This Application collects some Personal Data from its Users.
Owner and Data Controller
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Contacts permission; Camera permission; Microphone permission; Social media accounts permission; Approximate location permission (continuous); Cookies; Usage Data; email address; password; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Device permissions for Personal Data access, Analytics, Registration and authentication, Access to third-party accounts, Registration and authentication provided directly by this Application and Advertising.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Provides access to the User’s primary email address.
Device permissions for Personal Data access
Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Approximate location permission (continuous)
Used for accessing the User’s approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Used for accessing the camera or capturing images and video from the device.
Used for accessing contacts and profiles on the User’s device, including the changing of entries.
Allows accessing and recording microphone audio from the User’s device.
Social media accounts permission
Used for accessing the User’s social media account profiles, such as Facebook and Twitter.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.
In order to understand Google’s use of Data, consult Google’s partner policy.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Cookies; Usage Data.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User’s device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Camera permission; Contacts permission; Microphone permission; Social media accounts permission.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User’s browser.
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
What This Policy Contains
I. Information Collection and Use: Personally Identifiable Information
II. Legal Bases for Use of Your Personal Information
III. Information Sharing and Disclosure
IV. How Long We Store Your Information
V. Your Rights
VII. International Transfer
VIII. Our Policy Towards Children
X. Links to Other Sites
XII. Contacting Us
I. Information Collection and Use: Personally Identifiable Information
Information That You Provide
As you use the Services, you may provide us with personally identifiable information. This refers to information about you that can be used to identify, track, or contact you (“Personal Information”). Personal Information includes data such as your name and email address, but is not limited to this information. When you contact our customer support services, this may include a record of communication correspondence and associated contact information.
Where applicable, you may sign up to use the Services directly via the Site or Application or via certain third party social networking sites (each, a “Social Networking Site”). If you decide to create an account to use the Services via a Social Networking Site, we may extract the personal information you have provided to such Social Networking Site (such as your “real” name, email address and other information you make available via the Social Networking Site) from the account you have with such Social Networking Site and use that information to create your Violeta Dzhendova account, or an account for aVioleta Dzhendova application, website, or property; the information we extract may depend on the privacy settings you have with the Social Networking Site.
If you choose to purchase any virtual goods as part of your use of the Services, to the extent available, we or our third party service providers may collect Personal Information from you to facilitate your payment for such virtual goods.
We also collect other information that you provide in connection with your registration and/or use of the Services (e.g., without limitation, birthday, gender, zip code (on its own), individual preferences and certain information about your computer or mobile device, such as operating system, software version and unique advertising identifier) (“Non-Identifying Information”).
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).
With your permission, we access information from your device, such as your general location, contact lists, photo library, and calendar. If you choose to give us access, you may also link your use of the Services with your cloud storage accounts.
Information We Collect Automatically
Our products may require additional information or permissions from your device in order to function effectively.
Log Data. When you use the Services, whether as a registered user or a non-registered user, for example in accessing our Services through a Social Networking Site, (any of these, a “Violeta Dzhendova”), our servers automatically record information that your browser sends whenever you visit a website or application (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the website or application you were visiting before you came to the Service, pages of the websites or applications involved in the Service that you visit, the time spent on those pages, information you search for, access times and dates, operating system, software version, unique advertising identifier, and other statistics. We use this information to monitor and analyze use of the Services and for the Service’s technical administration, to increase the functionality and user-friendliness of our Services, and to better tailor the Services to our visitors’ needs. For example, some of this information is collected so that when you use our Services again, it will recognize you and serve advertisements and other information appropriate to your interests, as described in more detail below. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Cookies. Like many websites and applications, our Service uses “cookies” and mobile advertising identifiers to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We do not link the information we store in cookies to any Personal Information you submit while using our Services. An advertising identifier is an anonymous, resettable ID associated with your mobile device that can be managed in your device settings.
How We Use Your Personal Information:
We may use your Personal Information to provide products and services and to support our business functions. For example, we may use this information for the following purposes:
Provide, Improve, and Develop the Services.
- Provide the Services to you
- Recognize you when you return to our Services, keep your game progress, save your registration ID and login password for future logins, and store information about your use of the Services
- Display your achievements on leader boards within the relevant Application (which will include your basic social media profile information if you choose to link your social media accounts with the Services)
- Provide customer service
- Operate, protect, improve, and optimize the Services and the user experience, such as by performing analytics and conducting research
- Communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our products, services, contests, support messages, updates, security alerts, and account notifications. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your “user preferences” information. (See “Your Rights,” below.)
- Make your user experience easier, more personalized, more enjoyable and more efficient
- Address problems with and improve our products, brands, services and technologies, as well as to develop new products and services
- Enable certain features of the Services in order to better understand how you interact with the Services and to monitor aggregate usage.
- Facilitate your ability to share information to social media
- Administer and fulfill our contests and other promotions
- Help us learn more about your product preferences
- Send you push notifications with app-related information when you give us permission
- Fulfill your purchase requests and process refunds
- Fulfill a contract we have with you
- Operate, protect, improve, and optimize the Services and experience, and personalize and customize your experience. We conduct profiling based on your interactions with the Services.
We process this information given our legitimate interest in improving the Services and our users’ experience, and where it is necessary, for the adequate performance of the contract with you.
Create and Maintain a Trusted and Safe Environment.
Legal Bases for Use of Your Personal Information
- Our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Service);
- Or you have provided us with your consent to do so, including with respect to the advertising and marketing materials delivered via our Services that are tailored to you and your preferences.
Aggregate Information and Non-Identifying Information; Advertisers. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes.
In particular, we share Non-Identifying Information (including the advertising identifier currently associated with your device) and Log Data and other aggregated information with third party advertising and technology companies. The data we share with them includes data about your device, location, and use of our Applications, including IP address, device identifiers and information, Application usage data, and purchase data as well as information you provide to us when using our Applications such as game progress and certain technical information. Such information may be used to send you targeted advertisements for products and services that are relevant to your interests. In some cases these third parties will also use the data that they collect for their own purposes, such as aggregating your data with other data they hold in order to inform advertising related services provided to other clients. These third parties may place a cookie on your browser, or use a web beacon, to collect information about your use of our website so that they can provide advertising about products and services tailored to your interest. That advertising may appear across the Services, or on other websites, apps and services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. On mobile you can reset your settings by taking the following steps (for iOS: https://support.apple.com/en-us/HT202074 and for Android: https://support.google.com/ads/answer/2662922?hl=en). If you do not accept cookies, however, you may not be able to use all portions of the website or all functionality of our Services, and advertising will no longer be targeted to your interests.
A list of the third party advertising and technology companies that we use is set forth below:
We may employ third party companies and individuals to facilitate our services, to provide our services on our behalf, to perform services related to our Services (e.g., without limitation, analytics and reporting services, database & hosting services, distribution platforms, and other web or app service providers) or to assist us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Service providers with whom we share your personal information include:
Web, App and Game Distribution, Payments and Operating System platforms, including, but not limited, to Apple Inc., Google LLC, Amazon.com, Inc. Facebook, Inc., Bemobi International AS, and Microsoft Corporation;
- Analytics Service Providers, including, but not limited, to Flurry, Inc., Periscope, Inc., Appfigures, Inc., Google LLC (operating as Fabric, Firebase, Google Analytics), and Game Analytics;
Web, App or Game Software, Hosting and Database Service Providers, including, but not limited, to OneSignal, Inc., Amazon.com, LLC (Amazon Web Services), Globotech Communications, and GOTOANDPLAY S.N.C.; and
- Customer Support Platforms, including, but not limited, to Zendesk, Inc., Helpshift, Inc., and Salesforce, Inc. (Operating as Desk.com).
How Long We Store Your Information
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
concerned with safeguarding your information. We employ reasonable administrative, physical and electronic measures designed to help protect your information from unauthorized access. No security, however, can eliminate the possibility that your information may be accessed by an unauthorized third party and we cannot guarantee that your information will remain secure in all situations.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email, mail, telephone, or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. We reserve the right to choose which method we use to contact you about such an event.
Our Policy Toward Children
These Services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.
Links to Other Sites
Our Services may provide links to other websites and applications. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.