PRIVACY NOTICE

Last update: September 14, 2021

Dear User, we, VIZOR APPS LTD., respect your privacy and therefore appreciate your trust and confidence in us.

This Privacy Notice explains what information comprising personal data is collected, how we collect and process your personal data, how it is used and how we protect your personal data when you use the entertainment software program “Klondike Adventures” (“the Game”) that is licensed to you by VIZOR APPS LTD. (“the Licensor”). Depending on the applicable jurisdiction, you will also have an opportunity to get acquainted with your rights in relation to your personal data as set forth herein below.

Below you can find out the full version of this Privacy Notice, the text of which has legal force, and the version in plain language, which is not legally binding, but serves as a quick summary of the full version. Please read it carefully, because it is important for you to understand what we do with your information and how you can control it.

For what purposes do we process your personal data?

We process your personal data in order to provide you with our services connected to the Game, as well as to contact you as set forth below.

We also process your personal data to collect Game analytics. For more information, please, check “Analytics” section.

In addition we process your personal data to collect Game statistics, which we use for further development of the Game. Such data helps us to develop new features and add them to the Game, fix Game errors, as well as analyze users’ interests and needs, technical issues of Game functioning, etc. Processing personal data for collecting and analyzing statistics helps us make your Game experience more personal and smooth.

Also we process your personal data to provide you with advertisements, which have been tailored to meet your interests with the help of our partners. For more information, please, check “Advertising” section.

We do NOT process your personal data in order to sell it.

In any case we may process your personal data, if we are obliged to do so by applicable laws. We may also process your personal data in case we are entitled to do so by the applicable data protection laws without obtaining your consent.

On what legal basis do we process your personal data?

We process your personal data basing on the following grounds:

on the basis of performance of contract’s obligations: this means that we have to process your personal data in order to fulfill our obligations under the agreement with you, e.g., inter alia, provide you with the access to the Game, the services connected to the Game;
on the basis of your consent to such processing: this means that we process your personal data based on your consent in order to ensure the security and improvement of our services, to ensure the security of transactions within the Game, etc.
on the basis of the legitimate interest: the so-called “legitimate interest” means lawful purposes that could be reasonably expected (like informing you about the Game and Game’s services and making sure our marketing is relevant for you, protecting the security of our websites and systems, conducting anti-cheat analysis and anti-fraud checks); when we rely on the legitimate interest, we consider and balance any potential impact on you and your rights;
on the basis of applicable law: this means that we have to process your personal data in order to fulfill the applicable law’s requirements (e.g. our obligation to keep certain records under tax laws).

What data do we process?

№	What data do we process?	On what legal basis do we process your personal data?	For what purposes do we process your personal data?
1	your Game ID (identification number)	performance of contract’s obligations	to keep your data separate from the data of any other user. The applicable system provides you with a Game ID automatically when you install the Game on your device. The Game ID is a randomly assigned set of symbols, which is not connected to any data that may identify you. Each time you delete the Game and re-install it, you are assigned a new Game ID
2	your platform ID (identification number), such as Google Play Services ID	performance of contract’s obligations	we use these data for synchronization (if you play the Game on different devices) and data recovery
3	your location data. These data contain information about your IP address, state and city of your location	performance of contract’s obligations	we process these data in order to adjust Game language and currency settings for you. The Game does not have geographic location tracking, we do not monitor your movement
		on the basis of your consent to such processing	such data may be used for advertising purpose (for more information, please check “Advertising” section)
		on the basis of legitimate interest	such data may be used for analytics purpose (for more information, please check “Analytics” section)
4	your device information. These data include the operation system of your device and the version of the Game you use, your device ID (identification number), device language, brand and model of your device	performance of contract’s obligations	by processing this information we check whether the Game on your device needs updating and what version do you need, in case update is required
		on the basis of your consent to such processing	such data may also be used for advertising purpose (for more information, please, check “Advertising” section)
		on the basis of legitimate interest	such data may be used for analytics purpose (for more information, please check “Analytics” section)
5	information about your in-game purchases,	performance of contract’s obligations	we process the data such as a payment identification number, the type and amount of a product, as well as the price in your local currency, in order to adjust payment and currency settings. We never collect or process any payment information, such as bank card number, its validity term, your name as written on a bank card, etc.
6	information about in-game events	performance of contract’s obligations	we process the data such as your achievements within the Game, completed Game levels and actions taken within the Game in order to provide you the appropriate access to the Game events and activities
7	information you provide to us when addressing our help&support team or communicate with us through our official communities in social networks	performance of contract’s obligations	we process such data in order to response your submissions and provide you with feedbacks
8	information about your network provider, browser type, language, the version of the Game, your mobile advertising identifiers (such as your Google AAID), device IP address and network connection type	on the basis of your consent to such processing	we may process this information with the help of our partners in order to provide you with advertisements, which have been chosen to meet your needs and interests, and analytics (for more information, please, check “Advertising” section)
8		on the basis of legitimate interest	such data may be used for analytics purpose (for more information, please check “Analytics” section)

Finally, we may process information about you, which is made available to us by any of our partners, provided that such partner is entitled to share such information with us.

Do we provide third parties with your personal data?

Yes. For the purposes of analytics and advertising, we use services and solutions provided by third parties. Such parties process these data on our behalf and the respective technical solutions represent a part of the Game. Any transfer of your personal data to any of our partners is made, provided that such third parties comply with applicable personal data protection laws, including, but not limited to, General Data Protection Regulation 2016/679, California Consumer Privacy Act of 2018. Any transfer of your personal data to a third party is based on an agreement with such third party, and we make sure such a third party complies with the applicable data protection regulations, unless we are entitled by applicable data protection laws to transfer personal data without a written agreement (for example, if you have given you consent to such third party to obtain your personal data from us).

In certain cases we may transfer information about you to other third parties (for example, independent personal data controllers), if we are obliged or allowed to do so by applicable laws. If it is the case, we transfer such information while adhering to applicable personal data protection laws, including, but not limited to, General Data Protection Regulation 2016/679, California Consumer Privacy Act of 2018.

How long do we process your personal data?

We process all the data we collect for as long as you use the Game and 30 months after you stop using the Game. If you do not use the Game for 30 continuous months, we erase your personal data from our data base, as well as request the same erasure from any third parties whom your data may have been transferred to. We may erase your personal data earlier if we do not need to process such data anymore.

Do we process any personal data of children?

We do not use the Game to knowingly solicit data from or market to children under the age of 16. If you believe that we process personal data of a child below 16 years old, please, contact us and we will make all reasonable efforts to stop processing such data and erase it as soon as possible.

What rights do you have with regard to your personal data?

You enjoy the rights provided to you by the Legislation and other applicable legislative acts having transborder effect. Under the applicable data protection regulation, if you are a citizen of the EU and fall within the scope of a data subject, you are entitled to the following rights: right of access, right to rectification (correction), right to erasure (deletion), right to object, right to withdraw consent, right to data portability, right to restriction of processing.

Right of access

You have the right to access your personal data, which we process. In order to access your personal data, please, send us a message describing your request through our help&support service within the Game.

Right of rectification (correction)

You have the right to ask us to replace any inaccurate data about you with accurate data. If you think that the data we process are incomplete for the purpose of processing as stated in this Privacy Policy, you may ask us to complete your personal data accordingly. In order to have your personal data rectified, please, send us a message describing your request through our help&support service within the Game.

Right to erasure (deletion)

You have the right to ask us to completely delete your personal data. In order to have your personal data erased (deleted), please, send us a message describing your request through our help&support service within the Game. Please, be informed that we will not erase your Game ID, as we need to keep it for our internal records. However, we will erase all data that may help us identify you; therefore, your Game ID will not be considered personal data anymore.

Right to object

You have the right to object to processing of your personal data for the purpose of direct marketing. In order to do so, please, adjust the privacy settings of your device: resent Advertising Identifier on iOS by opening “Settings”, then tapping “Confidentiality”, then “Advertisements”, then enable the “Reset Advertising Identifier” option.

Right to withdraw consent

You have the right to withdraw your consent for personal data processing. Any withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. In order to withdraw your consent, please, send us a message describing your request through our help&support service within the Game.

Right to data portability

You have the right to ask us to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. In order to have your personal data transferred to you, please, send us a message describing your request through our help&support service within the Game.

Right to restriction of processing

Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679. In order to restrict processing of your personal data, please, send us a message describing your request and stating the basis of restriction through our help&support service within the Game.

California State Residents Rights

This clause of the Privacy Notice specifies your rights regarding our use of your personal data under the California Consumer Privacy Act of 2018 (hereinafter the “CCPA”) and other California privacy laws. This clause applies only to persons who reside in the State of California, USA.

If you are a resident of State California, USA, you are entitled to the following rights: the right to know what personal information is being collected about you; the right to know whether your personal information is sold or disclosed and to whom; the right to say no to the sale of personal information; the right to access your personal information; the right of equal service and price, even if you exercise your privacy rights.

Also, being a resident of state California, USA, you have the following rights:

to request deletion any personal information about you;
to request disclosure of the categories and specific pieces of personal information that we have collected about you;
to request disclosure to you the following: the categories of personal information we have collected about you; the categories of sources from which the personal information have been collected; the business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information; the specific pieces of personal information we have collected about you; the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.

We shall not discriminate against you because you exercised any of the state California, USA, consumer rights, including, but not limited to, by:

denying goods or services to the consumer;
charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
providing a different level or quality of goods or services to the consumer;

suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

We do not sale your personal data, and therefore are not required to provide an opt-out process under the CCPA.

If you have any concerns regarding your privacy, you can exercise the abovementioned rights by contacting us at [email protected] or via help&support service within the Game (please see the below).

ATTENTION

Please, note that after deletion of your personal data all your in-game achievements (including in-game goods) may be still available to you in incognito mode. Full deletion of your personal data (including your in-game achievements) may be performed on separate request. Deletion of personal data is irreversible. You will not have a chance of restoring your personal data.

We also draw your attention to the fact that processing your personal data (except for data that we use together with our partners to serve advertisements to you) is necessary to provide you with the Game and services that are connected to the Game. If you choose to withdraw your consent, you may have to stop using the Game.

How can you send us a message through our help&support service within the Game?

In case you want to submit a request and exercise any of your rights stated above, please, follow these instructions:

go to in-game Settings menu and tap Help and Support;
tap Contact Us button (a texting cloud) in the upper right corner;
write your request and submit it.

It is important that you submit your requests using our help&support service within the Game. Obtaining a request sent directly from within the Game makes us sure that such a request comes from the user.

Advertising

We show advertisements in our Game with the help of third-party advertising partners. We integrate their technologies into our Game, which are then used by our partners to select the advertisements that meet your interests in the best way. Processing data for advertising purposes is based on your consent to such processing. If you do not want to receive targeted advertisements, please, adjust settings of your device.

You can learn about our partners' terms and conditions of personal data use at the following links:

AdColony, Inc.: https://www.adcolony.com/privacy-policy/https://www.adcolony.com/privacy-policy/

AppLovin: https://www.applovin.com/privacy/

Chartboost: https://answers.chartboost.com/en-us/articles/200780269

Facebook: https://www.facebook.com/full_data_use_policy

Google: https://policies.google.com/privacy?hl=en&gl=US

HyprMX: https://www.hyprmx.com/pp

ironSource: http://www.ironsrc.com/wp-content/uploads/2017/01/ironSource-Privacy-Policy.pdf

Mopub: https://www.mopub.com/legal/privacy/

TapJoy, Inc.: https://www.tapjoy.com/legal/#

Unity Technologies: https://unity3d.com/legal/privacy-policy

Vungle: http://vungle.com/privacy/

Analytics

In order to analyze various aspects of Game functioning, we need to collect and process certain information with regard to your interaction with the Game. Such information includes your location data, information about your device and advertising data. It may also comprise information about errors of the Game functioning. For this purpose we use technologies and solutions provided by third parties – our analytical partners. We integrate such technologies into the Game and our partners process the data on our behalf to provide us with analytics.

You can learn about our partners' terms and conditions of personal data use at the following links:

Apple privacy policy: https://www.apple.com/legal/privacy/

Google privacy policy: https://policies.google.com/privacy

Amazon privacy policy: https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ

Processing data for analytical purposes is based on a legitimate interest of the Licensor – analyzing data about the Game for commercial purposes. Analytics helps us to provide better services to users, update and develop our Game. For example, we may use such information in order to fix Game errors, evaluate demographic composition of our users, determine what features to add to the Game or whether we need to translate the Game into another language.

In case you have any questions with regard to this Privacy Notice, please, contact us via email at [email protected] or via regular post at the address stated below, and we will get back to you as soon as practically possible. Should you send us a request with regard to exercising any of your rights stated in unit 8 of this Privacy Notice (“What rights do you have with regard to your personal data?”), we will ask you to re-send the request using our help&support service within the Game. Please note that for the exercise of some of your data subject rights, we might be requested by law to verify your identity.

The controller of your personal data is VIZOR APPS LTD., a company duly incorporated in the Republic of Cyprus at the address: Archiepiskopou Makariou III, 169, CEDAR OASIS TOWER, Flat/Office 301, Lemesos, 3027, Limassol, Cyprus.