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Privacy policy

Effective from October 11, 2021

This Privacy Policy (hereinafter –the “Policy”) describes how and when GOSU Data Lab UAB (hereinafter –“GOSU”, “we”, “us”, “our”), its subsidiaries and affiliated companies collect and utilize the information pertaining to your use of our services. By giving your consent in the consent forms provided in our Games or by using our Website (hereinafter collectively –“the Services”), you (hereinafter –the “User”) consent to this Policy.

As GOSU is established under the laws of the Republic of Lithuania, this Policy is in compliance with the General Data Protection Regulation (EU) 2016/679 (hereinafter –the “GDPR”), according to which we are the data controller.

We reserve the right to amend this Policy. Amendments will be effective from the moment of their publication, so please check regularly to be sure you are familiar with the latest version. If we decide to amend this Policy, we will post those changes on this page.

DEFINITIONS:

  •  “Advertising ID”shall mean the resettable and unique identifier associated with your Device that is used by advertisers for ad tracking (IDFA for iOS Devices or GAID for Android Devices). Some of the advertising IDs, for example, IDFA, may not be processed automatically. As such, you may consent to or limit their processing in the settings of your Device. For more information, please refer to the manufacturer of your Device.
  • Data Protection Laws”shall mean the laws applicable to the processing of the Users’personal data by GOSU in the relevant jurisdictions or according to the nationality of the Users or the territory they reside in.  
  • Device”shall mean the device you are using to use our Services.
  • Device Information”shall mean technical information about your Device. When we refer to Device Information, this means your Device ID, your Device’s IP address, Unique Device Identifier (UDID) and Open Device Identification Number (ODIN), your internet service provider (ISP), your browser and browser plug-in types, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your Device, the language you have set for your Device and the version of the Games installed on your Device.
  • Game(s)”shall mean a game published by GOSU regardless of the Platform it is distributed on or the Devices it is developed for.
  • Location Information”shall mean general information about the location from where you are playing the Games. We do not collect precise geolocation information, however, we may collect your Device’s IP address which can be used to identify the general location (city, province/state, country).
  • Platform”shall mean application stores through which Games are provided to Users (e.g., Google Play, Apple App Store). For the purposes of uniformity and for the avoidance of doubt, the term “Platform”as used in this Policy has the same meaning as the term “Application Store”in the Terms of Service.
  • Platform ID”shall mean an identifier assigned to your Device by the Platform when you log on to the Platforms or download the Games from the Platforms.
  • “Speech Data”shall mean your speech that was transcribed into text when using the voice assistant.
  • Support ID”shall mean an identifier we assign to your Device when you download and use our Games for the purposes of providing customer support.
  • Terms of Service”shall mean the agreement between GOSU and the User on whose basis access is granted to our Games and other Services upon the User’s acceptance, and which can be found at https://sbergames.ru/legal/Terms_of_Service.
  • Transaction ID”shall mean the unique identifier for a transaction such as a purchase, restoration, refund or renewal in the payment systems that we may use for the Games.

WHAT KIND OF INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?

The purposes and legal basis of data processing:

When you use our Services, we may collect and process technical information that may be considered personal data in certain jurisdictions.

We may collect and/or process such information to provide you the Services and the best user experience. You consent to such processing when you accept the Terms of Service and this Policy in the consent form provided in the Services.

Our legal bases for such processing are:

  • the contract between you and GOSU (Terms of Service);
  • your explicit consent to the processing expressed through the consent forms provided in the Services;
  • our legitimate interests.

Our legitimate interests are the following:

  • accounting and reporting (including management reporting);
  • identifying your age for legal compliance;
  • studying the markets in which we offer our Services;
  • making and substantiating our legal claims as well as the claims of third parties;
  • providing security and fraud prevention.

 

We process data for the following purposes:

  •  to improve our Services and analyze how they are used by Users, which implies processing Location Information indicating where the Services are used, the frequency of such use, the categories of Users and other statistical and analytical information;
  •  to establish and maintain our relationship with you (including customer support).

The collection of this data is crucial for us to provide you the Services. Therefore, if you wish to opt-out from our processing of your data, unfortunately, the functionality of our Services available to you may be limited. Nevertheless, you have the option to require the deletion of any information we have collected.

The types of information we process:

When you download a Game and start to use it, you may log in using the Platform which you downloaded the Game from. The Platforms will generate a Platform ID.

In such case, we will process your Platform ID which will allow us to:

  • know that you use a specific Platform;
  • restore your progress and purchases made in the Game in case you decide to delete and then re-install the Game.

You may also decide not to log into the Game through the Platform. In such case, we will assign your Device a Support ID that we will use to provide customer support and other Services to you.

In general, we endeavor to limit our data processing to Platform IDs and Support IDs. Nevertheless, we have legitimate interests in promoting and marketing the Services, thus, we may also process the information given in the table below.

Personal Data

Legal Basis for Collection

Purpose(s)

When You Play the Games

Information about how you play and use the functionality of the Services (version number of the Game you are using and the operating system version running on the Device;frequency;length of the game;Device;Platform;level;which in-game ads you may have viewed;in-game purchases and in-game preferences etc.)

Terms of Service

Our legitimate interest in learning about the market we provide our Services in.

Our legitimate interest in maintaining our relationship with you.

Providing you the best user experience and allowing you to save the progress in the Games.

Providing you the Game’s functionality –for more information, please see the section “Games Functionality”.

Analysing the use of our Services –for more information, please see the section “Analytics”.

Advertising IDs, Location Information, and Device Information

Terms of Service

Our legitimate interest in promotion and marketing of our Services.

Our legitimate interest in learning about the market in which we provide our Services.

Our legitimate interest in maintaining our relationship with you.

Analysing the use of our Services –for more information, please see the section “Analytics”.

Advertising –for more information, please see the section “Advertising”.

Games functionality –for more information, please see the section “Games Functionality”.

Transaction ID

Terms of Service

Our legitimate interest in maintaining our relationship with you.

Our legitimate interest in conducting the reporting.

Collecting and recording payments received –for more information, please see the section “Payments”.

Age barrier result

Our legitimate interest in compliance with legal requirements

Identifying your age and your capability to give consent for personal data processing –for more information, please see the section “Processing of children’s personal data”.

Speech Data

Terms of Service

Our legitimate interest in maintaining our relationship with you.

Virtual assistant function availability –for more information, please see the section “Games Functionality”.

User account ID in social networks, Location Information, and Device Information

Terms of Service

Your consent which you express by logging into the social network profile and accepting the privacy policy of the social network.

Allowing you to save progress on multiple Devices.

Providing you with an opportunity to share your progress on the social networks and conduct other communication related to the Games in the social networks (if available) –for more information, please see the section “Social media features and tools”.

Your e-mail address

Terms of Service

Our legitimate interest in maintaining our relationship with you.

Your consent expressed by providing us the e-mail address.

Customer support  

When You Use the Website

Device Information

Terms of Service

Your consent to the processing of “cookie”files given on our Website – for more information, please see section “Cookies”.

Our legitimate interest in learning about the market in which we provide our Services.

Our legitimate interest in maintaining our relationship with you.

Analysing the use of our Services – for more information, please see the section “Analytics”.

Information about your interaction with the Website, i.e., number of times the Website was accessed by you, the exact time you accessed and exited the Website

        Your consent to the processing of “cookies”used on our Website – for more information, please see the section “Cookies”.

Analysing the use of our Services – for more information, please see the section “Analytics”.

Location information, information on the search engine you used prior to accessing the Website

Your consent to the processing of “cookies”used on our Website – for more information, please see the section “Cookies”.

Our legitimate interest in learning about the market we provide our Services in.

Analysing the use of our Services – for more information, please see the section “Analytics”.

Information on your interaction with other Websites, statistics and preferences in regard to the content of the Website or other third-party Websites.

Your consent to the processing of “cookie”files used on our Website- for more information, please see the section “Cookies”.

Analysing the use of our Services – for more information, please see the section “Analytics”.

When You Contact GOSU (through the Games or the Website, or otherwise)

Name and e-mail address, Location Information, Device Information

Your consent which you express by filling in the contact form in the Game or on the Website, or by providing the personal data voluntarily and directly to us.  

Our legitimate interest in providing you with the best user experience, to pursue our legal claims or fulfil our legal obligations towards you.

You have the option to contact our customer support team directly or from our Games or Website. When you do so, we will collect and use this information to respond to your requests and/or comments.

Name and e-mail address (for developers)

Your consent which you express by filling in the contact form on the Website, or by providing the personal data voluntarily to us.  

Our legitimate interest in establishing a relationship with you.

As a developer, you have an option to contact us through our Website to apply for a job, or for other commercial or non-commercial purposes. We use your data to establish the working or commercial relationship with you.

Your correspondence with us, or a record of it.

Your consent which you express by filling in the contact form in the Games or on the Website, or by providing the personal data voluntarily and directly to us.

Our legitimate interest in providing you with the best user experience, to pursue our legal claims or fulfil our legal obligations towards you.

When you contact us for support or in regards to any legal or commercial issue, we may record the contents of your messages to us to answer them, and to use them to protect our rights, or assist you in protecting yours, and to fulfil our legal obligations towards you.

Below is a more detailed overview of our data processing pertaining to different purposes in the list above.

ANALYTICS

While you play the Games

As a game developer and publisher, it is important for us to know how users interact with our Games.

We may check the version number of the Game you are using and the operating system version running on the Device you use. This data is used for statistical purposes and will not be stored or transferred.

We enable third-party services to collect your Location Information, Device Information, and Advertising IDs so that we can deliver our Services to our users, measure, analyse and improve the performance of the Games, and to continually update and develop our Games.

We may use this information to assess the difficulty level of Games, fix any bugs or errors in the Games, evaluate the demographics of our users, and to determine whether we need to support a new Device type for the Games, determine whether we need to change our marketing and distribution decisions.

The third-party services that we use put in place technical and organizational measures to ensure safe processing of personal data as stated in their privacy policies.

We ensure that the agreements we conclude with the third-party services providers contain provisions for the safe processing of your personal data and the appropriate safeguards prescribed by the applicable Data protection laws.

We enable the collection of personal data by the third-party services using their Software Development Kits (hereinafter –“SDK’s”) which contain options and safeguards to ensure the protection of personal data.

Below you may find the list of the third-party services and their privacy policies:

Third-party service

Link to the privacy policy

Google Firebase (Google Analytics)

https://policies.google.com/privacy

While you access our Website

Our Website is directed at promoting our Games and Services and it is important for us to learn more about the Users who has shown interest in playing our Games and using our Services.

We have placed “cookies”(hereinafter –“Cookies”) on our Website that are uploaded to your Device when you access our Website and give consent to their processing (to learn more about Cookies, please see the section “Cookies”).

These Cookies may be provided and used by us to learn more about our audience and efficacy of the measures we use to draw interest to our Games and Services and their viability as business projects.

ADVERTISEMENT

While you play the Games

Our Games may include third-party services that show targeted advertisements. We integrate these third-party services into our Games using their SDKs which are then used by the third-party service providers to determine what kind of ads to display to you.

To show you ads that might be interesting and/or relevant to you (“Targeted Ads”), third-party services collect and use your Advertising ID, Location Information and Device Information. Because these third-party services’technologies control what kind of personal information is collected from your Device and how it is used, we encourage you to review their respective privacy policies.

Below is the list of the third-party services we use for advertisement and the links to their privacy policies:

Third-party service

Link to the privacy policy

AppsFlyer

https://www.appsflyer.com/legal/privacy-policy/ 

How to Opt-Out from Receiving Targeted Ads        

If you do not want to receive Targeted Ads, you may decide to opt-out from our processing of your personal data, however, the functionality of our Services available to you will be limited. With this in mind, your mobile Device shall give you the option to opt-out from receiving Targeted Ads on all apps. On Android Devices, you may opt-out by enabling the “Opt-out of Ads Personalization”setting. On iOS Devices, the forwarding of Targeted Ads is disabled by default, you may change this in the section “Allow Apps to Request to Track”in the Device’s settings.

In addition, you may be able to opt-out from receiving Targeted Ads from a specific third-party service. Please review our third-party services list and their privacy policies to see if they offer the ability to opt-out from receiving Targeted Ads.

In any event, you can contact us at support@sbergames.ru to inform us about your wish to opt-out from receiving Targeted Ads. We will share this information with our third-party services.

Please note that if you opt-out from receiving Targeted Ads, you may still receive contextual ads, which are non-targeted ads related to the content of the Games you are playing.

While you access our Website

We do not place advertisement from third parties on our Website. However, we may integrate Cookies into our Website that may collect your personal data to serve you with advertisements tailored to your preferences regarding content.  

A more detailed description of the Cookies we use is in the “Cookies”section of this Policy and the provisions it references.

FUNCTIONALITY

To provide you with the best experience in our Games, we integrate certain third-party services which may process your personal data.

We ensure that the third-party services which we integrate into the Games comply with the Personal Data Laws and that our agreements with these services providers provide for the required data protection safeguards.

For example, we implement the third-party service “GOSU.AI Voice Assistant”to allow you to interact with our Services orally. This assistant may process your Speech Data by transcribing your voice. Your voice logs will not be stored. This processing will be strictly limited to providing the ability to interact with our Services using your voice. We will not transfer your Speech Data in any form to any third parties.

If you prefer not to have your Speech Data processed, you may turn off the voice assistant functions in the preferences of the Games.

Below is the list of the third-party services we use for functionality and the links to their privacy policies:

Third-party service

Link to the privacy policy

GOSU.AI Voice Assistant

https://gosu.ai/terms-and-privacy

PAYMENTS

We may process the personal data pertaining to the payments only in the form of Transaction IDs provided to us by their respective Platforms. Such processing is pursuant to the terms of our business relationships with you. We use the Transaction IDs to verify the payments made in the Game and also for fraud prevention, refunds and collection of subscription fees together with the Platforms through which the Games are provided to the Users.

When you make in-app purchases in the Games, we do not collect or have any access to your name and billing information. This information is collected and stored by your Platform (e.g., Apple’s App Store, Android’s Google Play) or your Platform’s payment processor.

SOCIAL MEDIA FEATURES AND TOOLS

The Games and the Website may include integrated social media features and tools, such as the ability to log on to your social network accounts to use some of their features such as Facebook’s “Like”button and YouTube’s “Share This”button. These features may collect User account ID on social networks, Location Information and Device Information.

Social media features and tools are hosted by third parties, and your interactions with these integrated social media features and tools are governed by the privacy policies of the companies providing them.

Social media service  

Link to the privacy policy

Facebook

https://www.facebook.com/about/privacy 

YouTube

https://policies.google.com/privacy

COOKIES

Our Website uses Cookies.

Cookies are small text files that can be used by websites when put on your Device when you access the websites to make a user’s experience more efficient.

We use Cookies to provide the Website’s functionality to you and maintain your navigation through it. We may also use Cookies for showing personalized ads, to provide social media features and to analyze our traffic. We may also share information about your use of our Website with the third-party service providers.

We may process Cookies necessary for the operation of our website based on our legitimate interest to maintain the website.

For all other types of Cookies, we need your permission. The list of types of personal data processed with the use of Cookies is given in the section “The types of information we process”of this Policy.  

 

You may refuse to accept our Cookies on your Device at any time by activating the setting on your browser which allows you to refuse Cookies. The “Help”feature on most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive new Cookies and how to disable Cookies altogether.

To find more details about our use of Cookies, please see our Cookie Policy.

WHAT ARE YOUR RIGHTS IN RELATION TO PERSONAL DATA?

Under the applicable Data Protection Laws, you have certain data subject rights including the right to:

  1. request access to and rectification or erasure of your personal data;
  2. obtain restriction of processing or to object to the processing of your personal data;
  3.  ask for a copy of your personal data to be provided to you, or a third party, in a digital (machine readable) format;
  4. lodge a complaint;if you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence;
  5. object to our processing of your personal data if:
  •  you believe that we no longer have the legitimate purpose for processing;
  •  the personal data is processed for direct marketing purposes;
  •  you believe that your data is processed by automated means.

You may also exercise any rights provided by the applicable Data Protection Laws. If you wish to exercise one of the above-mentioned rights, please contact us at support@sbergames.ru. We would need to identify the requestor so we may ask for additional information.

Transfer of Personal Data Outside of the EEA. Because we may store the data we collect outside the EEA, and some of the third-party services providers we engage are located in countries outside of the EEA, your personal data may be transferred to other countries, e.g., the Russian Federation, that may not offer the same level of data protection as the laws of your country of residence.

We are obliged to store your personal data in such jurisdictions ensuring we can provide all the necessary security mechanisms for protecting your personal data, including data encryption (if available) and taking obligations under standard contractual clauses.

While we and the providers of the third-party services take all the reasonable and necessary measures aimed at protecting your personal data against unauthorized access by third parties, we shall inform you about the possible risks of such storage of your personal data in jurisdictions outside the EEA under Art.49(1)(a) of the GDPR.

Such possible risks include:

  1. Existence of different rules and regulations on personal data processing in such jurisdictions that are different from the GDPR. However, we provide personal data subjects with the level of guarantees granted to personal data subjects by the GDPR.
  2. State authorities of the third country, or other special governmental services obtaining access to your personal data. However, such access can only be obtained by these authorities in accordance with the applicable law of that country and only if there are legal grounds for obtaining the access. We undertake the obligation not to disclose information in the absence of such legal grounds and only to the minimum required extent.
  3. Efforts of illegitimate access to the personal data. We take all the necessary measures to prevent such efforts and do not allow unauthorized access to your personal data.

By agreeing to the processing of your personal data in accordance with this Privacy Policy, you provide us with the explicit consent to transfer your personal data to countries outside EEA despite all the possible risks of such transfer.  

HOW TO DELETE YOUR DATA?


If you wish to opt-out from our processing of your personal data and delete your data, you should contact us at 
support@sbergames.ru with a request to stop the processing and delete your data. We may process your request for 30 days from the date of its receipt by us.

We would need to identify the requestor so we may ask for an additional information. After said deletion, all of your in-Game progress will be lost, as well as the in-app purchases and account details.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

When playing the Games, we will keep your processed personal data for a period no longer than one year in order to allow you to restore your progress in the Games and allow us to conduct analysis of our Games’use. The aggregate statistical information based on the Users’interaction with our Services may be stored in an anonymized form for three years.

If the Data Protection Laws prescribe to store the personal data for longer or shorter periods, we will store the personal data for the period that is necessary to comply with the effective legal requirements.

IS YOUR PERSONAL INFORMATION SECURE?

The security of your personal information is important to us.

We follow generally accepted industry standards to protect your information both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

While no security system is completely secure, we and our partners implement appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. For GOSU, this includes, but is not limited to, ensuring that all of your information is disclosed only on a “need to know”basis and ensuring that all information collected by GOSU is done so via secured connections, protected and encrypted by industrial grade security software to guard against unauthorized access. Our employees and third parties that we share your information with are obliged to keep the confidentiality of your data.

WILL YOUR DATA BE TRANSFERRED TO THIRD PARTIES?

By accepting this Policy, you agree that we may transfer your information to the abovementioned third parties. We conduct such transfer on a contractual basis (to perform the Terms of Service) and on the basis of our legitimate interest to learn about the market in which we work.

Business transfers

To provide you with a better user experience and fulfil the Terms of Service executed between you and us, we may implement third-party services in our Services whose providers may process your personal data for the purposes of assisting us in providing you the Services.

We ensure that the agreements we execute with the providers of the third-party services provide for the level of personal data protection that is not lower than under this Policy and correspond to the requirements of the applicable Data Protection Laws.

In addition to the implementation of third-party services, we may transfer your personal data to our processor –SberGames, LLC (hereinafter –“SberGames”). It may process the personal data listed above for the following purposes:

  • customer support (consulting users on the use of services, as well as fixing errors in the operation of services);
  • fixing and processing requests related to the deletion of data in accordance with the GDPR;
  • preparation of informational notifications to users.

We represent that we have concluded a data processing agreement with SberGames that lists the appropriate technical and organizational measures taken by SberGames to ensure the security of the personal data and an obligation to not transfer the personal data further to other third parties.

As we continue to develop our business, we may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third-parties. In any of these types of transactions, any information you provide may be one of the transferred business assets. In the event that all or substantially all of our assets are acquired or we merge with a third-party, your information will likely be one of the transferred assets. You understand and agree that we reserve the right to transfer any information collected from you in the case of any such transfer. In such event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.

Legal transfers

We may disclose information you provide to respond to subpoenas, court orders, requests from authorities in any procedures, and to establish/exercise our legal rights. We may also disclose your information to defend against legal claims when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We may share your information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.

Transfers from third parties

We may receive personal data from third party sources, e.g., from Platforms (for example, to verify payments).

By accepting this Policy, you consent to our processing of the personal data provided to us by the third parties. In the case it exceeds the types of data we process on our own under this Policy and in the absence of a suitable legal basis for us to process such data, we will contact you and request your consent.

Third parties and their privacy policies

Throughout your use of our Games, you may see links to third-party websites or applications (e.g., in ads which are shown in the Games). Please be aware that if you follow the links to third-party websites or applications, you might share your personal data with such websites or applications. GOSU does not control collection of personal data by third-party websites or applications, and we encourage you to read their privacy policies.

PROCESSING OF CHILDREN’S PERSONAL DATA

The Services are intended for general audiences, and GOSU does not knowingly collect any personal data from children.

We implement an age barrier based on specifying the User’s year of birth or other verification methods (for example, solving a math problem). We will not store the year of your birth;we only store information about whether you are over 18 years old (“yes”or “no”). Based on the result of passing the age barrier, we may restrict access to our Services to Users under the age of 18 until the consent of a parent or legal representative acting on behalf of a minor user is obtained.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files within a reasonable time period.

ABOUT US

GOSU Data Lab UAB

Address: Rinktines g. 5, LT-09234 Vilnius, Lithuania.

E-mail: support@sbergames.ru.