Effective Date: 18th of November, 2019
1. Introduction and Applicability of This Policy
2. Data Controller Details
2.1. Throughout this document, “Company”, “we”, “us”, “our” and “ours” refer to
APL Publishing Ltd. (“Data Controller”)
Address: 60/2, Melita Street, Valletta VLT 1122, Malta
Contact E-Mail: email@example.com
3. Table of Contents
4. Data We Collect and Receive
4.1. In order to provide the Services, we may collect or receive data, which may include the information voluntarily provided in the course of filling special forms in the Game, the information provided during subscription to the Services, publication of materials and request for other services or information collected automatically during the course of providing the Services.
4.2. Data You Provide Us With
4.2.1. Account Data
To create or update an Account, you may be asked to provide Personal Data including, but not limited to, your username.
4.2.2. Communication and Content Data
When you communicate with us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, we may process all of this information. This data includes:
Please note that information that you voluntarily make public, or which you post publicly (for example in the game-chat), will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions.
4.2.3. Anonymous data
We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
4.2.4. Sensitive Information
We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.
4.2.5. Social Network Login
To access some Services, you may choose to log in using your social network account, for example such as Facebook or Vkontakte. We do not have access to your social network login and password, since the login process runs on social network’s servers. You enter your username and password on social network site. You are responsible for safeguarding the details of your social network account and for any activities or actions under your social network login using the Services.
When you connect to the Services and/or use the Services through your social network account, you will be asked to permit the Service to access certain information stored on social network. We use your information from social network account only in accordance with your privacy settings you have set up under your social network account. Accordingly we only use the information to provide you with the Service at the given moment (but do not store) such information, which you allowed social network to share with third parties subject to the privacy settings that you have set in social network.
4.2.6. Other Data
We may request any information required to organize and conduct events in the Game when you register to participate in such events initiated by us.
4.3. Data We Collect Automatically
4.3.1. Usage Data
The browser (when visiting our Site) or a client program may transfer certain information about the details of visits to the Services, including
In most cases, when you use the Services, we also create for you an in-game identifier such as an Account ID.
4.3.2. Cookie Files and Similar Technologies
Cookies or similar technologies stored on your computer or device through which you use the Services have amongst others but without limitation, the following functions:
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
We may use third-party analytics providers software to allow us to better understand the functionality of our software on your device, including but not limited to, Google Analytics, Google AdWords, Yandex.Metrica, firebase, Facebook Analytica, AppsFlyer (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Services, the events that occur within the Services, aggregated usage, performance data, and where our Software was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Services.The information about your use of our Services, may be transmitted to and stored by Third-Party Analytics Providers’ servers, which may also be located outside of the European Economic Area.
The following are third parties that we use for analytics:
To Opt-out: Visiting Yandex Metrica opt-out add-on.
Solution for analytics that helps to understand how You use our Services. For more information about Facebook Analytics privacy practices, please see the https://www.facebook.com/full_data_use_policy.
Firebase helps us understand clearly how Users behave, which enables You to make informed decisions regarding app marketing and performance optimizations. For more information about Firebase privacy practices, please see the https://firebase.google.com/terms/analytics.
Google AdWords (Marketing Cookies)
To Opt-out: Visiting Google’s Ads Settings.
To opt out, please visit this page: https://www.appsflyer.com/optout.
You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.
5. How We Use Your Data
5.1. To Provide the Services to You
To provide the Services to you and to perform our contract with you, we use your information, which is necessary:
5.2. To make the Service more suitable for our players
5.2.1. To provide a great Service to our players, we have a legitimate interest in collecting and processing the necessary data to
You may opt out of receiving promotional communications from us. To find out how to do this, please refer to section 11.7. “Request That We Stop Using Your Data”.
5.3. To Keep The Services Safe And Fair
5.3.1. In order to keep the Service and its social features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to:
5.3.2. If the data can be used to prove that cheating, fraudulent activity, or EULA violation has occurred, we will further store the data for the establishment, exercise, or defence of the legal claims for the duration of the applicable statute of limitations.
5.4. With Your Consent
5.4.1. With your consent, we may process your data for additional specific purposes.
5.4.2. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time (to find out what to do in this case, please refer to section 11.9.), but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.
6. Who We Share Your Data With
6.1. We share information we collect about you in the ways discussed below and only when necessary for the performance of a contract with you, compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties.
6.1.1. Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services.
6.1.2. Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests.
6.1.3. External Moderators and Testers: some limited data about you (such as your nickname, IP-address) may become available to third-party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games.
6.1.4. Developers of the Game Software: for the purpose of developing and supporting the Game Software, we may share your nickname, e-mail, IP-address and some other information with third-party developer companies.
6.1.7. Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you and that cannot reasonably be used to identify any individual user, for instance to show trends about use of the Services. We may also allow our third party advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
6.1.8. Publicly available information: our Sites may offer publicly available chats, forums and blogs that are viewable by others. Please note that you post publicly available information at your own risk. We are not liable for any information that you voluntarily choose to be public through such and/or other explicit actions. You should be aware that any information you provide on these communication services —including your Account information — may be read, collected, and used by any member of the public who accesses these communication services. Your posts and certain Account information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as specified below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to, and why.
7. International Data Transfers
7.1. Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
7.1.2. International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Russia and allow access to that information from countries in which our owned or operated companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our customers and users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.
8. Data Retention
8.1. We retain your data for as long as your account is active, or as long as is needed to provide you with the Service. We will periodically de-identify unused game Accounts, and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
8.2. Content you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Services. For example, we continue to display messages you posted on the forum, and continue to display content you provided.
8.3. Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.
9. Security Safeguards
9.1. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
10. Age Limits
10.1. We do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under the age of 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
11. How To Exercise Your Personal Data Rights
11.1. You have certain choices available to you when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
11.2. You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.
11.3. Your requests and choices may be limited in certain cases, such as when fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
11.4. Access Your Data (Right of Access): Upon your request, we will provide you with a copy of your personal data in a structured, electronic format.
11.5. Change or Correct Your Data (Right to Rectification): You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
11.6. Delete Your Data (Right to Erasure): In certain territories (including the European Union) you can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and game-related information linked to the Account, subscriptions to forums, and the possibility to access other services for which you are using the Account. Please note that once your Account has been deleted, you will lose your gaming experience and all Digital Content.
11.7. Request That We Stop Using Your Data (Right to Object): In certain territories (including the European Union) where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims.
Opt-Out of Direct Marketing:
You can opt-out of receiving any direct marketing communications that we may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting. To opt-out of interest-based advertising on mobile applications please check the privacy settings of your Android or iOS device and select "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android).
To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.
You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
11.8. For European Union users only. Data Portability: Data portability is the ability to obtain some of your personal data in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
11.9. You may withdraw consent where processing of your personal data is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
11.10. We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.
12. Contact US
12.1. If you have any questions about how your personal data is collected, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at:
APL Publishing Ltd.
Address: 60/2, Melita Street, Valletta VLT 1122, Malta
Contact E-Mail: firstname.lastname@example.org