READ IT CAREFULLY PRIOR USING THE SOFTWARE. YOU ARE FREE TO DECLINE THIS PRIVACY POLICY AND IF YOU DO SO, PLEASE, DO NOT USE THE SOFTWARE AS IT OTHERWISE WOULD MEAN THAT YOU ARE CONSENT TO THIS PRIVACY POLICY.

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Last Updated and Effective: August 30, 2021

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We may ask your explicit consent for processing your personal data if it is necessary in your data region, but make sure that you fully understand which data we process.

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1. Introduction

Individual Entrepreneur Grigoryev Ivan Mihaylovich (reg. number: 318784700340439)(“IG”, “We”) provides software applications, games, serices and websites (Products). At IG the privacy and security of our Users are of paramount importance. IG is committed to protecting the data you share with us. This privacy policy explains how we processes information that can be used to indirectly identify an individual (“Personal Data”) collected through use of its Products.

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For the purposes of this policy, IG defines the term “User” (“You”) as an individual with which IG  has an established relationship and who has accepted user agreement.

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Any information stored on the IG platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. IG implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

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2. Collection and use

 

PERSONALLY IDENTIFIABLE INFORMATION (PII)

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IG collects personally identifiable information (“PII”) when you choose to provide it to us. PII is any information that specifically identifies or locates a particular person or entity. We receive and store certain types of PII. The types of PII collected may include:

• IP address

• your email when you contact us via email

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IG uses this information for reasonable business purposes, including to contact you to respond to your inquiry, to provide the service requested. We may share Client PII with partners as necessary to improve the Service.

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Once obtained, IG will store your PII for as long as needed to provide services and for a reasonable time thereafter for record keeping purposes.

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IG may collect, record and analyze information of Users to its Products. IG may add information collected by way of pageview activity. If you provide IG with your social media details, IG may retrieve publicly available information about you from social media. We DO NOT collect, store or operate any information about: age, gender, political thoughts, religious beliefs, phone number etc, even if User would like to share such information with us directly.

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NON-PERSONALLY IDENTIFIABLE INFORMATION

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IG also collects non-personally identifiable information (“Non-PII”) from our Products. Non-PII is pseudonymous information that cannot by itself be used to specifically identify a particular person or entity, and may include your purchases, completed tasks or quests, your in-product achievement, ranking score, length of time spent using Products, actions performed within our Products, statistics, smartphone type and model, screen resolution and ID, usage habits, the time/date of your visit to the Products and your device’s operating system and its version.

 

We may use a third-party analytics provider to help us collect and manage this data (check out our third party services). We use this information to help manage and improve the Products.

 

By using our software, you consent to the collection and use of your non-personally identifiable information.

If you don’t want us to keep and process such information, please contact us directly to delete any of your records, accounts and all the data we collected about you. You may not use our products after that. You cannot reverse this action and no refunds would be applicable.

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Basis of processing PII

 

The basis for processing PII is a contract between User and IG (user agreement). IG uses the collected data to communicate with Users, to customize content for Users, to show ads of other Products to Users and to improve its Products by analyzing how Users navigate our Products.

 

Sharing PII/non-PII

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IG may also share such information with third-parties in order to provide a requested service or transaction or in order to analyze the User behavior on its Products.

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We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to IG or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

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Ads and Third-Party Services

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We may use third-party services and applications to perform Product-related services or to assist us in analyzing how our Product is used.

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Please be aware that while using our Products, Users can follow links to other sites and/or software applications that are beyond our sphere of influence. IG is not responsible for the content or privacy policy of these other sites and/or software applications. For information on how our selected third parties may use your information, please see their privacy policies:

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• Google Play Services

• IronSource

• AppLovin

• Amplitude

• ChartBoost

• AdColony

• Google

• Firebase Analytics

• Facebook

• DevToDev

• GameAnalytics

• Unity

• Appsflyer

• Pangle

• Vungle

• TapJoy

• InMobi

 

Collection of User data

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During a User’s registration, you provide information such as an Identification Data (ID) collected from the service provider, such as Google Play or App Store and other platforms where our Products are located. This information is used by IG to identify the User and provide them with support, services, mailings, sales and marketing actions and to meet User License agreement obligations.

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Please, pay attention, you cannot use our Products without having an authorised account in Google Play, App Store or any other platforms where our Products are located.

IG Users can at any time reach out with a request to edit, delete and update personal data. IG will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

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Products Users

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If you are a user of our Products, then this section is relevant for you. By using our software, you consent to the collection and use of your PII as described herein. If required by applicable law, we will seek your explicit consent to process PII collected on these Products or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your PII, the use of the Products may be subject to restrictions.

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3. What Happens In The Event Of A Change Of Control

 

We may buy or sell/divest/transfer Products (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Optimizely Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via in-game chat and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

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4. Geographical location

 

IG offers a number of data regions. A IG “Data Region” is a set of data centers located within a defined geographical area where User data is stored. Personal Data is not transmitted between Data Regions. For IG Users with accounts located in IG European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in Data center in the USA . For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.

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5. Processing and collection

 

Processing in the European Economic Area (EEA)

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For Users with accounts located in IG European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and IG processing comply in accordance with the GDPR.

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Controller

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IG processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR: The IG entity which you as a User entered an agreement with when using IG platform, will be the Controller for User data, as outlined above in “Collection of User data” section. IG adheres to the GDPR. Consequently, IG processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by IG Users through Products will be stored exclusively in secure hosting facilities. IG has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

 

Processing in the United States Of America (US): For Users in the l US Data Region, IG processes data solely in data centers located in the USA. IG has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in IG possession. IG will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

 

Processing in Canada: For Users with accounts in the IG Canada Data Region, IG processes data solely in data centers located in Canada. IG has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in IG possession. IG will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

 

Processing in other regions: For Users with accounts in our Asian Pacific Data Region, IG has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in IG possession. IG will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

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6. Retention and deletion

 

IG will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Respondent data, IG Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Respondent data, Users with an active account will therefore have the responsibility to delete data when required. When a user’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.

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7. Acceptance of these Conditions

 

We assume that all Users of our Products have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our Products. We reserve the right to change our privacy policy as necessity or law dictates. Continued use of IG Products after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

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8. Complaints

 

IG is responsible for matters relating to privacy and data protection. Our privacy protection can be reached at the following address:

• Individual Entrepreneur Grigoryev Ivan Mihaylovich, reg. num. 318784700340439

• address: 199226, NAHIMOVA STR. 20-369, ST. PETERSBURG, RUSSIA

• Dedicated email: eventhorizonpublishing@gmail.com

If you have any further questions regarding the data IG collects, or how we use it, then please feel free to contact us by email or in writing at the provided address.