for the purposes of accessing or using our Products and Services or otherwise post or share on our website or games. Such user generated content may include your submissions on ideas or content, emails to us, photos, videos, in-game chats, and feedback.
We also collect, use and share aggregated data which may be derived in whole or in part from personal information. It does not directly or indirectly reveal your identity. Aggregated data may include statistical or demographic data. For example, we may aggregate Game Play Data to track the number of players using particular features and when, as well as the ads they are served.
Google Analytics, a web analytics service provided by Google Inc. which tracks and reports website traffic, including such data as your IP address, general location, device type, browser used, time spent and pages visited.
These tools may remain on your device after you leave our site (until the cookie expires or is deleted by you). You can disable cookies and other tracking technologies by adjusting the settings on your internet browser, however, disabling cookies may affect your ability to access some pages on our websites.
HOW YOUR INFORMATION IS USED
We collect personal information for limited purposes, such as to provide the Products and Services.
How we use your Personal Information and why
We will only use your personal information for the purposes we have explained to you or as listed below, unless we are permitted or required by law. We may use your personal information for the following purposes:
Identity, Contact information
To engage you as a new user, customer or developer, including account creation, verification and communications with you regarding Products and Services you request
Identity, Game Play and User Generated Content
Game operations, such as allowing game play and advancements in association with your game ID, to assess and improve games as well as our Products and Services and associated systems
Identity, Contact information, and User Generated Content
To provide you with our Products and Services such as game development support, player and technical support (such as to address player issues, bugs and glitches, obtain your feedback, and process refunds), access to our website resources, and associated administration related to the Products and Services you have requested
Device data and Identity
To operate and improve our website and provide you access with associated Products and Services, to help us understand your interests and preferences, enable operation of various features on our website including the personalization of features, to audit interactions, transactions, and other compliance activities, and to troubleshoot issues with the website and ensure its proper operation
Identity, Contact information, and Device data
For fraud prevention and security, including to detect and prevent security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity
For marketing attribution by us or third parties identified by us to associate information for mobile advertising service and tracking purposes (See Marketing Attribution below)
We use third parties to assist us in understanding the interactions you have with various advertising media through our games, apps. This information is used to attribute metrics regarding advertisements and their effectiveness. For example, our service provider Kochava, focuses on mobile attribution for app-installations connecting new app installations to the marketing campaign and media source. Your device’s operating system may have options to limit, turn off or reset the advertising identifiers associated with the system’s advertising IDs.
To set your Android Advertising ID:
Go to ‘Settings
Scroll down and click on ‘Google
Scroll down and click on ‘Ads
Shift the ‘Opt out of Ads Personalization’ slider to the right.
If at any time you wish to reset your Android Advertising ID, you can instead click on “Reset advertising id”.
iOS Advertising Tracking:
We follow Apple’s AppTrackingTransparency framework. This requires that you agree to sharing Device information with third parties to allow advertising tracking. In devices running iOS 14 or after, Marketing Attribution partners and Ad Networks will not be able to identify your Device unless of course you opt in. You may do that on installation of the app / game, or set it yourself:
Go to ‘Settings’
Scroll down and click on ‘Privacy
Scroll down to the bottom of the page and tap Advertising
Toggle the ‘limit ad tracking’ slider on or off.
If you do not permit ad tracking on your device, you may still be shown advertisements through or Products and Services but they will not be tailored to your preferences in the same way.
If permitted on your device, third party Marketing Attribution partners and Ad Networks may directly collect and process information via cookies and tracking technologies. This is so they can serve you with content that is tailored to your preferences. For more information on how these Marketing Attribution partners and Ad Networks collect and process your personal information, please see the relevant Google, Apple or Microsoft terms relevant to you and the privacy policies of the Ad Networks. For ease of reference, we provide here links to such Ad Networks so you can find out more about how they work and their privacy practices:
Unity Ads https://unity.com/solutions/unity-ads
Facebook Ads Manager https://www.facebook.com/
No Cross Device Tracking.
Although we collect information through various tracking technologies, we do not link information across your different devices and browsers, and do not create a consolidated profile of your cross-device online activity or behaviour.
Other Legal Basis for Use.
There may be other legally permitted business reasons we process or use your personal information. For example, we may use and process your personal information to perform a contract we have entered into with you, enforce our contractual rights and exercise our legal obligations, to comply with a legal or regulatory obligation, to investigate and take steps to prevent fraud or breach of a law or contract, or as otherwise permitted by law.
SHARING YOUR PERSONAL INFORMATION
We share information about you for limited purposes only, such as to assist us with our business and the provision of Products and Services to you.
We currently use third party service providers for the following services:
Analytics services (e.g., Google LLC, Facebook Analytics);
Account and database management (e.g. Firebase)
User Acquisition services (e.g., Kochava);
Hosting and content delivery network services (e.g., Google CDN)
Any sharing or disclosure of your personal information to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed. The third party service providers will have access limited to personal information needed to do the specific tasks that they have been hired to do. We do not permit our service providers to sell the personal information shared with them. We also take steps to ensure your personal information remains secure. See our Security Measures section below.
Some of the third party service providers identified in this Policy are located outside of Ukraine, and your personal information may be stored, accessed or used in the United States and may be subject to the laws and access by government or regulatory organizations in those jurisdictions. As above, if we share your personal information, we will take reasonable steps to ensure that your personal information remains secure and your privacy is protected.
Data transfers for European Data Subjects We are not an establishment under European data protections laws (e.g. the General Data Protection Regulation “GDPR”), however, if you are a European data subject, we take appropriate steps to ensure that we process your personal information in accordance with the GDPR. We are based in Ukraine, and so rely on the legal ability to transfer data to Ukraine as a permitted jurisdiction under GDPR. We will seek express consent from European data subjects to data sharing with providers processing personal information outside your jurisdiction. If you do not provide consent, we may not be able to provide the Products and Services you have requested. We also take appropriate steps to ensure that we have implemented appropriate safeguards to protect your personal information and your privacy rights.
A summary of your particular rights as a data subject of a member state pursuant to GDPR is described in the Additional Information for European Data Subjects section below.
If you are a data subject of an EU member state and have questions about our practices or wish to exercise any of your privacy rights, please contact our privacy officer as described below with a written request.
SECURITY MEASURES WE TAKE TO PROTECT PERSONAL DATA
We are committed to taking reasonable efforts to secure the information that you provide us, and we use a variety of measures for security. We use security technologies to help protect against unauthorized access to, alteration, disclosure, or destruction of your personal information. We limit access to personal information by those employees who have a business need to have access. Our staff are subject to duties of confidentiality.
We have put in place procedures to deal with any actual or suspected misuse of personal information. Unfortunately, no transmission of personal information can be guaranteed to be 100% secure. Thus, we cannot guarantee or warrant the security of any information you provide to us.
We retain your personal information for as long as your account is active or as needed to provide you with our Products and Services, comply with our legal obligations, such as regulatory requirements, resolve disputes and enforce our rights and agreements.
We use care when destroying or disposing of personal information to prevent unauthorized access, use or disclosure of any personal information.
CORRECTION AND ACCESS TO YOUR PERSONAL INFORMATION
You may request access to the personal information we hold about you by making a request in writing at the contact information noted below, with sufficient detail to enable us to identify the nature of the personal information being sought. We may ask you to confirm your identity by providing reasonable proof. Access to your personal information may be limited for a number of reasons, which include but are not limited to if it would reveal: personal information about another individual, confidential commercial information, or privileged information.
In appropriate circumstances, we may charge a reasonable fee according to the cost required to retrieve and provide access to the personal information you request. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee. Playesta may not provide access to your personal information in all cases where the denial of access is required or authorized by law. If we deny your request for access to your personal information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address questions you may have.
You may challenge the accuracy and completeness of your personal information we hold by contacting us through our privacy officer below. In appropriate circumstances, we will amend your information. It is your responsibility to provide any updates to your relevant personal information to Playesta in writing.
With respect to data portability rights, we may only be able or have a requirement to port personal information you have provided to us, not any other information. These rights may be restricted for various reasons, including if we are not processing the information by automated means or providing you with the information would prejudice another person’s rights.
The Products and Services may contain links to third party websites (the “Linked Sites”) that are not controlled or operated by Playesta. The Linked Sites are maintained by the third parties who have their own privacy policies and their own terms and conditions of use. This policy does not apply to any of the Linked Sites and we are not responsible for any information collected, used or disclosed by virtue of your activities on those Linked Sites or for their privacy practices. You are responsible for understanding the privacy practices of those Linked Sites before using them.
Playesta recognizes the privacy interests of children. Our Products and Services are not intended for children under the age of 13 and we do not target our Products and Services to children under the age of 13. We do not knowingly collect or use any personal information from children under the age of 13. We encourage parents and guardians to take an active role in their children’s use of our Products and Services. A parent or guardian who becomes aware that their child has provided us with information without consent should contact us at the email address below. We will delete such information from our files within a reasonable time.
If you are between the age of 13 and 18, please obtain your parents’ permission prior to using any of our Products and Services or providing us with any Personal Information.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
California residents may have particular or additional rights in accordance with the law. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of your rights. As a summary, you rights may include the following:
Right to Know. You can receive a copy of categories of personal information and specific pieces of personal information we have collected about you in the past 12 months, consistent with legal requirements. We may provide you with data electronically, sent in a portable and readily usable format that allows for the transmission of this data to third parties.
Right to Deletion. You can request we delete personal information we collect or maintain about you, subject to certain exceptions prescribed by law.
Right to Opt-Out of Sale. We do not sell your personal information. You can request restriction or object to the processing of your personal information, and you have the right to opt in or opt out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law. See our Marketing Attribution and Ad Tracking opt-in / opt-out information above.
Right to Non-Discrimination. We will not discriminate or disadvantage you because you have exercised your rights.
Correction. You can request correction of your personal information where it is inaccurate or incomplete. See the section above about correcting your personal information.
None of these are intended to limit your privacy rights available in law. Some of these rights may be exercised by updating your account, or you can contact our privacy officer as set out below.
ADDITIONAL INFORMATION FOR EUROPEAN DATA SUBJECTS
If you are a data subject of an EU member state, you may have particular rights in respect of your personal data pursuant to GDPR. We have summarized these rights below, however, not all details are included and so you should read the relevant laws and guidance from the regulatory authorities for a full explanation. Your principal rights under data protection law are to:
Access your data;
Rectify your data;
Erase your data;
Restrict and object to processing;
Obtain your data in a portable format;
Raise concerns with us and initiate complaints a supervisory authority; and
Withdraw your consent.
We respect your personal data rights and we will take reasonable steps to respond to any requests you have to exercise those rights, or any questions or concerns that you may have. None of these are intended to limit your privacy rights available in law. Your rights may have some exceptions and restrictions as provided by law. For example, your rights to erasure as well as to restrict or object to data processing are subject to general exclusions where continued storage or processing is necessary for such things as compliance with a legal obligation.
If you wish to access or rectify your personal data, please contact us as described in the section regarding Correction and Access to your Personal Information.
This policy is governed and interpreted pursuant to the laws of Ukraine applicable therein, without regard to principles of conflicts of law that would impose the law of another jurisdiction.
Should you have a dispute with us regarding our privacy practices, by using our Products and Services, you agree to raise any complaint under the laws of Ukraine, therein, through the regulatory framework pursuant to those laws. You further agree that such regulatory bodies and courts of Ukraine, therein have exclusive jurisdiction over, and you agree to submit to them only, any dispute in respect of the issues covered in this policy.
If you choose to provide personal information by using our Products and Services from outside Ukraine, you are responsible for compliance with local laws, if and to the extent local laws are applicable.
We welcome questions or comments about our privacy practices and this policy. Please direct any questions, comments or concerns to the following address: