1. Terms and definitions
Users are people using any digital products or services produced/provided by the Company on the Platform (hereinafter the “User” / “Users” or “you”).
The Platform is an Internet platform that hosts applications, games or any other digital products produced by the Company (hereinafter the “Platform”).
Personal Data is information relating to an identifiable person that can be obtained by the Company when the user is using digital products or services produced/provided by the Company (hereinafter “Personal Data”). Aggregated and otherwise non-identifiable Personal Data is information that cannot be used to identify a User.
Personal Data Processing is an action performed by Controllers or Processors (under GDPR), including automatic and non-automatic operations with Personal Data of Users.
Data Controller is an organization that collects Personal Data from citizens of the European Union.
Data Processor is an organization that processes Personal Data on behalf of the Data Controller.
Application is software developed by the Company that performs a specific function directly for a User.
Game is a game developed by the Company
2. General Terms
Our Company is committed to protect and respect your privacy. This Policy has been developed to inform you about the ways we collect, process, use, and manage the information you provide in connection with any game or application or any other digital products or services produced/provided by the Company (hereinafter referred to as “Products” or/and “Services”). Please note that the scope of this Policy is limited only to information collected by the Company through use of the Products. This Policy shall not apply to any practices of third parties that the Company will neither own nor control.
In respect of the use of Personal Data our Company complies with the regulations of the Russian Federal Law on Personal Data (No. 152-FZ), enacted as of July 27, 2006 and (where applicable) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal Data and on the free movement of such Data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).
3. Personal Data collected by our partners
At the moment we don’t use any personal data, but in case that in a future we use some information would be:
Please note that this Personal Data is collected automatically by third parties (controllers or processors under GDPR) due to the fact that you’re using our Products/Services:
- Data on your game progress;
- Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
- Data on your device, such as device name and operating system, browser type and language;
- General location data;
- Precise geo-location data (GPS, with your consent);
- Information on your use of our application or game, such as gameplay data and your interactions with other players (if applicable).
- Our software products include features from our partners, such as social media interaction tools and in-game advertising. The list of these partners is available below. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
4. Personal Data that we can obtain from other sources and/or share with third parties
We may also cooperate with third parties (including, e.g. partners, technical contractors, payment services, analytics providers, search information providers), and may receive Personal Data from them as part of the service we provide to you, or for legal reasons and share Personal Data with such third parties. Such third parties will not collect Personal Data, except for the persistent identifiers (such as IDFA, IDFV, Advertising ID, or IP address) which are able to uniquely identify your device, but they do not identify you personally.
By accepting the terms and conditions of this Policy you agree that we may disclose any aggregated and non-identifiable Personal Data to third parties without restriction for any purpose.
5. Why your Personal Data is collected and processed
Our Company collects Personal Data for some or all of the following reasons:
- To provide you with Products and Services under the terms and conditions specified herein;
- For legal reasons, e.g. if you have entered into a contract with us;
- To provide you with information on our Products and Services, if you have consented to receive them;
- To provide advertising and playing experience tailored to Users for the best quality of the Products or the Services.
Your Personal Data may be processed because:
- We have a contract with you;
- You have given us permission to do so;
- We should provide Services to you after you have purchased any Products from us;
- To comply with laws.
6. Rights and Options
Pursuant to GDPR you have certain data subject rights among other things changing or deleting your Personal Data, requesting access to your Personal Data and its rectification, obtaining restriction of processing your Personal Data, asking for a copy of your Personal Data, objection to processing of your Personal Data.
Please note that we do not collect and store your Personal Data. Pursuant to paragraph 3 of the Policy your Personal Data is collected automatically by third parties (controllers or processors under GDPR). If you wish to request access to your Personal Data, to rectify your Personal Data, if you want to remove your Personal Data just send us an e-mail request to: firstname.lastname@example.org. We will make every reasonable effort to help you and shall forward your request to our partners (controllers or processors under GDPR) which may access your Personal Data and operate under their own privacy policies. We will respond to all your requests within reasonable time.
We assure you that we will use your Personal Data in accordance with this Policy to the extent deemed to be reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure security, integrity, accuracy and privacy of the information you have provided to us.
If you have any questions, comments, or concerns about this Policy, please contact our Company by email: email@example.com.
7. Opt-out of targeted advertising
Some of our Games has an option to personalize your advertising using software development kits (SDK) of Appodeal, Admob, Yandex AppMetrica, GameAnalytics, OneSignal and other third-party companies, In particular, these SDK may collect and process your Personal Data such as device identifiers, location data, demographic and other data to provide you with relevant advertising. By consenting to this, you will also see ads that Appodeal and its partners believe are more relevant to you.
You may opt-out of interest-based personalized advertising on mobile applications by checking the privacy settings on your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For personalized in-game offers opt-out, you may use the options provided in the Game settings.
At the same time some of our Games may use software development kits (SDK) of Yandex AppMetrica, GameAnalytics, OneSignal and other third-party companies for analyzing players gaming experience and your gaming experience to improve it. These SDK may collect and process your Personal Data such as device identifiers, location data, demographic and other data in anonymous form to provide you with relevant playing experience to improve the quality of the game.
If you ever change your mind, you may withdraw your consent from the Setting menu on your Android or iOS device.
As we do not process or operate information on the age of Users of our Products, the Company may not been able to prevent processing of the data of person under the legal age. We also do not intentionally collect personal information on the age through our Products. If you are a parent or guardian of a child and you believe that we have inadvertently received personal information about the child, please contact us and we will delete the information from our records. If you are a parent of a teenager under 16 (or any applicable age in your country), we will seek your consent, if you wish your minors to access the Products.
We also follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children in Internet. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the Federal Trade Commission’s website of the United States of America.
We don’t knowingly collect personal information from children under the age of 13, and if in the event that a user identifies himself or herself as a child under the age of 13 through a support request or through any feedback, we will not collect, store or use, and will delete in a secure manner, any personal information of such user.
If you believe that we may have unintentionally collected your child’s personal information without your prior consent, you may contact us by e-mail: firstname.lastname@example.org
We draw your attention that we do not collect any personal information. When you download and use our mobile Applications, we don’t require you to provide any information about you and we don’t collect any information about you or your device. We use only general information about you to analyze how users interact with our apps. It includes only technical characteristics of your device. We use the your device’s IP address for the sole purpose of providing support for the internal operations of the our online Service, to maintain or analyze its functioning.
Parents who have registered their child to the our Games and Apps should understand that information, including but not limited to a child’s first name, last name’s initial, country of residence and behavioral activity, may be collected by third parties including, for example, analytics providers, search information providers.
Our Games and Apps may contain advertisements about third party products and services but in any case, we did not permit behaviorally-targeted advertising to children in our Games and Apps where we have actual knowledge that the user is under the age of 13.
9. Changes in the Policy
The Company may change this Policy from time to time. Any such changes will be posted here in the present Policy, and we advise you to check back frequently to look for any updates or changes. We shall reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Policy will indicate the data it was last updated. Your continued use of our Platforms will acknowledge your acceptance of changes in our Policy.
10. Company’s contact information
Twisted Fingers Games – Jaime Falomir – Fernando Iguago
Address: Müggelstr. 18 10247 Berlin (Germany)
If you contact us via e-mail, we will collect your name and e-mail address, as well as any other information included in the e-mail, in order to respond you. We may only use your Personal Data submitted in your communications to contact and respond to you.