Valid from the 2st of February 2021
We are GEAR GAMES LLC (“Gear Games, LTD”, “Gear Games”, “Company”, “We”), established and acting under the laws of the Russian Federation.
We are grateful to you for playing our games!
We respect Users of our applications, services, and visitors to our website. The privacy and security of our Users are of paramount importance to us, and we comply with provisions of applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Federal Law of the Russian Federation "On Personal Data."
The present Privacy Policy ("Policy") applies to our games, websites, and related services ("Services"). The Policy is complemented and should be considered in conjunction with the License Agreement.
For the purposes of the present Policy, we define the term the "User" ("You") as a natural person with whom we have established relations and who has accepted our License Agreement.
The policy determines how and what data about you we collect and process when you use our Services, how such information is protected, and what rights you have regarding this information.
In accordance with the General Data Protection Regulation (GDPR) and other data protection laws in the member states of the European Union, Gear Games is the Data Controller in regards to our Services.
We classify as "Data about you" (personal data, information about the User) any data that can identify you personally or are indirectly related to you and by which you can be identified.
By "Processing" information, we mean any action (operation) or a set of actions (operations) carried out with personal data using automation tools or without using such tools, including collection, recording, structuring, sorting, accumulation, storage, adaptation, or modification, downloading, viewing, analyzing, disclosing by transmission, distributing or otherwise providing access, matching or combining, reducing, deleting or destroying.
Anonymous or anonymized information that we cannot associate with your person is not classified by us as personal data.
In providing the Services, we, acting reasonably and in good faith, believe that you:
We do not verify the information received from you about the Users unless such verification is necessary to implement our obligations.
The company collects and processes only those personal data that are necessary to implement obligations under the License Agreement concluded with you and in order to ameliorate the quality of our Services.
To use our Services, there's no need to provide us with information about your name and surname, residency or place of stay, telephone number, or e-mail address. We do not request or process your financial information and information about bank accounts, bank cards, and their holders.
The information necessary to make purchases in our Services is provided by you to the payment service provider using secure protocols in accordance with its established procedure. If you pay in a mobile application, then this information is collected and stored by the platform you use (for example, Apple Store or Google Play) or the platform's payment service provider.
Under no circumstances we collect and process a special category of personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs, membership in any public organizations, genetic and biometric data, data on health conditions, criminal records and offenses, and other intimate information about a natural person.
We will process your personal data on the basis of your consent and provide you with all the information necessary to make a voluntary decision to grant or refuse consent.
When registering, you automatically provide us with identificators of service providers: Google Play, App Store, and other platforms on which our Services are hosted. This information is used by the Company to identify the User, provide him/her with support, services, mailing, marketing campaigns, and can be transferred to our partners.
You can use our Services without an authorized Google Play and App Store account only in a restricted mode since we will not be able to synchronize data between your different devices and will not create a save file. In this case, your profile and saved data will be associated with your device ID.
When you contact us or report problems using our Services, issue any content, or provide any other information, we may process all of that information. This information may include:
Information that Users can share using the chat function or forums may contain personal data.
We do not encourage or ask Users to share such information, but we cannot prevent it. The user who has shared his/her data via chat or forum is fully responsible for such actions.
In all cases, you can always contact us and request to delete your data from any Services controlled by us.
The browser or the Client part of our Services may collect and transmit certain information about Users, including:
For our Services to function properly, we or our partners may use cookies. Cookies are small pieces of textual information stored in memory, which is generated automatically and stored on your device to associate and identify User activity. Cookies do not contain personal information.
Cookies or similar technologies stored on your device through which you use our Services carry out the following functions:
In order to refuse to transmit any information using cookies or other tracking technologies, you can actively manage the settings of your browser or mobile device. Please see the technical information of your browser or mobile device to get instructions on how to remove and disable cookies and other similar tools.
We may collect information from third parties for our legitimate purposes in addition to the information provided by you and collected by us automatically. For example:
We also process information that does not directly or indirectly link to a specific natural person and cannot be used to identify him/her.
Such information may include a summary or generalized information about the actions and achievements in the Services, visiting hours of the Services, the duration of their use, and other similar information.
We may use a third-party analytics provider to help us collect and manage this data. We use this information to provide the Services and improve them.
By using our Services, you consent to the collection and processing of anonymous or impersonal information.
We collect and process your information to deliver services per the License Agreement, with your consent, in the legitimate interests of our company, as well as for other legitimate reasons.
The main purpose of collecting and processing information about you is to ensure that our Services are delivered and the quality is improved.
We collect and process your data and impersonal data to:
You can optimize or disable notifications about various events and advertisements in the settings of our Services.
The legal ground to process data (for Users from the European Union).
Our legal ground for processing your data will depend on the purpose for which We use your data. In general, We will rely on the following legal bases to process your data:
To achieve the purposes prescribed by the present Policy and the License Agreement, We сan share your data with third parties. These may include the following categories of beneficiaries:
Also, We may disclose the information collected and processed in the event of a reorganization, merger, sale, the formation of a joint venture, disposal, transfer, or another disposal, in whole or in part, of Gear Games and/or our assets.
To deliver the services of our Services and following the License Agreement, the above data may be processed and stored wherever we or our partners carry out their activities, including outside the European Union and the European Economic Area.
To store and process your data, We currently use the services of our partners Selectel and DigitalOcean.
By using our Services, you authorize the transfer of personal data in the quantities indicated above outside of your country of residence and acknowledge that your data may be transferred to other countries, each of which may have privacy rules that differ from those applicable in your country of residence.
Regardless of where exactly your data is processed, the Company uses the same security measures described in the present Policy, inter alia, by including special conditions in contracts with our partners.
To meet the objectives described in the present Policy and License Agreement, we are currently working with the companies listed below. Also, when using our Services, Users can click on links to other sites and/or software applications that are beyond our control.
Gear Games only works with competent and reliable partners, but we cannot be responsible for the content or privacy policies of our partners.
For information on how third parties may use your information, please see their privacy policies.
Google (https://policies.google.com/privacy)
Facebook (https://www.facebook.com/about/privacy/)
Tapjoy (http://info.tapjoy.com/about-tapjoy/privacy-policy/)
DevToDev (https://www.devtodev.com/policy)
IronSource Ltd (https://www.ironsrc.com/ru/)
AppMetrica (https://yandex.com/legal/privacy/)
Unity (https://unity3d.com/ru/legal/privacy-policy)
Gear Games will not maintain data more than needed to achieve the purposes for which it was collected or as required by applicable legislation or regulation.
We may periodically identify unused accounts, and we regularly check and delete unused and unnecessary data.
To the specified data, we refer to the User's data that is not used for 1 (one) year since the last use of the Service.
Please note that if you ask us to delete your data following the procedure described in the “Your rights” section, we may retain it as necessary to protect our legitimate business interests, for example, to comply with our obligations, settle disputes, and enforce compliance with our agreements.
To provide security when using our Services, we use and implement organizational, administrative, legal, technical, and physical measures to protect your data from unauthorized access, fraudulent use, distribution, and other threats to information security.
For example, to store information, We use computer systems with limited access in controlled areas. We also use encoding and encryption technologies to protect some of the information we collect.
Also, we take all the necessary measures per the Federal Law of the Russian Federation of July 27, 2006, No. 152-FL "On Personal Data" (Appendix 1. Additional Provisions - Russia).
Currently, you can download our games on Google Play and App Store, and valid links can be found on our website.
Any other download sources are invalid, and we cannot guarantee your safety when you receive services from other sources.
Since our Services are intended for capable Users (as understood by applicable legislation), we do not purposefully collect or use "Personal information" (as defined in the Children's Online Privacy Protection Act (COPPA)) obtained from anyone under the age of 13.
If you are under 13 (or under 16, depending on the country you are in), please do not use our services or ask your parents (or their authorized representatives) to consent to your use of our services.
We respect the privacy rights of parents and children, and we are committed to complying with the provisions of COPPA. If you are a parent (a person exercising parental authority) and you believe that we have collected your child's data in violation of the law, please let us know in any way convenient for you following the "Appeals" section of the Policy. We will delete this data per applicable law.
You have certain rights regarding your personal data. There is a brief overview of these rights below, their use, and probable restrictions.
You can send us a request to provide information about your personal data that we process, under section "Appeals". Carrying out of your requests may be limited in some cases, for example, when your request concerns the disclosure of information about another person, or if you ask to delete information that we are entitled to process in accordance with the provisions of the law, regardless of your consent.
You have the right to access your personal data, object to our use of your information (including for marketing purposes), request the deletion or restriction of your information, or request your data in a structured format.
Right to delete data. You have the right to entrust us to completely or partially delete your personal data. In addition, in some of our Services, you can independently use the "Reset Account" function, and thus delete your personal data. If you delete your account, you will permanently lose progress, experience, upgrades, and all digital content on the Services.
Right to object to data processing. You can exercise your right to object to the processing of your data. If you refuse to process your data, we will no longer process your personal data unless there are strong and prevailing legal grounds for processing and if the data is not used to protect our legitimate rights and interests.
You can withhold your consent to the processing of data by contacting us by the section "Appeals". If you revoke your consent, this will not affect the legality of the processing based on your consent before its withdrawal.
Refusal to direct marketing. You can turn off push notifications in our Services by visiting the appropriate section of the settings. To reject receiving interest-based advertising on mobile applications, please check the privacy settings of your Android or iOS device and select "Restrict ad tracking" (Apple iOS) or "Restrict interest-based advertising" (Android).
You can also refuse to receive our information for marketing purposes by contacting us following the "Contact" section.
You have the right to make a complaint with a supervisory body.
Right to data migration. You have the right and the opportunity to get some of your personal data in a format that you can relocate from one service provider to another, from our Services to other software products. Depending on the context, this applies to some, but not all of your data.
The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to obtain information, delete data, and refuse to proceed data and requires companies to collect or disclose data to submit notifications and opportunities to exercise rights.
Over the past 12 months, we have collected data from the following categories mentioned in the CCPA:
You also have the right to have your data deleted.
To exercise any of the mentioned rights, send a request by email: [email protected] In the request, please indicate: the Service you use, your name or nickname, what right you want to exercise, and to what extent. Within 10 days, We confirm that your request is received. We may solicit specific information to help us verify your identity and process your request.
However, we inform you well in advance that in the above case you will have to tell us more information about you than we had before.
You can appoint an accredited representative to send inquiries on your behalf. However, for this, we need written confirmation of the representative's authority and immediate verification of your identity.
You have the right not to be discriminated against by us for the exercise of any of your rights.
Our Services' users who are California residents may request (i) a list of their data's categories that we disclosed to third parties during the preceding calendar year for marketing purposes; and (ii) a list of the categories of third parties to whom we have disclosed such data.
The request may be submitted to the following contacts (email or mailing address), indicating that it is being carried out in accordance with the California Shine the Light Act. Please note that we have an obligation to respond to such inquiries only once per calendar year.
If you are a user of our Services, and you are a California resident under the age of 18, you can ask us to remove any content or information that you post on our Services. Please submit a request specifying the information you want to remove to our email address: [email protected] with the subject line "California Under 18 Content Removal Request". We will make all reasonable attempts to remove posted information from the relevant public domain. However, we cannot ensure the content to be completely removed, and it may retain the content necessary to comply with our legal obligations, resolve disputes, and for the enforcement of our agreements.
You may have other rights under the laws of your country of residence or where you are a resident.
We assume that our Services' Users have carefully read this document and agree with its content. If you disagree with the present Policy, please refrain from using our Services.
We will make the needed improvements and additions to our Privacy Policy in case of changes in legislation and as necessary.
Changes to the Policy will be posted on this page and, if the changes are essential, we will give you notice using our existing communication means in our Services.
We will keep previous versions of the present Privacy Policy in our documentation archive.
If you continue to use the Services after you have been informed of any such changes, it constitutes acceptance of the present Policy.
Gear Games is the data controller and is responsible for privacy and personal data protection issues.
When addressing us on a matter that concerns the exercise of your rights, per the rules of the existing legislation, we may require additional information for fulfilling a request or implement an instruction. In most cases, we will fulfill your request or mandate within one calendar month, if all the required information is available on your part.
By the existing legislation, users from the Russian Federation are provided with information about the processed personal data on the grounds of a written request (request) sent to the postal address indicated below. In the appeal, it is necessary to indicate the number of the basic identity document of the subject of personal data or his representative, information about the date of issue of the specified document and the issuing authority, the name or nickname of the User, the signature of the subject of personal data or his representative, and other information necessary for identification. The appeal can be sent in the form of an electronic document and signed with an electronic signature following the legislation of the Russian Federation.
If we are not able to fully satisfy your request or fulfill the mandate within a calendar month (due to the complexity or the number of requests), we can extend this period for another two calendar months, if this is not at variance with the existing legislation. If an extension is necessary, we will explain the reasons for the delay. If you make your request electronically, we will provide you with the information electronically, unless you request otherwise.
If you have any questions regarding the present Policy, mandates on how to process your data, or requests to resolve problems related to personal data, please contact us in a convenient way for you:
Data Controller - GEAR GAMES LLC
Email address: [email protected]
Phone number: 8 (495) 673 30 97
Postal address: 111024, Moscow, st. Enthusiasts 2nd, 3, office 415