Last updated: May 1, 2022
Michal Nowikowski (hereinafter referred to as “we”, or “us”) respects the privacy of its users, both parents and children (hereinafter referred to as “you” or “user”). We believe that it is important for you to make informed decisions regarding the use of our applications(“Apps”). Therefore, we have provided our privacy policy (“Privacy Policy”)which describes our privacy practices while you use our Apps. Please read it carefully as it will help you understand what we do with the information that we collect.
If you are a minor child or under the legal age to consent, please read the following privacy with your parent. Also, you must obtain parental consent before playing our Apps.
We are committed to protecting the privacy of children who use our Apps. This privacy policy explains our information collection, disclosure, and parental consent practices concerning the information provided by children. Accordingly, this Privacy Policy aims to comply with requirements of the U.S. Children's Online Privacy Protection Act ("COPPA"), the General information Protection Regulation and(“GDPR”) and any other applicable laws. We reserve the right to amend this Privacy Policy.
We may translate this Policy into other languages. If there is any difference between the English version and any other language version of this Agreement, then (subject to applicable laws and regulations) the English version will prevail to the extent of the inconsistency.
1. What information do we collect from you and how we use it?
In short, we collect information directly or passively. We won’t require a child to disclose more information than is reasonably necessary.
(a) Information we collect directly from you
Currently, we do not collect any information directly from you, such as biological information, location information, contact information, etc. If we change the type of information collected, we will mention it in our privacy policy and send a notification to users.
(b) Information we collect passively:
We also collect certain technical non-personal information (which might be considered as personal information under some legislations), such as
(1) IP Address;
(2) Log and usage data, such as game progress, game time, achievements, and error and crash reports. We use this information to:
(i) allow you to connect to the server;
(ii) operate, provide, maintain, protect, manage, customize our Apps and the way in which we offer them;
(iii) enhance the experience with the Apps, detect fraud, security or technical issues in connection with the Apps.
(c) Information collected by third parties:
Please carefully read Part 2(a) (Authorized third parties) of the Privacy Policy.
2. Advertising
(a) In order to allows us to continue offering the Apps for free or at low cost, we may display advertisements to you. To enable advertising tracking, we allow our advertising partners to collect device identifiers (i.e. IDFA on iOS) that might be considered as personal information under some legislations. You can choose whether to allow or disable our Apps from collecting this device identifier when prompted for an authorization notification by your phone system or through the privacy settings in your phone system.
(b) Currently, we only contract with partner to provide advertising. By indicating our content as child-directed, we disable any Interested-based ads and remarketing ads on our Apps.
3. Do we share any information we collect?
We do not sell any of your personal information with or to any independent third parties. Situations where we will disclose or allow a third party to collect (i.e. the device identifiers) your information are:
(a) Authorized third parties:
TODO(b) Business Transfers. We may transfer our information bases containing personal information in the event of a merger, acquisition, reorganization, bankruptcy or other similar events, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again.
(c) Law Enforcement-related disclosure. We may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
4. How do we protect and secure your information?
We may take proper physical, technical and administrative measures based on the existing technologies to prevent the illegal copying, loss, misuse, unauthorized access, download, disclosure, and changes of your information security. These measures include, but are not limited to, SSL, encrypted storage, information center access control, and dedicated network channels and proxies.
Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal information, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.
5. Parental rights
At any time, parents can refuse to permit us to collect further personal information from their children and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete information may lead to the deletion of an account.
Parents can request access to and delete their child's personal information by logging on to the child's account.
Parents can also contact us to request access to, change, or delete their child's personal information by sending an email to us at [email protected].
6. Jurisdiction-specific rights
Information protection law is jurisdiction-specific and we seek to abide by all relevant applicable laws.
(1) For EEA(European Economic Area) Resident, please carefully read Part 6.2(Your rights as an EEA resident) and Part 7(International Transfer) of the Privacy Policy.
(2) For California Resident, please carefully read Part 6.3(Your rights as a California Resident) of the Privacy Policy.
6.1. General rights
Your rights will be determined by the country in which you reside. Many counties have specific laws relating to privacy. We seek to abide by all relevant national laws.
(1) Right to Know
If you request in writing via email, we will provide you a copy of your personal information in an electronic format after passing our verification process.
(2) Right to Rectify
If we process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate and up-to-date for the purposes for which it was collected. If your personal information is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal information without undue delay and you can modify the information you provided via email.
(3) Right to Delete
You have the right to delete your personal information by contacting us at [email protected]. You acknowledge and agree that as a result of deleting your account, you will lose access to our services, including the account, subscriptions and App-related information linked to such account and lose the possibility to access other services through the account.
(4) Other Rights
You may request any other rights as provided herein or regulated in the applicable laws from authorities (including but not limited to the GDPR and the CCPA) by sending an email to [email protected]. Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information.
6.2. Your rights as an EEA resident
GDPR grants EEA residents certain privacy rights regarding the personal information we collect. You have the following rights in addition to your rights to know, correct, update, or request the deletion of your personal information.
(1) Right to Object
When our processing of your personal information is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to our processing. If you object, we will no longer process your personal information unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR; in particular, if the information is necessary for the establishment, exercise or defense of legal claims. You also have the right to complain at a supervisory authority.
(2) Right to Restrict Processing
You have the right to restrict the processing of your personal information under the conditions set out in Article 18 of the GDPR.
(3) Right to Personal information Portability
You have the right to receive your personal information in a structured, commonly used and machine-readable format and have the right to transmit those information to another controller under the conditions set out in Article 20 of the GDPR.
6.3. Your rights as a California resident
The California Consumer Privacy Act (“CCPA”) grants California residents certain privacy rights regarding personal information we collect. You have the following rights in addition to your rights to know, correct, update, or request the deletion of your personal information.
(1) Right to Know About Personal Information Collected, Disclosed, or Sold You have the right to access your personal information that we hold about you, i.e. the right to require free of charge,
(i) information whether your personal information is collected, used, disclosed, or sold,
(ii) categories of your personal information which has been collected in the preceding 12 months,
(iii) categories of sources from which your personal information is collected,
(iv) business or commercial purpose for collecting or selling your personal information (if any),
(v) disclosure of sale of your personal information (if any): i.e. the categories of your personal information which has been disclosed or sold (if any) to third-parties in the preceding 12 months, the categories of third parties to whom your personal information was disclosed or sold (if any), statement regarding whether we have actual knowledge that we sell your personal information if you are under 16 years of age; and you have the right to require us to provide a duplicate of your personal information undergoing processing, subject to submitting a verifiable request in the form of email to [email protected].
(2) Right to Opt-Out of the Sale of Personal Information (if any) You have the right to opt-out of the sale of your personal information (if any) and require us to make a statement regarding whether or not we sell your personal information and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
(3) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal information. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.
(4) Right to Authorize an Agent to Make a Request on Your Behalf You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and information security, we are entitled to denying such request.
7. International Transfer
We store information on the server closest to the end user's location to provide a secure and fast service The locations of servers for the game services include:
(1) the United States, in which the CCPA and the COPPA shall govern our services conducted as stipulated in this Privacy Policy;
(2) Hong Kong; and
(3) German (where EEA users' data is stored), in which the GDPR shall govern our services conducted as stipulated in this Privacy Policy.
You acknowledge and agree that your data is processed on our servers or our processors’s servers which may not locate in your country of residence. We use European Commission approved contract clauses to protect your personal information (see Firebase Data Processing and Security Terms: Model Contract Clauses at https://firebase.google.com/terms/firebase-mcc).
However, we will only keep your data for as long as your account is active or is only necessary to provide your services unless they are deleted in accordance with your request or in accordance with legal requirements and matter where the servers are located, we will make great efforts to take the appropriate measures to guarantee your rights in conformity with this Privacy Policy.
8. How long do we keep information about your?
The retention periods of the IP Address, Log and usage data: 3years.
9. Contact us with your questions
If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal information while using our services, please contact us as soon as possible by emailing us at [email protected].
10. Any changes to this policy?
We may occasionally update this Privacy Policy. When we do, we will indicate the date that this Privacy Policy was last updated. Any changes we make will be effective immediately upon notice. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
