Effective Date: 22 December 2020

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

This Privacy Policy applies to all of our games, websites and related services, collectively referred here as our Services. Your continued use of the Services after the effective date will be subject to new Privacy Policy.
Please read the following to learn more about how we use your personal information.

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), “Perfect Play” LLC (referred to as the “Company”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.

If you have any questions or concerns about this Privacy Policy, including those related to exercise any of your rights, please contact us through the game’s Help & Support so we can reply to you more quickly.

The data controller: “Perfect Play” LLC
Email: legal@perfectplaystudio.com
Address: floor pod. pom. 1, apart. 1 house 13, building 1, Shipok street, Moscow, Russia, 11505

2. SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) from you directly (through the game, website or online forms); and/or

b) from third parties, service providers that are assisting us in providing you with a service, or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google etc.).

3. PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our existing or prospective individual customers related to users of our Services:

a) Contact information (such as name or nickname or email you submit as part of your register for our Services or log-in or via social networks);

b) Data about your account and game progress, we create a specific ID for you when you use the Services;

c) Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);

d) Data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language;

e) Broad location data (e.g. country or city-level location);

f) Precise geolocation data (GPS, with your consent);

g) Data (such as your nickname, profile picture) we receive if you link a third party tool with the Service (such as Facebook, Google or Weibo);

h) details of orders (amount spent, date, time, vouchers or offers used);

i) Data to fight fraud (such as refund abuse in games or click fraud in advertising);

j) Data from platforms that the games run on (such as to verify payment);

k) Data for advertising and analytics purposes, so we can provide you a better Service;

l) Your messages to the Services (such as chat logs and player support tickets) any feedback you submitted about your experience with us; and/or

m) Other data you choose to give us.

4. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to: Our lawful basis for doing so is:
Provide you with our products or services (for example, play one of our online games and make online purchases) Contract
We may use your personal data to: Our lawful basis for doing so is: Our legitimate interests in doing so are:
Establish and manage our relationship (this covers making your experience with us personalised, dealing with complaints or maintaining your account with us) Legitimate Interest Account Management
Management Reporting
Exercise or defend legal claims
Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us) Understand the market in which we operate
Management Reporting
Security (ensuring confidentiality of personal information or preventing unauthorised access and modifications to our systems) Managing security, risk and fraud prevention
Management Reporting
Let you know about our products, services and events that may be of interest to you by email or other forms of electronic communication Promote our goods and services
Management Reporting

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in section 1.

Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, 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 16 may provide any personal data. If we learn that we have collected personal data about a child under age 16, 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 16, please contact us.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH

We do not sell your personal data to third parties.

Our Partner Organisations and Service Providers
We may disclose information about you to organisations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

a) technical support providers who assist with our website and IT infrastructure,

b) third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;

c) professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;

d) providers that help us generate and collate reviews in relation to our goods and services;

e) our advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or

f) service providers that assist us in providing our services.

Law enforcement or government bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

7. YOUR RIGHTS

You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data.

We do not carry out any decision-making based solely on automated processing, including profiling.

If you gave us your consent to use your data, e.g. so that we can send you marketing emails or display personalised ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.

If you would like to exercise any of your above rights, contact us using the contact details in section 1 above.