By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the activities described in this notice, the data controler is AppGeneration Software Technologies, Lda.
While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data.
In matters related to this notice, you can reach us by email at email@example.com or to:
AppGeneration Software Technologies, Lda.
Av. da Boavista, 848
4100-112 Porto - Portugal
To perform our contract with you, we may process your data as necessary to:
Based on our legitimate interest to make our Services the best they can be, we may process your data to:
Based on our legitimate interest to make sure you have the best possible user experience in our Games, we may process your data to:
Based on our legitimate interest to make sure our Services are a fair and safe environment for all users, we may process your data to:
Based on our legitimate interest to promote our Services and to make sure we reach interested audiences, we may process your data to:
Based on our legitimate interest to provide you with relevant ads in our Games and to fund our Services so that we can keep providing them to you, we may process your data to:
Based on our legitimate interest to safeguard our operations, we may process your data to:
With your consent, we may process your data:
Finally, we may process your data as necessary to:
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
We do not use your data to make automated decisions which significantly affect you. By an “automated decision”, we mean a decision made by an information system without any human intervention.
Advertising funds our Services and enables us to make our Games available free of charge. In our Games, we show our own ads and also ads from third parties. We also advertise outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes.
Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of a device. It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices.
Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them to your desired state on each of your devices individually. It may take some time for your updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads, but the ads you see may be less relevant to you.
When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID).
When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. Ad networks may also use your data to:
In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services.
For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. It is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.
A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.
We may process the following data relating to you:
We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
We may collect data relating to you from the following sources:
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings.
We may share your data with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:
In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards.
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services.
After the applicable retention period, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).
We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the processing activities described in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary, but typically include, for example, encryption in transit, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.
If we are processing your data, you have the right to:
Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.
To exercise any of your rights, you can contact us at firstname.lastname@example.org. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations.
Finally, you always have the right to lodge a complaint with your local data protection authority regarding our processing of your data. For more information, please contact your local data protection authority.
Under our Terms of Service, you represent that you are at least 13 years of age. However, we do not know the specific age of individual users of our Services. If you are under 13 years of age, please do not provide your personal data (including your name, address, telephone number, or email address) to us or use the Services to make your personal data available to others.
If we discover that we hold personal data relating to a user under 13 years of age, we will take appropriate measures to ensure that we process that data according to the requirements of applicable laws and regulations or promptly delete the data from our records. If you have reason to believe we hold personal data relating to a user under 13 years of age, please contact us.
We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.
Effective May 19th, 2020.