PRIVACY POLICY

Last updated: 19 November 2024

This privacy policy explains how we (“Promedia Studio”) collect and process your personal data when you access and play our application (“app”).

The scope of this Privacy Policy is limited to the personal data collected by you using our application and services.

The application may contain links to external sites. Clicking on a third-party link will redirect you to that site. Please note that we have no control and responsibility for the content and Privacy Policies of third-party sites or services.

1. Your consent

By installing and accessing the application on your mobile device, you consent to the terms and conditions set in this Privacy Policy and to the possible collection and processing of your data as described.

PLEASE NOTE – if you do not agree or if you are under the age of 16, you must not install, access or use the application.

If you are under the age of 18, please ensure that your legal guardian has reviewed and agreed to this Privacy Policy.

2. Information and data we may collect

We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including on web and mobile), and information collected from other sources, like social networking sites and gaming partners. Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws.

We may collect and process the following personal data and information when you using our application:

Data automatically collected

Device type and model, manufacturer, operating system platform and version, broad location (region, country, city), application version, game play status (stage start, end, and operation information).

IP address and Advertising ID (for Apple devices, IDFA and for Android devices, AAID).

Information you might provide when contacting us

Contact information such as your name and email address, and any other information needed to provide support.

Data obtained from advertising partners

We may obtain personal information about you from third-party advertising partners, depending on the permission you give to the partner.

Collecting of special categories of personal data

We do not knowingly collect any special categories of personal data (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) or personal data relating to criminal convictions and offences or related security measures when providing applications and services.

There are two types of information which may be processed about users of our application:

  1. Non-identifiable anonymous information (Non-personal information) – may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. We and third parties do not know the identity of the user from whom non-personal information has been collected. Non-personal information is any information which is available to us and/or our third parties through use by players of the app.
  2. Individually identifiable information (Personal information). This information may identify an individual and/or may be of a private and/or sensitive nature.

3. Purpose for the collection and use of information

Generally, in order to properly provide sustainable game services, it is necessary to collect and use player information and data. We use your information to fix game errors, to improve stability, to develop new features and provide a better experience. We may also use the information when sending notifications, including app updates, support and management messages.

We may collect and use your data and information for purposes presented below.

Non-personal information can be collected in order to:

  • Measure traffic and usage on app and promote the app.
  • Use it for analytical and business purposes, for customization, development and improvement of our application, analyzing and fixing problems, developing new offerings, providing better content, improving the user experience based on behavior and preferences shown by users within the app.

Personal information can be collected in order to:

  • Personalize and enhance the users’ experience while using the app.
  • Provide personalized content and information, including customized ads, interest-based ads, targeted ads.
  • Enable certain ad serving features, such as frequency capping.
  • If applicable, to enable certain functionalities within the app, such as Game Center Features, Social Features and features which are available while using the “Log in” option.
  • Provide users with updated information regarding our products and services, including about competitions which we may hold and to allow users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements).
  • Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the user.

4. Sharing your information

We may share your information with partners for the purposes described above.

We may disclose your information in response to law, legal process, lawsuits, and the demands of public and governmental authorities inside and outside your country of residence.

We may disclose your information to public authorities if we believe necessary to protect and challenge the legal rights of us, our customers and partners, and to exercise our legal rights in accordance with relevant laws.  We will not notify you of such disclosures unless required by law.

We may share your information with the following partners to improve our app and provide tailored advertising.

Google: https://policies.google.com/privacy

Firebase: https://firebase.google.com/support/privacy

Unity: https://unity3d.com/legal/privacy-policy

Meta: https://www.facebook.com/privacy/explanation

AppLovin: https://www.applovin.com/privacy

TapJoy: https://www.tapjoy.com/legal/#privacy-policy

ironSource: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy

Vungle: https://vungle.com/privacy/

Mintegral: https://www.mintegral.com/en/privacy

Smaato: https://www.smaato.com/privacy/

InMobi: https://www.inmobi.com/privacy-policy/

Pangle: https://ad.oceanengine.com/union/media/privacy

MoPub: https://www.mopub.com/legal/privacy

AdColony: https://www.adcolony.com/privacy-policy/

Tiktok: https://www.tiktok.com/legal/privacy-policy

5. Ads

We accept and display ads in various formats (banners, interstitial, rewarded videos, etc.) from third party ad networks which may be displayed in our application. These third party ad networks may collect and use: information about your visits to our application in connection to marketing, sales and advertising activities; geographic tracking and carrier network preferences; information such as age, gender and other information logged from your device to ensure that appropriate advertising is presented within the app, to calculate or control the number of views of an ad, to deliver ads relating to user’s interests and to measure the effectiveness of ad campaigns. 

The delivery of ads may be based on IP address, device identifiers and other information gathered during your use of the app. You may also be presented with contextual or non-targeted ads (ads which are not directed towards specific users). 

If you chose to receive contextual or non-targeted ads only within our app, please be aware that you may still see some targeted ads served by third parties if you have separately (e.g. on that third party’s website or app) agreed to personalized advertising directly to those third parties. We recommend that you review the terms of use and privacy policy of any third party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

We may promote the application in third party applications and platforms. In addition, we may, at our discretion, advertise our other apps within the application. Such advertisements are not directed towards specific users.

6. Cookies

When you access or use the app, we and/or our third parties may use industry-wide technologies such as “cookies”, web beacons, tags and local storage (or other similar technologies), which store certain local information on your device to identify a user’s device and ‘remember’ information about the user which may enable automatic activation of certain features, monitoring of use of the app (counting users who visit certain pages, use certain tools, viewed certain advertisements), frequency capping, to improve the quality of our services, measure ad performance, provide relevant ads etc. and making the user’s app experience and usage simpler, more relevant, convenient and effortless. Such information can be locally stored in the user’s device. 

We and/or our third parties may access such information. Third parties may use both session cookies (which expire once you close the app) and persistent cookies (which stay on the user’s device until he/she deletes them). Such local storage used by the app may store non-personal information (such as the different pages viewed by a user within the app) as well as user persistent identifier and geo-location data, which will be collected in accordance with the specified terms. 

It is easy to prohibit or delete the local storage, including through uninstalling the app from your mobile device or through the Settings option of your device. Most browsers and platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the local storage option you may use the settings option of your device or according to the specific instructions provided by the technology provider or third parties privacy policies and terms of use.

7. “Do not track” and opt-out of certain third parties’ interest-based services

Any user may prevent or limit targeted advertising from the device settings which may vary from device to device. You can find the applicable settings for your device by following the instructions below. Please note that activation of any applicable “Do-not-track” settings on the user’s mobile device or any other device-level setting opt outs for targeted advertising may not cease all tracking activities by our third parties’ service providers.

If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such third parties and follow the instructions specified there.

Electing to opt-out will not stop advertising from appearing in your browser or applications, but may make the ads you see less relevant to your interests, and the companies you select may still collect information for other purposes, such as research, analytics, and internal operations. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choice.

iOS Device

  • iOS device with iOS 7 or a newer version (up to iOS 14): go to Settings/Privacy/Advertising and select resetting advertising identifier or limiting ad tracking setting.
  • iOS device with iOS 14 or a newer version: go to Settings/Privacy/Tracking and disable tracking across all apps on your device or on a per App basis.

If you gave permission to be tracked in a particular app on a device with iOS 14 or newer, you can withdraw your tracking permission from settings by tapping on the particular app and turning off Allow Tracking. You can also limit targeted advertising by Apple within your device settings in Settings/Privacy/Apple Advertising settings.

Android Device

  • Google Android device with Android 2.3 or a later version, go to Settings/Google/Ads and enable “Opt out of ads personalization”.

8. User rights under GDPR

If you are under GDPR or the equivalents, you have the following rights regarding the processing of personal data:

When exercising the following rights, you can send a request to the contacts listed in the “Contact” section. We may ask you to provide certain information in order to identify and correct your data.

Right to withdraw consent

You have the right to withdraw your consent at any time in accordance with Article 7, paragraph 3 of the GDPR.

You can opt out of interest based advertising at any time by accessing the Settings section of the application. Please note that this will not change the number of ads you are seeing. The ads will not be targeted using information that we hold about you and will be less relevant to you. The withdrawal of this consent cannot affect the legality of the treatment based on the consent before the withdrawal.

Right of access and rectification

You have the right to receive confirmation as to whether or not personal data is being processed, and, where that is the case, access to the personal data in accordance with Article 15 of the GDPR.

You also have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you in accordance with Article 16 of the GDPR.

Right of erasure and restriction of processing

In accordance with Article 17 of the GDPR, you have the right to obtain from us the erasure of personal data concerning you without undue delay.

You also have the right to restrict the handling of personal data in accordance with Article 18 of the GDPR.

However, if your personal data is legitimately used to provide our services and for other purposes, we may reject your request or ask you to postpone the response.

Right to data portability

In accordance with Article 20 of the GDPR, you shall have the right to receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us to which the personal data have been provided.

You have the right to have the personal data transmitted directly from us to another, where technically feasible.

Right to object

In accordance with Article 21 of the GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.

Transferring of your data

We may transfer and process your personal data from your country or region of residence to other countries around the world. We may share your information with international organizations as partner. Please note that these countries and jurisdictions may not have the same data protection laws as your country.

9. Children’s personal information policy

This application is not intended for users under 16 years of age.

However, we cannot determine if the personal information sent is for persons under 16 years of age. We do not knowingly collect personal information from anyone under the age of 16.

10. Contact

Contact information

If you have any questions or concerns regarding this privacy policy, including to exercise any of your rights, you can contact us at the following email address: pstudio.ro@gmail.com.

You can also write to us at: Promedia Studio SRL, Basarabi 11A, Valu lui Traian, Constanta, Romania.