Personal data protection statement
We strive to protect the privacy of personal data that we obtain and process. During data processing, the Company undertakes to take all necessary technical and regulatory action in strict compliance with applicable law and solely upon legal grounds permitting any such processing.
If you do not want us to collect and process information about you in accordance with this Policy, you may not, unfortunately, use our applications and/or services.
When we control data collection methods and identify the goals for which such data is used, the Company becomes the “data controller” for the purposes of the EU General Data Protection Regulation (the “GDPR”), the UK Data Protection Act 2018, and any other European data protection legislation. We may also be the “data operator” under the 1998 Children’s Online Privacy Protection Rule (the “COPPA”).
We process personal data only upon at least one of the following legitimate grounds for such processing, including but not limited to:
- processing is required for the purposes of any legitimate interests of the Company as the controller or third party (unless where interests pertaining to fundamental rights and freedoms of the data subject that require data protection prevail over the above interests);
- processing is required to execute or fulfil an agreement with you (including any offer and acceptance), including when you are using our applications / services;
- you consented to your data processing;
- such processing is required under the legislation of the countries to which we provide our services or make our applications / services available;
At the same time, please note that we do not request special categories of personal data of our users / visitors.
If you do not agree to the updates, you may refuse to use our applications / services (in particular, by removing the applications from your devices).
Anyway, you can always delete or re-install an application on your mobile device to delete or change the personal data accordingly.
How do we obtain personal data?
The Company may obtain your data from various sources and with various aims, including, without limitation:
- when you watch ads in our applications;
- when you play our games or use other services in applications or on the website;
- when you make a purchase through our applications
- when you contact us via support email;
Our applications can gather information based on the analysis of actions taken during their use.
What personal data we collect and process
The following information about you can be collected and processed by our applications and/or services used by you, including the website:
- device information (such as device name / model, operating system, browser information, including browser type and language settings);
- game progress and activities (such as remembering the language selected by the user and level of difficulty at a certain stage of use);
- geo location (country, state or region, GPS location);
- device IDs and advertisement ID (if authorised by the user);
- Information that we collect using cookies and similar technologies
However, if data processing is not required for using our applications and/or services by you, or is not explicitly required by law, we will delete it.
App Tracking Transparency (ATT) Compliance
In alignment with Apple’s App Tracking Transparency (ATT) framework, we want to assure our users that our educational mobile games designed for Kids do not utilize ATT, and we refrain from tracking any specific user identifiers for advertising purposes. We are dedicated to upholding the privacy and security of our young users. Our apps do not engage in tracking practices involving the linking of data with third-party sources for advertising or sharing collected data with data brokers. Our commitment is to create a safe and enjoyable digital environment for children, and we strictly adhere to Apple’s privacy requirements.
We treat a user / customer as a child if they are under 13 years of age, unless different age limitations apply in their country.
We do not intentionally collect and process children’s personal data. However, the Company understands that the target audience of our applications may include children, and that among its users there are probably parents with children who might be ordering services for children.
When ordering a service or downloading an application for further use, the person who takes the relevant action is representing the legitimate interests of the child and is personally responsible for the child’s actions with this service and/or application in future.
Children must not disclose their real name, location, phone number or email address, or any other personal data without prior consent of their parents or any other legitimate representatives.
We do not encourage children to participate in a game by using our applications through offering a reward, and we do not encourage any other child’s activities that disclose more personal data of the child that actually required to use the application.
Our applications and other services do not involve any direct disclosure of the child’s personal data to any third parties.
Please refer to the relevant sections of this Policy below to learn what third parties may get information about users and for what purposes.
Purposes of personal data processing
The Company provides services and makes its applications available almost worldwide. We use the collected information about users / customers mostly to ensure the appropriate quality of our services, in particular, to enhance your gaming experience and improve functions and capabilities of our applications in future. We may analyse information related to the use of applications in order to adapt the user tasks so that they would better suit the user’s needs.
We also use personal data for the following purposes:
- providing promotional / marketing information, including joint special offers of the Company and our partners;
- buying a Premium Access;
- offering you a full scope of our services;
- control of age restrictions that meet the legislation of your country of residence;
- bug finding and fixing;
- advisory assistance to users;
- use for administrative, analytical and statistic purposes;
- advertising / direct marketing and efficiency assessment;
- protection against any malicious actions of users and in connection with other security considerations of the Company;
- safeguarding of the Company’s legitimate interests;
Please understand that we have to display ads in our applications, including third party ads, to raise funding for development, distribution and technical support of our applications, most of which are free. For example, you might see third party advertisements while using our application.
Emailing any advertising / marketing notifications to you requires your specific consent that may be revoked at any time.
Some of our applications have in-app purchasing function as Premium Access.
External payment processors do not share the information provided by you, and we do not have credit card details. However, we receive a summary about all purchases made, including the transaction amount, which is necessary to give access to your purchase in the application.
Personal data disclosures
We may, and in certain cases must, disclose personal data to third parties to ensure your use of our applications and/or other services. The reason is that we use services of other companies – our partners that have limited access to certain information about users for purposes like administration, optimisation, marketing, support, sales, and payment processing.
Information received by the Company may also be shared with our counterparts whose services are used to improve the user experience and for the purposes described herein above, depending on the vendor.
If you decide to use, while using our applications, such social media features as “like”, this will automatically enable data sharing between us and the relevant social platform.
We work with the following service providers:
- Google Analytics
- Google Firebase
- Google Ads
- Google Marketing Platform
- Google Cloud
At the same time, we may disclose user’s data to third parties, including any governmental agencies, if we are confident that this information is required for the following purposes:
- legitimate demand / request of a governmental agency (e.g. in court proceedings);
- revealing, investigation and/or prevention of fraud by users or any third parties;
- safeguarding of rights, property and/or security of the Company to the extent permitted by law;
Technical, administration and other data protection means
To ensure the secure storage of your personal data, we have implemented a number of technical and administration tools that protect personal data against any unauthorised or unlawful processing and against any unintentional data loss, destruction or damage.
When we share any data with our partners, we always use the most safe and secure data communication channels.
In compliance with the GDPR, the Company provides relevant protection for data disclosure to countries outside the European Economic Area or Switzerland based on standard terms and conditions approved by the European Commission, or any other applicable provisions referred to in Article 46 of the GDPR.
However, we cannot guarantee the security of your data in case of any unauthorized access to your devices that are outside of your control, and, accordingly, the Company will not be liable for this.
Duration of data processing / storage
We will not keep your data longer that is necessary to achieve the purpose for which it is collected and processed, or to comply with regulatory requirements.
In order to identify the relevant storage period, we identify the nature and category of the personal data, purposes of processing, and whether we can hit those purposes otherwise.
In particular, if regulations of the country where our application / service user resides contains the limitation of action provisions defining the period during which you may file your claim or complaint against us, and we, accordingly, need relevant proof of legal relations with you, we may process your personal data during this limitation of action period.
We also need to consider any periods when we might need to keep your personal data for complying with our legal commitments to you or supervisory authorities.
Over time, we might minimize the personal data that we use, or can even make them anonymous so that they are no longer related to you personally. In this case, we can use this information without further notice as it no longer contains any personal data.
Cookies and other tracking technologies
Cookies are small text files that are placed on your device such as computer or mobile device by websites that you visit. The website will, for a certain period of time, remember your preferences and actions, so that you will not have to set them up again. Our cookies do not identify a specific user and only identify the device that is being used.
Rights of personal data subjects under the GDPR
Please be advised that when you contact us you have through the identification process and submit your specific requirements, so that we can process your request and provide a response on legitimate grounds. List of data that we must provide to you is contained in Article 13 and Article 14 of the GDPR.
Please note that where we cannot identify you through messaging or your request to the support service, or if we have reasonable suspicions about your identity, we may request you to provide your ID. Only this way we can avoid disclosing your personal data with an individual claiming they are you.
We process requests as quickly as possible, but at the same time we ask you to remember that providing a complete and legitimate response regarding personal data is a complex process that may take up to a month or even longer. If we need more time to prepare a complete response, we will let you know.
The GDPR has secured the following additional rights of data subjects to safeguard their personal data.
The right to be informed
We are ready to provide data subjects with information about what personal data we process. If you want to know what personal data we process, you can request this information at any time, including by contacting the Company’s data protection officer.
The right to restrict processing
You may request to restrict your data processing so that only we can keep it. This means demanding that we terminate any of your data processing, other than storage under certain circumstances.
Revocation of data processing consent and the right to erasure
If we process your personal data under the processing consent (specifically, with the purpose of marketing mailings), any subsequent processing may be terminated at any time. It only takes to revoke your consent to such processing.
You may also exercise your right to erasure. In cases referred to in Article 14 of the GDPR, the Company will delete the personal data being processed, other that the data that we are obliged to keep under applicable law.
If you are a parent of a child under 13 (or any other age established by applicable law), and you believe that your child disclosed any information to us without your consent, please notify us immediately and we will remove this information.
Your requests related to data protection and processing
We have designated a data protection officer (DPO) who is a single point of contact for any questions or comments regarding your data protection and processing. You may contact DPO at: email@example.com
Platforms and Games:
Apple Store Games: https://apps.apple.com/us/developer/vidloonnya-reborn/id1648708380
Google Play Games: https://play.google.com/store/apps/dev?id=7298138477933561187