privacy POLICY

Effective date: September 30, 2019

Last updated:

[reserved]

Introduction

Navy Spade Software aims to create unique entertainment experience for people around the world. To pursue our goals, we collect and use certain information from our players. We have created this Privacy Policy to be fully transparent and to demonstrate our firm commitment to protecting and respecting your rights and privacy.

Navy Spade Software develops and publishes application and games (“Apps”) for a range of platforms, including, but not limited to mobile devices (“Devices”). Other terms used in this policy include:

“Navy Spade Software”, “we”, or “us” in this Privacy Policy refers to Navy Spade Software and any other corporate entities under ownership of Navy Spade Software;
“Services” refers to our web sites, games, applications, and other properties or services owned or operated by Navy Spade Software . “Apps” refers specifically to games and applications;
“You” or “your” refers to any individuals or entities who use our Services.

This Privacy Policy applies when you use our Services and Apps. It describes how we collect, store, use, and disclose your personal information when providing these Services to you, and your rights concerning your information.

By using our Services, you agree to the practices described in this Privacy Policy. If you do not agree to this privacy policy and the practices described herein, please do not access and / or use the Services.

Personal data we collect and why do we collect it

Navy Spade Software is a gaming company headquartered in Saint-Petersburg, Russia. Our main business is to develop and publish mobile game applications.

Our Apps are free to play games (with optional in-game purchases and ads), and in order to maintain a high quality and a great game experience, we process information from and about you to improve the entire experience in the Apps and to support internal operations. Below you find the data we collect.

Data you provide directly to us

Certain parts of our Services may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to begin playing games, to subscribe to marketing communications from us, and/or to submit enquiries to us. This information and contact details may further include:

Your first and last name;
Your username and password;
Profile information (such as profile photo);
Your gender;
Your age or birthday;
Your email address;
Other information you choose to give us (such as data to identify a lost account, chat logs, player support tickets).

You may also give us information when:

You upload user-generated content (such as, photos, comments, or other materials) that you post to our Services;
You correspond with our customer support team (such as, your name, email address, information about your game play or activity in our Services) which we will store and may share with our internal teams to provide support, diagnose technical issues, and improve our Services. For example, we may send you Service-related emails (such as account verification, technical or security notices);
You voluntarily participate in our surveys, promotions, and contests, which we conduct from time to time;
You opt-in to receive marketing email newsletters for updates related to our Services.

Data you generate using our services

When you use our Services, we will collect information on the ways you use and interact with our Services, such as:

Data about your account and game progress;
How long and often you return to use our apps and games;
In-app purchases you make and consume;
Other gameplay related activities, such as your interactions with other players inside the Service.

Data we collect automatically

When you use our Services, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, your age, device information incl unique device identification numbers, browser-type, language, general location data, data to fight fraud and cheating, and other technical information. We may also collect information about how your device has interacted with our Services, related to your use of the Apps, including your game progress, scores, achievements, purchases with both virtual and real currencies, reception of virtual goods in-game and interactions with other players.

Data we collect from our partners

When you use our Services, we may collect certain information from our partners. This data might include:

Data we receive if you log into or link the Apps with third party tools (such as Facebook);
Demographic data (such as to determine the coarse location of your IP address);
Data to fight fraud (such as refund abuse or advertising abuse);
Data from platforms that the Apps run on;
Data for advertising and analytics purposes, so we can provide you with a better service.

When you use any of our Services on connected third-party applications or platforms (like Facebook, Apple, Google, Microsoft, or Amazon), any purchases you make will be processed by that third-party and subject to their terms of service and privacy policy. For these purchases, Navy Spade Software does not receive your financial information, but may receive non-financial information related to your purchases, like your name, approximate physical location, and the items purchased.

Other sources

We may collect or receive information about you from other sources like third-party information providers. We use this information and the information you provide us directly, for instance, to provide you better Service and show you advertising that we believe is most relevant for you.

Legal basis for processing personal information

Under the data protection laws applicable, Navy Spade Software must have a legal basis to process your personal data. The legal basis that applies in a particular instance will depend on the specific purposes for which Navy Spade Software is processing your personal data:

In certain cases, Navy Spade Software will ask for your consent to collect and process your personal data. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described below. Please note that the withdrawal of consent will not affect processing which has already occurred;
In other instances, the processing of your Personal Data may be necessary in order to comply with any applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.

Usage of personal information

Navy Spade Software’s primary goals in using your information are to deliver services and games to you, based on your acceptance of our terms and conditions.

With your consent, we will also collect your information to troubleshoot, improve and optimize our services and games, contact you, conduct research and create reports for internal use to make sure we provide you with the best experience. Uses of your information, thus, may include:

Creating accounts and allowing you to play our apps and use our Service;
Saving your account information and game progress, no matter the device and platform you use to access our apps and service;
Showing personalized advertisements to support the Service;
Enabling players to share user content and communicate with each other (on a per app basis);
Providing technical support and resolving customer support inquiries;
Preventing fraud or potential illegal activities, protecting the safety and well-being of our users, and enforcing our Terms of Service;
Communicating with you about updates to the apps and promotional offers we believe might be of interest to you;
Managing in game events, online tournaments, contests, or sweepstakes (that you agree to participate in);
Complying with our legal obligations and protecting Navy Spade Software’s rights and property in connection with our Services.

Sharing of personal information

We may share your information, including personal information, with third parties (collectively, our “Partners”), and allow third parties to collect information to provide our Services for you. We use advertising to fund our Services and to make our games available for free. We show third party advertising in our games and also advertise our Service via third parties. To enable us to show in-game ads we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third party properties.

Advertising partners

We use advertising to enable us to offer some of our apps, in-app features, and other Services for free. We and our advertising partners collect and share personal information with each other, so our advertising partners can decide to bid on ad inventory and serve ads best personalized for you.

Our advertising partners collect aggregated information (non-personal information) to measure the effectiveness and value of advertising on our Service, such as ad views, ad clicks, and whether users performed post-click actions like clicking to advertiser’s web site or installing the app.

Analytics partners

We collect and share personal information with analytics partners to perform marketing optimization and data analytics, such as:

How long and often you use our apps and games;
Game features you and other players interact with;
Other gameplay related activities.

Third-party service providers and other partners

We share personal information with Partners only according to Navy Spade Software’s instructions to provide the Service, such as hosting, player support, app performance tracking, and fraud prevention.

Our Partners are obligated to use personal information we share through our Service in compliance with applicable laws and regulations. We ensure we have appropriate agreements in place with Partners to protect your information.

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies. Check out the list of third parties we use (or might use) on our website/in our games:

Gameanalytics - https://gameanalytics.com/privacy
Google analytics - https://www.google.com/analytics/terms/us.html
Firebase - https://firebase.google.com/support/privacy/
Appsflyer - https://www.appsflyer.com/privacy-policy/
Tenjin - https://www.tenjin.io/privacy/
Facebook - https://www.facebook.com/privacy/explanation
Iron source - https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Mopub - https://www.mopub.com/legal/privacy/
Admob - https://support.google.com/admob/answer/7665968;
Applovin - https://www.applovin.com/privacy/
Vungle - http://vungle.com/privacy/
Unityads - https://unity3d.com/legal/privacy-policy
Facebook Audiance Network - https://www.facebook.com/about/privacy/update?ref=old_policy
Adcolony - https://www.adcolony.com/privacy-policy/
Tapjoy - https://www.tapjoy.com/legal/#privacy-policy

Please note that other third parties (our data partners) may be data controllers of your information.

In all the above cases and purposes, we may analyze, profile and segment all collected personal information. With your consent, we may process information for additional purposes.

Social sharing features

The Services offer social sharing features which let you share actions you take in the App with other media (for example Facebook, Twitter, Game Center and similar). The use of such features enables sharing of information with your friends or with the public, depending on the settings you establish with the entity that provides the social sharing feature.

For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, according to the applicable processing laws, you can do so at any time by contacting us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect;
You can in certain circumstances, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information according to the applicable data processing laws;
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we may send you;
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent;
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws in due course. Please find the contact datails at the end of this Privacy Policy.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Security

Navy Spade Software uses appropriate technical and organisational measures designed to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Our servers are located around the world, and our third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice and applicable law.

Push notifications

Navy Spade Software may send you push notifications or alerts to your mobile device to provide game-related information, promotional communication and other related messages, if you have agreed to such notices. You can deactivate these notifications by changing the notification settings on your device.

Children’s privacy

Our services are intended for general audiences and we do not knowingly collect personal data about children. If we discover that we have inadvertently gathered personal information from a minor under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.

How to contact us and how to exercise your rights

To stop all collection of information from the Services, leave and discontinue use of the Service. You can also easily stop all collection of information through an App by uninstalling the App.

If you have any questions or concerns about our use of your personal information, or if you want to exercise your rights to access personal information or for your personal information to be erased, please contact us by sending an e-mail to

privacy@navyspade.com

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

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