Privacy Policy
This Privacy Policy document (hereinafter referred to as the “Policy”) represents the rules for the use of the User's personal information by Touchgames Limited Liability Company and its affiliates (hereinafter referred to as the “Copyright Holder”, “we”, “us” or “our”).
1. General Provisions
1.1. This Policy is an integral part of the License Agreement (hereinafter referred to as the "Agreement") posted and/or available on the Internet on the web address: https://playinmobile.com/agreement, as well as other documents referring to it, including the documents posted on the Websites and in the Applications.
1.2. By visiting and using the Websites on the domains Удивительная Ферма (mferma.ru), Братва (bratki.mobi), Доценты (hata.mobi), В Тени (vten.ru), Танки: Стальной Легион (sleg.mobi), Лорды (lords.mobi), Риальные Пацаны (pacan.mobi), Пушистики (pusiki.mobi), Флибустьеры (flibu.mobi), Poker Space (pokers.pro), Октагон (8gon.mobi), World of Shadows (shadowsgame.com), Amazing Farm (myfarm.games), including the Games and other services hosted on them, as well as by downloading, installing and using by means of the user device the downloaded (copied) software applications published by the Copyright Holder (hereinafter referred to in this Policy as the “Applications”), you freely, by your own will and in your interests, give written consent to the following methods of processing the Personal Information: collection, recording, systematization, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access) to third parties, including cross-border transfer to the territory of the foreign states, depersonalization, blocking, deletion, destruction for the purposes established by this Policy using automation tools or without using such tools at the Copyright Holder’s discretion.
We are not responsible for the actions of individuals with no relationship to the Copyright Holder or third-party companies, the content of their websites, the use of information or data you provide to them, or for any products or services they may offer. The links to those websites do not constitute that we are sponsors or affiliates of those individuals or companies.
If you do not want the Copyright Holder to process your Personal Information by using methods described in this Policy, you should not use the Websites and the Applications of the Copyright Holder.
1.3. This Policy, including the interpretation of its provisions and the procedure for its adoption, execution, amendment and termination, is subject to the legislation of the Russian Federation.
1.4. In the text of this Policy, the terms and definitions provided by the Agreement are used, unless otherwise provided by this Policy or follows from its essence. In other cases, the interpretation of the term used in the Policy is made in accordance with the current legislation of the Russian Federation, business customs or scientific doctrine.
2. Personal Information
2.1. The Personal Information in this Policy means:
2.1.1. The information, including the User's personal data, which the User provides about himself/herself when registering or authorizing on the Website and in the Application, as well as in the process of the further use of the Website and the Application, including subscribing (agreeing) to the distribution of information and advertising messages, participating in promotions , as well as when contacting the technical support service of the Copyright Holder through any communication channels, including telephone, feedback form on the Website, etc.
2.1.2. The data that are automatically transferred to the Website and/or the Application in an impersonal form, depending on the settings of the User's software, in the course of their use using the software installed on the User's device, including the IP address, cookie data, information about the User's browser (or another program through which the Website or the Application is accessed), the technical characteristics of the equipment and software used by the User, the date and time of access to the Website or the Application, the web addresses of the requested pages and other similar information.
2.2. The Copyright Holder has the right to establish requirements for the composition of the User's Personal Information, which must be provided for using the Website and the Application. To provide access to the respective services on the Website or in the Application, the Copyright Holder may provide an extended list of information to be provided by the User. If the certain information is not marked as mandatory by the Copyright Holder, its provision or disclosure is carried out by the User at his/her discretion.
2.3. When authorizing on the Website or in the Application using authentication services used by social networks such as Facebook, VKontakte, Odnoklassniki and others, these services can provide the Copyright Holder with the information about the User, including the Personal Information, inter alia the User's identification number (ID), the link to the User's profile on a social network, list of friends on a social network etc.
2.4. With the permission of the User, the Copyright Holder also collects accurate geolocation data from the User.
2.5. The Copyright Holder collects and processes the following data about the User's interaction with the Website, the Application or other Users:
- The information about the time, methods, duration of the use by the User of the resources of the Website and the Application, the data flow and records of screen elements that the User accesses in the process of using the Website and the Application (the so-called "Visit History");
- The registration files (logs) and statistical data on the actions of the User on the Website and in the Application;
- The technical information about devices and operating systems and other software that the User uses in the process of visiting and using the Websites and the Applications, namely the information about the means of access control to the media (Media Access Control, MAC), mobile device identifier (IDFA (it is collected only when accessible), Google Advertising ID or other identifiers), the IP address of the user device and the information about the browser used, as well as the information necessary to detect, investigate and prevent actions that violate the provisions of the Agreement.
2.6. The Copyright Holder does not check the accuracy of the Personal Information provided by the User and whether the User has the necessary consent to its processing in accordance with this Policy, believing that the User acts in good faith, prudently and makes all necessary efforts to maintain such information up-to-date and obtain all the necessary consents of personal data.
2.7. The User understands and accepts the possibility of using third-party software on the Website of the Copyright Holder, as a result of which such persons can receive and transmit the data specified in the Clause 2.1.2. in an impersonal form.
The specified third-party software includes the visit statistics collection systems:
- Google Analytics (their privacy policy is available at https://policies.google.com/privacy);
- Yandex.Metrica (their privacy policy is available at https://yandex.ru/legal/confidential/);
- AppMetrica (their privacy policy is available at https://yandex.ru/legal/confidential/);
- Firebase (their privacy policy is available at https://firebase.google.com/support/privacy).
The composition and conditions for collecting anonymized data using third-party software are determined directly by their copyright holders and may include:
- Browser data (type, version, cookie);
- Device data and its location;
- Operating system data (type, version, screen resolution);
- Request data (time, referral source, IP address).
2.8. The Copyright Holder is not responsible for the procedure for using the User's Personal Information by third parties with whom the User independently interacts within the framework of using the Website and the Application.
3. Purposes of Processing the Personal Information
3.1. The Copyright Holder carries out processing, including the collection and storage of only that Personal Information that is provided by the User in the manner and on the conditions provided for in this Policy, is necessary for the conclusion and execution of the Agreement, the Partnership Agreement and other agreements concluded between the Copyright Holder and the User, if this is directly provided for by their terms.
3.2. The Copyright Holder has the right to use the Personal Information for the following purposes:
3.2.1. The conclusion and execution of the Agreement and other agreements with the User, proposed for conclusion on the Website or in the Application, or concluded on the basis of an offer posted on the Website or in the Application, including the offers posted by the Copyright Holder on the Website or in the Application.
3.2.2. The User’s identification as part of the fulfillment of obligations under the Agreement and other agreements concluded between the Copyright Holder and the User.
3.2.3. The fulfillment of obligations under the Agreement and other concluded agreements, including providing the User with access to the Website and/or the Application, as well as technical support.
3.2.4. Providing communication with the User under concluded agreements for the purpose of information services and improving the quality of the Websites and the Applications, including through notification and with the involvement of third parties.
3.2.5. Conducting marketing, statistical and other research based on anonymized data in order to improve the quality of the Websites and the Applications.
Anonymized data from Google Analytics, Yandex.Metrica, AppMetrica and Firebase are collected and analyzed to find out how much time the Users spend on various pages of the Websites and in the sections of the Application, their interests and preferences. In addition, the cookies transmitted by the Website or the Application to the User's equipment and the cookies transmitted by the User's equipment to the Website or the Application, can be used by the Copyright Holder to provide the User with personalized services and opportunities for using the Website or the Application, to target advertisements and information materials that are displayed to the User, in statistical and research purposes, as well as to improve the Website and the Application.
3.2.6. Distribution, including automated distribution, among the Users of information and advertising materials of the Copyright Holder and/or third parties.
To the extent advertising is displayed on the Website or in the Application, advertising networks of our affiliates and partner networks may collect and use anonymized information, in particular, the information about the User’s activity on the Website and in the Application, the information about the means of access control to the media (Media Access Control, MAC), mobile device identifier (IDFA (it is collected only when accessible), Google Advertising ID or other identifiers), the information about the browser used, geolocation data from the User, language settings and the IP address of the user device. It enables them to serve targeted ads to the User.
4. Requirements for the Protection of the Personal Information
4.1. The Copyright Holder stores the Personal Information and ensures its protection from unauthorized access and distribution in accordance with internal rules and regulations.
4.2. With regard to the User's Personal Information, its confidentiality is maintained, with the exception of publicly available data and other cases when the functionality of the Website, the Application or the settings of the software used by the User provide for an open exchange of information with other participants and users of the Internet.
4.3. In order to improve the quality of the Websites and the Applications, the Copyright Holder has the right to store log files about the actions performed by the User within the framework of the use of the Websites and the Applications, as well as in connection with the conclusion and execution of the Agreement and other agreements by the User on his/her part, for 6 (six) months.
5. Transfer of the Information
5.1. The Copyright Holder has the right to transfer the Personal Information to third parties in the following cases:
- The User has expressed his/her consent to such actions, including the cases when the User applies the settings of the software used that do not limit the provision of certain information;
- The transfer is necessary as part of the User's use of the functionality of the Website or the Application;
- The transfer is required for the conclusion and execution of the Agreement and other agreements between the Copyright Holder and the User using the Website and/or the Application;
- In connection with the transfer of the Website and/or the Application of the Copyright Holder into the possession, use or property of such a third party, including as part of the assets of the Copyright Holder, or the assignment of rights under agreements concluded with the User in favor of a third party, which is allowed without the consent of the User;
- At the request of a court or other authorized state body within the framework of the procedure established by law;
- To protect the rights and legitimate interests of the Copyright Holder in connection with the violation by the User of the Agreement or other agreements concluded with the Copyright Holder.
6. Specific Provisions for the Residents of the European Union
At any time, you may contact the Copyright Holder at privacy@playtox.ru in order to:
- request to access the personal data that the Copyright Holder holds about you. The Copyright Holder may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your personal account is not accurate, complete or outdated, then please provide the Copyright Holder with the necessary information to correct it;
- withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal;
- request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for the operation of the Websites and the Applications of the Copyright Holder or for other legitimate purposes, in which case we will let you know if we are unable to do so and what are the reasons for;
- receive your personal data that you have provided us in a structured, commonly used and machine-readable format and exercise the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others;
- ask questions about the processing of your personal data. We will process your request and make good faith efforts to resolve any concern you may have.
If you consider that the processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7. Policy Relating to Children
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Websites and Applications. If you are under 16, please do not send us any information about yourself, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us at privacy@playtox.ru.
8. Specific Provisions for California Consumers
These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (hereinafter referred to as the “CCPA”) provides additional rights to receive (“the right to know”), delete and opt out the Personal Information requires “businesses” collecting or disclosing the Personal Information to provide notice and a means to exercise those rights.
Categories of the Personal Information collected in the preceding 12 months are specified in the Clause 2. of this Policy.
Business purposes for processing, including the collection and storage of the Personal Information are specified in the Clause 3. of this Policy.
Third parties with whom we may share your information are specified in the Clause 2., the Clause 3. and the Clause 5. of this Policy.
For any of the Personal Information described above, you can request to know what Personal Information we collected, disclosed, used and sold, and at any time request that we delete your Personal Information.
To exercise your right to know and right to deletion, please submit a request by sending an email to privacy@playtox.ru with the subject “California Rights Request.” We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us with to the information we maintain about you in our system. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
Upon verification of your request, we will delete your Personal Information from our records (and direct our service providers to delete), unless retaining the information is necessary for us or our service providers to complete the transaction with you, detect security incidents or fraud, fixing errors, exercise free speech or another right provided by law, comply with legal obligations, or other internal and lawful uses.
The CCPA gives you a right to direct a business that sells your Personal Information to stop selling your Personal Information and to refrain from doing so in the future. We do not sell any of your Personal Information, and we will require our service providers not to sell your Personal Information.
You also have the right not to be discriminated against for exercising any of the rights listed above.
If you are a California resident seeking to exercise your rights under the CCPA or have any questions or concerns, please email us at privacy@playtox.ru. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf, and you successfully verify your own identity with us.
We aim to respond to a consumer request for data access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reasons and extension period in writing.
9. Change of the Personal Information
9.1. The User has the right at any time to independently edit (change, clarify, update) in his/her Personal Account on the Website or in the Application the Personal Information provided by him/her during registration or authorization.
9.2. In case of termination of the concluded agreement or refusal to use the Website or the Application, the User has the right to delete his/her own Personal Account by contacting the Copyright Holder at privacy@playtox.ru.
9.3. You may contact the Copyright Holder’s Data Protection Officer at privacy@playtox.ru.
10. Changes to the Privacy Policy
10.1. This Policy can be changed or terminated by the Copyright Holder unilaterally without prior notice to the User. The new version of the Policy comes into force from the moment it is posted on the Website of the Copyright Holder, unless otherwise provided by the new version of the Policy.
10.2. The current version of the Policy is posted on the Website of the Copyright Holder on the Internet on the web address https://playinmobile.com/privacy.
The version of the Privacy Policy as of June 4, 2021