You must possess sufficient capacity (reach certain age) under the applicable law of your place of residence to accept Policy. If you haven’t reached this age, your holder of parental responsibility should study and accept Policy on your behalf. Developer neither purposefully collects personal data of children under 13, nor does Developer sell personal data, so if you as a holder of parental responsibility learn that your child has accepted Policy in violation of the aforementioned, please, contact Developer through firstname.lastname@example.org and we will erase the data.
Hereby Users are informed to check Policy regularly since Developer reserves the right to update it at any time.
Private Entrepreneur Fedoseev Evgeniy Sergeevich
Private Entrepreneur Registration Number (PERN): 307645303600019
- Vavilova, 38, office 1004, Saratov, Russia
- “Activity Information” – statistical information about actions Users undertake while playing Red Ball 5 or accessing the Game’s application, such as first User flow interactions, mission/objective completions, User progression, virtual economy data.
- “Device Information” – technical information about User’s device. Device Information includes: IP address, information about the network, type and manufacturer of the device, the language set for the device, the version of Red Ball 5 installed on the device used.
- “User Attribution Data” – information about the source from which Users learnt about Red Ball 5 and/or download or obtain access to the Game.
- “User ID” – a unique identifier assigned to User’s device, which is used for recognition of each separate User.
1. What and for which purposes does Developer process Users’ personal data?
|Personal Data||Purpose||Legal basis|
|Provision of Game’s functionality||User’s freely given, informed, unambiguous and specific consent
|Analytics||User’s freely given, informed, unambiguous and specific consent
Our legitimate interest in improvement and further development of the Game
|User Attribution Data||Analytics||User’s freely given, informed, unambiguous and specific consent
Our legitimate interest in efficient advertisement of the Game and popularisation
We do not collect direct personal data like name, e-mail or address.
We have shrunk our data processing to a minimum, and, as is shown above, purposes of processing come down to improvement of the Game and advertisement thereof.
User’s consent is necessary to enable Developer to provide proper functionality of the Game.
2. Does Developer provide security of Users’ personal data?
Yes, Developer applies physical, managerial, and technical safeguards to ensure secure processing, such as restricted access to data, regular integrity checks and monitoring, anti-virus software, contractual obligations to keep confidentiality of data, and data encryption used by our partners. To sum up, Developer uses generally accepted industry standards to protect personal information.
Developer regularly updates personal data and takes measures to prevent loss of data.
3. How long does Developer store personal data?
Data used for the purposes of analytics is usually not stored or not stored for a prolonged period of time.
Other information, however, Developer will process data for as long as User plays the Game and for 3 years after User ceases use of the Game.
Keep in mind that User has a right to erasure and rectification of data.
4. Does Developer transfer personal data to third parties?
Yes, Developer transfers to and receives data from the following third parties:
|Amplitude Inc.||Address: 631 Howard Street, 5th Floor, San Francisco, CA 94105
Server location: USA
Purpose: analytics for Game improvement
|AppsFlyer Ltd.||Address: 14 Maskit St., Herzliya, Israel
Server location: Israel, other as may be specified by the processor
Purpose: User attribution
|Tenjin Inc.||Address: 476 Jackson Street, 3rd floor, San Francisco, CA 94111
Server location: USA, other as may be specified by the processor
Purpose: User attribution
Developer allows the aforementioned third-party services collect and Developer receives data for the purposes of improvement of the Game, analytics and popularization/advertisement of the Game.
In addition to the listed jurisdictions, Developer collects and processes personal data in the territory of Russia and USA – jurisdictions not recognized as adequate by the European Commission.
Developer guarantees that the agreements concluded with third-party services provide at least the same level of data protection, include corresponding safeguards and confidentiality clauses dictated by the applicable data protection laws. Nevertheless, under GDPR Developer is obliged to list potential risks of transfer to the territory of inadequate countries:
- Different regulation of personal data processing;
- Potential access to personal data of state institutions of the RF and US; and/or
- Potential illegitimate access to data.
By accepting Policy, you agree with personal data transfer to the territory of Russia and the United States of America.
5. What rights do Users have in relation to their personal data?
Users have the following rights in relation to personal data:
- Right of access, rectification or erasure of personal data;
- Right to object to processing of personal data and request restriction of processing;
- Right to request a copy of personal data processed, including for a third party, in machine readable format;
- Right to lodge a complaint.
To exercise the listed rights, please, contact Developer through email@example.com. We will request additional information to identify the User.
If Developer finds User’s request reasonable, Developer will adopt appropriate measures and notify the User of actions taken.
Developer does not process cookie files.
Developer does not sell Users’ personal data to third parties.
Developer does not use targeted ads.
If you have any questions concerning Policy, please, don’t hesitate to contact Developer through firstname.lastname@example.org.