Privacy policy
in force from 22 May 2018
Vivid
Games (hereinafter: "Vivid Games", "us", "our" or "we") is protecting
the privacy rights of our users ("users" or "you"). This Privacy Policy
(hereinafter: "Policy") lays out the rules or processing (i.e.
collecting, storing, using, and managing) users personal information,
and data that you provide or we collect in connection with any of our
services, websites or any Vivid Games game provided on a mobile platform
(we shall refer to all those services and games as “Software” in this
document). We shall refer to all the personal data and information you
provide to us or we collect as “Data” in this document.
All
use of Software is governed by this Privacy Policy and by using or
accessing the Software you give consent to the processing, use and
disclosure of your data. Please do not install or use the Software if
you do not agree to this Privacy Policy.
Not
all of the Data processing described herein will apply to you, as there
may be differences in processing practices in respect of some of our
Software (e.g. not all games include multiplayer or social network
features).
Why are we processing your Data?
We may process your Data under the following legal basis:- To
perform under a contract you enter into with Vivid Games which allow
you to use the Software (please check End User License Agreement and
Terms of Service). It is the basis of processing when we make the
Software available to you, provide customer support, integrate our
Software with your devices and distribution platforms such as Apple iOS
and Google Android and inform you of the Software related changes and
game progress.
- To pursue our legitimate interests such as
engineering, performing analysis of user behavior for future improvement
of our games and user experience as well as obtaining revenues from
your use of Software (direct payments as well as revenues from
advertisement) and successful marketing of our Software.
- To perform our legal obligations to process the Data, e.g. prevention of frauds or maintaining tax records.
- When the processing is not covered by the agreements, you provide your consent to such processing, when applicable.
In
general, the Data is essential to allow use of Software by end users.
The Data serves several specific purposes which are described both in
this Policy as well as in other documents disclosed to you, such as
Terms of Service and End User License Agreement which you have entered
into by using our Software. In particular, your Data may be used to:- Create game accounts and allow users to play our games;
- Save your game progress;
- Identify and suggest connections with other Software users;
- Allow to participate in leaderboards;
- Operate and improve our Software;
- Understand you and your preferences to enhance your experience and enjoyment using our Software;
- Respond to your comments and questions and provide customer service;
- Provide and deliver products and services you request;
- Deliver advertising and marketing and promotional information to you, including interest-based advertising;
- Send
you related information, including confirmations, invoices, technical
notices, updates, security alerts, and support and administrative
messages (if applicable);
- Communicate with you about promotions,
rewards, upcoming events, and other news about products and services
offered by Vivid Games and our selected partners;
- Enable you to communicate with other users;
- Enable you to take part in multiplayer games with other users;
- Conduct marketing;
- Link
or combine it with other information we get from third parties, to help
understand your preferences and provide you with services better
fitting your expectations;
- Allow statistical analysis of users’
preferences and behavior and adjust our Software to your preferences
based on such analysis.
We
shall process your Data as long as you are using our Software, however
some data may be stored after that period for technical, marketing and
statistical purposes.
What Data are we processing and how do we collect it?
There
are some Data which you provide to us voluntarily, such as Data
required to register an account (if applicable), to subscribe to
marketing communication, to take part in a contest or sweepstake or to
request help from our support. Such Data include your name, email
address and other contact details.
Other Data is collected automatically from you, your device and other services your are using. Such Data include:- Mobile
device identifiers (such as your unique device ID
(persistent/non-persistent, hardware type, international mobile
equipment identity ("IMEI");
- Your communications within the Software (e.g. in-game chats and messages with other players);
- Data
and analytics about your use of our Software (e.g. in-game play
progress, levels, games played, session length, preferred settings,
which in-game adverts you may have viewed, in-game references or just
game preferences, what friends you connect with, how you were directed
to our Software);
- Your IP address and device identifiers such as your Advertising ID, Device ID numbers;
- Your device type and the operating system that you use;
- Broad geographic location (e.g. country or city-level location) based on your IP address;
- GPS location (if you provide your consent to provide us with such Data).
Not
all of such data is immediately considered to be personal data under
applicable laws, however it may be regarded as such if it allows to
identify you in connection with other information.
The
Data which is collected automatically is necessary for us to operate
the Software. If you wish such Data not to be collected, you should not
install or use our Software. If you already did, please refer to Can you influence processing of your Data? section below.
We
also may receive some of your Data from Social Network Services you
participate in, especially when you connect to our Software using your
account registered in some of such Social Network Services (e.g.
Facebook). Such Data include:- your username;
- profile picture;
- age range;
- gender;
- your friends using the same Software.
We
may receive some of your Data from other third parties and advertising
partners, in particular when you were directed to our Software via
advertisement in other products.
Our
Software may contain third party tracking and data collection and
analytics tools from our service providers. Such third parties may use
cookies, APIs, and SDKs in our Software to enable them to collect and
analyze user and device related data and information on our behalf. The
third parties may have access to and collect data and information about
you, such as your device identifier, MAC address, IMEI, locale (specific
location where a given language is spoken), geo-location information,
IP address, application usage, access and session times, applications
present on the device or in use at a particular time on the device, and
your viewing of and interactions with advertising, for the purpose of
providing their services, including, for example, enabling, providing
and delivering advertising as described in further detail below.
The
privacy policies of our service providers may include additional terms
and disclosures regarding their data collection and use practices and
tracking technologies, and we strongly advise you to check such privacy
policies to learn more about their data collection and use practices, or
use of tracking technologies.
In
no instance we process any special categories of information, such as
information on your health, race, religion, political opinions or
philosophical beliefs, sexual preferences or orientation or any
information of similar categories. We do not require you to provide us
such information and we do not collect it automatically.
When
we collect Data we do not know the age of our players. In case a player
has a Facebook account and has logged in to a game, we will get the age
information from player’s Facebook profile information. If we learn
that we had inadvertently gathered Data from a child under 13 years of
age, we will take reasonable measures to promptly erase such personal
information from our records.
Third party advertisement
Advertisers
on mobile devices and our third party advertising and analytics
partners sometimes collect and use Advertising IDs to enable and
optimize advertising. Advertising IDs are non-permanent device
identifiers such as the Android advertising ID and/or Apple's ID for
advertising.
These
advertisers and third party advertising and analytics partners may
collect and use data and information about you, such as your Software
session activity, viewing of and interaction with an advertisement,
device identifier, MAC address, IMEI, geo-location information and IP
address for the purposes of analyzing, tracking and measuring
advertisement performance and to provide interest based advertising.
In
addition, you may see our games advertised in other services. After
clicking on one of these advertisements and installing our game, you
will become a user of our Software. In order to verify the installs,
a device identifier may be shared with the advertiser or third party
advertiser or analytics partner.
We
inform you of such aforementioned collection practices, however we are
not in control of data collected in such way, if you want to know more,
you should revise privacy policies of such third party advertisers.
A list of such third parties and links to their provacy policies is
available here.
Who may access your Data?
Within
our organization your Data shall be disclosed only to our personnel
which needs to know such Data for carrying out their work and shall be
subject to strict rules. We may disclose your Data to our affiliates
(companies controlled by Vivid Games) and their personnel. Apart
from that, third parties (such as advertising providers) may access
your data as described in this Policy. Such third parties may be located
outside the European Union or the European Economic Area, in particular
United States of America in accordance with applicable legislation and
this Policy. We
may use third parties to collect and process personal data on our
behalf and in according to our instructions. We are not liable for the
acts and omissions of these third parties, except as provided by law
provisions.
Can you influence processing of your Data?
At
any time you may request us to have access to your Data. You may
request the Data to be corrected. You may also request to erase your
Data, restrict the processing of your Data or object to such processing.
If we process your Data basing on your consent, you may withdraw such
consent at any time.
Please
pay attention however, that erasure of all your data may be technically
impossible if such data is connected with your accounts in other
services, in particular Social Network Services and mobile platform
operators.
Also
keep in mind, that use of the Software requires your Data to be
processed as described herein. If you do not accept processing of your
Data, you should cease using the Software. The data you provide is
necessary to perform the agreements you enter into with Vivid Games
which allow you to use the Software. If you object to processing of your
Data, request the Data to be erased or request that we stop processing
your Data, as a result you may not be (depending on the type of Data and
the type of Software) able to use the Software.
If
you withdraw your consent to processing of certain Data, you may not be
able to use full functionality of the Software or participate in some
activities, like contests.
Your Data may be portable upon your request, however possibility of transfer is technically limited.
If
you consider your rights to be violated or your Data processing rules
infringed, you are entitled to file a complaint with relevant
supervisory authority. Default authority for such a complaint is
Inspector General for Personal Data Protection (Generalny Inspektor
Ochrony Danych Osobowych) in Poland (soon to be replaced by a new
authority - Prezes Urzędu Ochrony Danych Osobowych), however you may
also lodge a complaint with any other personal data protection authority
in an European Union member state.
Controller
of the Data is Vivid Games S.A. You can contact us at
personal.data@vividgames.com or by means of phone +48 523 215 728 or
post: Ogińskiego 2, 85092 Bydgoszcz, Poland.Vivid Games is not considered
to be the controller of your Data, if it is collected by third parties
under their privacy policies. We recommend you to check such policies,
in particular in respect of your use of any Social Network Services,
where you provide the most of your Data, which is then transferred
elsewhere.
All requests concerning your Data should be sent to: personal.data@vividgames.com.
Vivid
Games (hereinafter: "Vivid Games", "us", "our" or "we") is protecting
the privacy rights of our users ("users" or "you"). This Privacy Policy
(hereinafter: "Policy") lays out the rules or processing (i.e.
collecting, storing, using, and managing) users personal information,
and data that you provide or we collect in connection with any of our
services, websites or any Vivid Games game provided on a mobile platform
(we shall refer to all those services and games as “Software” in this
document). We shall refer to all the personal data and information you
provide to us or we collect as “Data” in this document.
All
use of Software is governed by this Privacy Policy and by using or
accessing the Software you give consent to the processing, use and
disclosure of your data. Please do not install or use the Software if
you do not agree to this Privacy Policy.
Not
all of the Data processing described herein will apply to you, as there
may be differences in processing practices in respect of some of our
Software (e.g. not all games include multiplayer or social network
features).
Why are we processing your Data?
We may process your Data under the following legal basis:
- To perform under a contract you enter into with Vivid Games which allow you to use the Software (please check End User License Agreement and Terms of Service). It is the basis of processing when we make the Software available to you, provide customer support, integrate our Software with your devices and distribution platforms such as Apple iOS and Google Android and inform you of the Software related changes and game progress.
- To pursue our legitimate interests such as engineering, performing analysis of user behavior for future improvement of our games and user experience as well as obtaining revenues from your use of Software (direct payments as well as revenues from advertisement) and successful marketing of our Software.
- To perform our legal obligations to process the Data, e.g. prevention of frauds or maintaining tax records.
- When the processing is not covered by the agreements, you provide your consent to such processing, when applicable.
In
general, the Data is essential to allow use of Software by end users.
The Data serves several specific purposes which are described both in
this Policy as well as in other documents disclosed to you, such as
Terms of Service and End User License Agreement which you have entered
into by using our Software. In particular, your Data may be used to:
- Create game accounts and allow users to play our games;
- Save your game progress;
- Identify and suggest connections with other Software users;
- Allow to participate in leaderboards;
- Operate and improve our Software;
- Understand you and your preferences to enhance your experience and enjoyment using our Software;
- Respond to your comments and questions and provide customer service;
- Provide and deliver products and services you request;
- Deliver advertising and marketing and promotional information to you, including interest-based advertising;
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages (if applicable);
- Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Vivid Games and our selected partners;
- Enable you to communicate with other users;
- Enable you to take part in multiplayer games with other users;
- Conduct marketing;
- Link or combine it with other information we get from third parties, to help understand your preferences and provide you with services better fitting your expectations;
- Allow statistical analysis of users’ preferences and behavior and adjust our Software to your preferences based on such analysis.
We
shall process your Data as long as you are using our Software, however
some data may be stored after that period for technical, marketing and
statistical purposes.
What Data are we processing and how do we collect it?
There
are some Data which you provide to us voluntarily, such as Data
required to register an account (if applicable), to subscribe to
marketing communication, to take part in a contest or sweepstake or to
request help from our support. Such Data include your name, email
address and other contact details.
Other Data is collected automatically from you, your device and other services your are using. Such Data include:
- Mobile device identifiers (such as your unique device ID (persistent/non-persistent, hardware type, international mobile equipment identity ("IMEI");
- Your communications within the Software (e.g. in-game chats and messages with other players);
- Data and analytics about your use of our Software (e.g. in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, what friends you connect with, how you were directed to our Software);
- Your IP address and device identifiers such as your Advertising ID, Device ID numbers;
- Your device type and the operating system that you use;
- Broad geographic location (e.g. country or city-level location) based on your IP address;
- GPS location (if you provide your consent to provide us with such Data).
Not
all of such data is immediately considered to be personal data under
applicable laws, however it may be regarded as such if it allows to
identify you in connection with other information.
The
Data which is collected automatically is necessary for us to operate
the Software. If you wish such Data not to be collected, you should not
install or use our Software. If you already did, please refer to Can you influence processing of your Data? section below.
We
also may receive some of your Data from Social Network Services you
participate in, especially when you connect to our Software using your
account registered in some of such Social Network Services (e.g.
Facebook). Such Data include:
- your username;
- profile picture;
- age range;
- gender;
- your friends using the same Software.
We
may receive some of your Data from other third parties and advertising
partners, in particular when you were directed to our Software via
advertisement in other products.
Our
Software may contain third party tracking and data collection and
analytics tools from our service providers. Such third parties may use
cookies, APIs, and SDKs in our Software to enable them to collect and
analyze user and device related data and information on our behalf. The
third parties may have access to and collect data and information about
you, such as your device identifier, MAC address, IMEI, locale (specific
location where a given language is spoken), geo-location information,
IP address, application usage, access and session times, applications
present on the device or in use at a particular time on the device, and
your viewing of and interactions with advertising, for the purpose of
providing their services, including, for example, enabling, providing
and delivering advertising as described in further detail below.
The
privacy policies of our service providers may include additional terms
and disclosures regarding their data collection and use practices and
tracking technologies, and we strongly advise you to check such privacy
policies to learn more about their data collection and use practices, or
use of tracking technologies.
In
no instance we process any special categories of information, such as
information on your health, race, religion, political opinions or
philosophical beliefs, sexual preferences or orientation or any
information of similar categories. We do not require you to provide us
such information and we do not collect it automatically.
When
we collect Data we do not know the age of our players. In case a player
has a Facebook account and has logged in to a game, we will get the age
information from player’s Facebook profile information. If we learn
that we had inadvertently gathered Data from a child under 13 years of
age, we will take reasonable measures to promptly erase such personal
information from our records.
Third party advertisement
Advertisers
on mobile devices and our third party advertising and analytics
partners sometimes collect and use Advertising IDs to enable and
optimize advertising. Advertising IDs are non-permanent device
identifiers such as the Android advertising ID and/or Apple's ID for
advertising.
These
advertisers and third party advertising and analytics partners may
collect and use data and information about you, such as your Software
session activity, viewing of and interaction with an advertisement,
device identifier, MAC address, IMEI, geo-location information and IP
address for the purposes of analyzing, tracking and measuring
advertisement performance and to provide interest based advertising.
In
addition, you may see our games advertised in other services. After
clicking on one of these advertisements and installing our game, you
will become a user of our Software. In order to verify the installs,
a device identifier may be shared with the advertiser or third party
advertiser or analytics partner.
We
inform you of such aforementioned collection practices, however we are
not in control of data collected in such way, if you want to know more,
you should revise privacy policies of such third party advertisers.
A list of such third parties and links to their provacy policies is
available here.
Who may access your Data?
Within
our organization your Data shall be disclosed only to our personnel
which needs to know such Data for carrying out their work and shall be
subject to strict rules. We may disclose your Data to our affiliates
(companies controlled by Vivid Games) and their personnel.
Apart
from that, third parties (such as advertising providers) may access
your data as described in this Policy. Such third parties may be located
outside the European Union or the European Economic Area, in particular
United States of America in accordance with applicable legislation and
this Policy.
We
may use third parties to collect and process personal data on our
behalf and in according to our instructions. We are not liable for the
acts and omissions of these third parties, except as provided by law
provisions.
Can you influence processing of your Data?
At
any time you may request us to have access to your Data. You may
request the Data to be corrected. You may also request to erase your
Data, restrict the processing of your Data or object to such processing.
If we process your Data basing on your consent, you may withdraw such
consent at any time.
Please
pay attention however, that erasure of all your data may be technically
impossible if such data is connected with your accounts in other
services, in particular Social Network Services and mobile platform
operators.
Also
keep in mind, that use of the Software requires your Data to be
processed as described herein. If you do not accept processing of your
Data, you should cease using the Software. The data you provide is
necessary to perform the agreements you enter into with Vivid Games
which allow you to use the Software. If you object to processing of your
Data, request the Data to be erased or request that we stop processing
your Data, as a result you may not be (depending on the type of Data and
the type of Software) able to use the Software.
If
you withdraw your consent to processing of certain Data, you may not be
able to use full functionality of the Software or participate in some
activities, like contests.
Your Data may be portable upon your request, however possibility of transfer is technically limited.
If
you consider your rights to be violated or your Data processing rules
infringed, you are entitled to file a complaint with relevant
supervisory authority. Default authority for such a complaint is
Inspector General for Personal Data Protection (Generalny Inspektor
Ochrony Danych Osobowych) in Poland (soon to be replaced by a new
authority - Prezes Urzędu Ochrony Danych Osobowych), however you may
also lodge a complaint with any other personal data protection authority
in an European Union member state.
Controller
of the Data is Vivid Games S.A. You can contact us at
personal.data@vividgames.com or by means of phone +48 523 215 728 or
post: Ogińskiego 2, 85092 Bydgoszcz, Poland.Vivid Games is not considered
to be the controller of your Data, if it is collected by third parties
under their privacy policies. We recommend you to check such policies,
in particular in respect of your use of any Social Network Services,
where you provide the most of your Data, which is then transferred
elsewhere.
All requests concerning your Data should be sent to: personal.data@vividgames.com.