Right to object: you have the legal right to object at any time to:
(i) Use of your personal data for direct marketing and profile creation; and
(ii) the processing of your personal data based on our legitimate interests, provided that we do not have any valid legal grounds for further processing.
1. AGE RESTRICTIONS
At the time of collecting personal data, we do not know the age of our players. We do not intentionally collect or request the personal data of users under the age of 18, and we do not intentionally send personalized advertising to such users. If you believe that we have any information received from or relating to a child under the age of 18, please contact us so that we can remove such information as quickly as possible.
2. PERSONAL DATA WHICH WE CAN COLLECT
2.1 We collect data to improve the quality of the products and Services provided to you, as well as to ensure our legal obligations. We may collect and process the following information about you:
2.1.1 data provided by you during registration, when using the Services, as well as when contacting us, for example:
- Your name, email address or other contact information voluntarily provided by you (“Contact Information”);
- ID of your transaction, payment amount (“Payment Information”);
- Your account name, social network identifier and other information indicated on the social network (if you decide to link a third-party social network to our Services);
- Other data that you decide to provide to us in the game, via e-mail or through web forms, including upon our request.
2.1.2 data that you publish in your user profile or that you publish in the game as messages. Please note that personal data that you voluntarily make publicly available in your user profile, or which you disclose by leaving comments, will be accessible to everyone and may be viewed by others. We do not bear any responsibility for any information that you voluntarily disclose by such and / or other explicit actions;
2.1.3 correspondence or its copies, if you contact us;
2.1.4 polls you have completed;
2.1.5 data about your device, such as its name and operating system, browser type, device language, manufacturer, as well as other available technical data;
2.1.6 data that we collect using cookies or similar technologies (see section “Cookies”)
2.1.7 general location data (e.g., location of a country or city) based on your IP address
2.1.8 data and analytics about your use of the Services (for example, game progress, levels, purchases, etc.) (“Analytical data”)
2.1.9 your IP address, mobile device identifiers (which may include: unique mobile device identifier (UDID), international mobile equipment identifier (IMEI), Android ID, device MAC address, Android advertising ID, advertising ID (IDFA ) and Merchant Identifier (IDFV) for the iOS platform, as well as OPEN UDID and ODIN). Some of these unique identifiers for mobile devices are used by advertisers to provide personalized advertising. They are the same for all applications, which allows tracking between applications. Advertising identifiers are fickle, depersonalized identifiers uniquely associated with your device. (see the Advertisers section below to find out
2.1.10 information about how you play and use the functionality of the Services (including recording a screen while using the Services, which in-game advertisements you are viewing, in-game preferences)
2.2 We may collect your personal data or data on the use of the Services from third parties, including:
2.2.1 Social networks. We may receive personal data if you decide to link a third-party social network to our Services. The nature of the information we receive depends on your privacy settings in such a social network.
2.2.2 Third Party Service Providers. We may receive your personal data from third-party sources, for example, from platforms on which games are running (for example, to confirm payment) or from geographic data (for example, to determine the approximate location of your IP address).
2.3 Lack of information in a special category. We do not request or intend to collect any “special category information”, such as information regarding health, race, religion, political views or philosophical beliefs, sexual preferences or orientation. Please be careful not to share such information about yourself (or others) using our Services.
3. HOW WE USE YOUR DATA
3.1. The information we collect is used only to provide the Services to you and to fulfill our legal obligations. We can also provide personal information to our service providers and partners, to the extent necessary to provide their services (see clause 4.1.2). We use the data we have to assist you, as our client, to provide you with the information you have requested, to improve the quality of our Services and prevent fraud, and to provide you with the most comfortable gameplay, taking into account your preferences, in particular for the following legitimate business goals:
To provide and manage our Services
- To create user accounts / profiles that will allow you to play our games and use our Services, if necessary;
- To provide and provide the services requested by you, and manage them;
- To provide the opportunity for your communication with other users;
- To send you messages related to the Services (for example, regarding changes, updates, new features);
- To verify and confirm payments (we do not collect or store credit card information);
- To provide suitable versions of our games (for example, games in the right language).
For the security and transparency of our Services
In order to ensure the safety and transparency of the social functions of the Services, to combat fraud, and to provide acceptable use, namely:
- To track the use of the Services and their social functions;
- For automatic or manual moderation of chats;
- To prevent and / or detect illegal activity, fraud or fraudulent behavior;
- To take action against players committing fraudulent or fraudulent acts, as well as against illegal activities (including against hacking or cheating).
To ensure fair and fair eSports tournaments
From time to time, PieDream together with its partners can organize e-sports tournaments for our games. Honest and fair eSports competitions are an important priority for PieDream and its partners. We make every effort to ensure compliance with the rules of e-sports tournaments, so that all participants have equal opportunities, and the winners are determined based on skills, not cheating.
To do this, during e-sports matches, PieDream can record data related to your gameplay (for example, take screenshots). Players who refuse such a record will not be allowed to matches and may be disqualified. PieDream may use the recorded data to investigate in-game fraud and apply sanctions. We will send you an in-game notice before the start of the tournament match.
We urge players to turn off pop-up notifications on your devices for the entire duration of a tournament match so that such notifications are not accidentally recorded by us.
To improve the Services, taking into account the preferences of our players
- To respond to your support requests (for example, if you contact us with a complaint or comment);
- To provide social functions as part of the Services;
- To conduct optional user surveys;
- To conduct research, testing, optimization, development and improvement of the Player’s Services and experience;
- To remember information for your subsequent authorization when using the Services;
- To inform you about promotions, awards, upcoming events, and other news about our products and services;
- So that we can receive data about errors that you / your device encounter when using our Services, and fix problems and compatibility problems;
- To process and analyze information, in order to better understand you and your preferences and to improve the quality of your gaming experience and the level of pleasure when using our Services.
For promotion purposes (including marketing and advertising)
- To find the right personalized ads for you;
- To track the installation of games (to evaluate the effect of a marketing campaign);
- To provide special gaming offers and rewards (based on your purchase and gaming history);
- To send marketing messages and / or newsletters, if you have consent to receive them.
- To comply with our legal obligations;
- To exercise, establish or protect our legal rights, as well as to protect the vital interests of both you and others;
- With your consent, we may also process your data for additional purposes.
4. WHO YOUR PERSONAL DATA CAN BE TRANSFERRED TO
4.1 We may transfer your personal data:
4.1.1 to our affiliates and members of the PieDream group of companies, both inside and outside the European Economic Area (EEA);
4.1.3 to other players and users, as Social features are an important part of our games. For example, users can view your profile data, game activity, as well as read messages posted by you. Please note that the data that you voluntarily publish in your user profile or which you disclose when posting comments is publicly available and can be viewed by other people .
4.1.4 to any competent law enforcement, regulatory or other government agency, court or other third party if, in our opinion, the transfer of personal data is necessary:
(a) in accordance with the applicable law or regulation, (b) for the implementation, establishment or protecting our legal rights, or
(c) protecting the vital interests of both you and any other person;
4.2 We require the observance of high standards of confidentiality from third parties. If any personal information we receive from you is provided to third parties outside the European Economic Area (EEA), we will ensure that appropriate security measures are followed, such as standard contractual terms approved by the European Commission or the use of the Privacy Shield mechanism.
4.3 We may share with third parties general information regarding how our users use our Services, but such information does not include data that allows you to personally identify you.
5. WHERE AND HOW MUCH TIME DO WE KEEP YOUR PERSONAL DATA
5.1 We take the necessary organizational and technical measures to protect the personal data held by us. Specific technical measures include data anonymization, data retention policies and encryption of transmitted data. Access to your personal data is granted only to those persons who, in our opinion, really need such access to perform their work.
5.3 The transmission of information via the Internet cannot be absolutely secure. Despite the fact that we take into account the confidentiality of personal data that we collect, process and store, and do our best to protect your personal data, we cannot guarantee the protection of your data in the process of their transfer to us, and you accept all risks associated with such a transfer.
5.4 We may store your personal data in order to provide any Services we provide or to comply with applicable laws, requests from state authorities or relevant decisions of competent courts. The duration of the storage of your personal information will depend on the services we provide and the period of your use of these services, and usually corresponds to one of the following categories:
5.4.1 backup copies of game data, magazines, correspondence history, etc., containing your personal data, are stored for up to 14 days;
5.4.2 any personal data collected and stored by us (for example, personalized game progress, information about payments, devices, etc.) will be deleted at your written request sent to us, or within 7 years from the date of your last use Services, whichever comes first;
5.4.3 any personal data collected and stored by us (for example, personal game progress, information about payments, devices, etc.) will be deleted after the termination of the corresponding game within 6 months;
5.4.4. screen recordings during e-sports matches will be deleted within 7 days after the end of the match. If fraud is registered, the data of such a user will be deleted at the end of the e-sports tournament within 6 months.
6. COMPLIANCE WITH LEGISLATIVE REQUIREMENTS AND COOPERATION WITH STATE AUTHORITIES, LEGAL BASIS FOR PROCESSING PERSONAL DATA
6.2.1 With your consent. We or our service providers / partners may request your consent to the processing of your data for certain purposes (for example, direct marketing) and you can withdraw your consent at any time;
6.2.2 Based on a legitimate (legitimate) interest. We process your personal data as part of our legitimate business interests, applying security measures to ensure the security of your privacy. This means that we process your data, in particular for:
- Providing, supporting and improving our Services to meet the needs of our users;
- New product and feature development;
- Detection, prevention or other solution to problems of fraud, misuse, security or technical problems with our websites; and,
- Protection against infringement of rights, damage to property or threats to security, in relation to us, our users or the public, in accordance with the requirements of the law or to the extent permitted by law;
- Providing you with special gaming offers and rewards.
6.2.3 At the conclusion and execution of the contract. We process your data to provide the Services you request (for example, make the game available to you, provide customer support services, etc.); and,
6.2.4 Subject to legal obligations. We process your data in the presence of an appropriate legal obligation, for example, in response to a court order or a reasoned request from government agencies.
6.3 If you have any questions regarding our legal basis for the processing of your information, you can contact us by e-mail firstname.lastname@example.org . If you have questions about your rights under local law, or if you want to file a complaint, you can contact your local data protection authority.
7. COOKIE FILES
Please note that in our games third-party advertising is shown, and we also advertise our Services through third parties. We want to provide you with more information regarding the use of information for advertising purposes, both in games and on third-party resources.
When you view ads using PieDream products
In order for us to display in-game ads, we can send your advertising identifier and IP address, as well as other information to advertisers (or ad networks). Thus, they can choose the ads suitable for you to display in our games and on third-party resources. You can control and limit our use of your advertising ID using the settings on your device. “PieDream” does not control what specific advertising will be shown in our games (this is controlled by advertising networks), but we block certain categories of advertising.
Advertising identifiers are used by advertising networks for a number of purposes, for example:
- To limit the number of times you view the same ad;
- In order to make sure that they work with people / real devices, and not with automated bots;
- To show you advertisements that may be of interest to you;
- Other brands purchase advertisements through ad networks or ad exchanges to showcase their products in PieDream games. An ad network or ad exchange acts as an intermediary between PieDream and other gaming companies.
In order for the ad network to charge a company buying an ad, the ad clicks are tracked, as well as the potential installation of third-party applications. Views, transitions, installations, and similar actions from advertisements are measured using the Advertiser’s identifier.
The IP address is typically used by advertisers to determine the total geographic area of your residence, for example, to determine the country, state, and, sometimes, city.
When you view PieDream ads on third-party services
PieDream also advertises its games in other applications through ad networks, showing ads to an audience that might be interested in these games. Advertising identifiers are used by advertising networks for some purposes, including, for example, determining the effectiveness of advertising (studying the aggregate views, conversions and settings that it generates through advertising in games of other publishers). Advertising identifiers are also used to track views, conversions, installations, and other similar activities from advertisements.
You can opt out of personalized ads in mobile applications by changing the privacy settings of your device and selecting “restrict ad tracking” (Apple iOS) or “opt out of personalized ads” (Android).
10. PROTECTING YOUR ACCOUNT
10.1 In cases where we provide you (or in cases when you independently set) a password that provides you with access to certain types of Services, you are responsible for ensuring the security of this password, as well as for any improper use of password-protected data. You should change your password regularly and not share it with anyone.
10.2 You are solely responsible for the protection and confidentiality of your account. Please make sure that you do not allow anyone to use the Services on your behalf and that you are logged out after completing work with your account.
10.3 You are responsible for all orders, as well as for the accuracy of information sent via the Internet using your user ID, password or other personal identification tools used to identify you in the Services.
11. YOUR RIGHTS
11.1 You have the following rights regarding your personal data held by us:
(a) the right to access, rectify, update or delete upon request your personal data;
(b) the right to object to the processing of your personal data (which are processed on the basis of a legitimate interest), the right to demand restrictions on the processing of your data or to send a request for the transfer of your personal data (request to provide you with the data that you transmitted earlier so that you can transfer this data to another controller);
(c) the right to refuse to receive personalized offers based on your gaming activity and behavior, as well as the right to object to the use of your personal data for direct marketing purposes;
(d) if we process your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing that we performed prior to your withdrawal, as well as the lawfulness of the processing of your personal data made on other legal grounds other than consent.
(e) you have the right to file a complaint regarding our collection and use of your personal data with data protection authorities. For more information, please contact your local data protection authority.
You can take advantage of all the rights listed above by creating an in-game application for support or by contacting us using the information in the “How to Contact Us” section below.
We will respond to all inquiries we receive from individuals who wish to exercise their rights to protect personal data in accordance with applicable laws on the protection of personal data.
11.2 If you have any questions and would like to contact us regarding the processing of your personal data or to exercise the rights described above, you can contact us by e-mail email@example.com . We may need to verify your identity before we can act upon your request.
11.3 You can refuse to collect your personal data by contacting us by e-mail firstname.lastname@example.org .
13. HOW TO CONTACT US
Data Controller: PieDream.
If you have any questions regarding data protection, or you would like to send a request to solve problems with your personal data, we recommend that you first contact us using the in-game support application. This will allow us to approach the consideration of the application in more detail, as it will be obtained directly from the device and from the application.
Last update: January 31, 2020