Effective Date: 25th May, 2018
- The ways we collect your personal data and why we do so;
- Who and how use your personal data;
- Your rights about your personal data we collect.
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly.
Name of the controller: QUMARON SERVICES LIMITED
Address: Cyprus, Nicosia, 41-43 Klimentos,
Klimentos Tower, Flat/ Office 25
1. WHAT DATA DO WE COLLECT
Data you provide us:
- Contact information (such as name and email address);
- Player name (nickname);
- Information from a profile on social networks with which you are authorized in the game or which are linked to your account in the game (such as profile photo);
- Your messages to the Service (such as chat logs and player support tickets);
- Information about purchases made in the application (which purchase was made by the user, purchase price, currency of payment);
- Other data you choose to give us (such as data to identify a lost account).
Data we collect automatically:
- Data about your account and game progress;
- Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
- Data about your device, such as device name and operating system, browser type and language;
- Data we collect with cookies and similar technologies (see more below);
- General location data;
- Precise geo-location data (GPS, with your consent);
- Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service.
Data we collect from our partners:
- Data we receive if you link a third party tool with the Service (such as Facebook, WeChat or Google);
- Demographic data (such as to determine the coarse location of your IP address);
- Data to fight fraud (such as refund abuse in games or click fraud in advertising);
- Data from platforms that the games run on (such as to verify payment);
- Data for advertising and analytics purposes, so we can provide you a better Service.
2. WHY DO WE COLLECT YOUR DATA
We collect the above data solely to ensure the stable operation of the Services, to improve the applications themselves and to ensure security.
Stability of work. To maintain the stable and proper operation of the Services, we process the data necessary to:
- Create accounts and allow you to play our games and use our Service;
- Operate the Service;
- Verify and confirm payments;
- Provide and deliver products and services you request;
- Send you Service-related communications;
Services personalization. To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to:
- Update and develop player profiles;
- Develop and improve the Service and player experience;
- Manage our relationship with you;
- Provide social features as part of the Service;
- Customize your Service experience;
- Respond to your comments and questions and provide player support;
- Provide you Supercell offers in the Service as well as in other websites and services, and by email;
- Send you related information, such as updates, security alerts, and support messages.
Security and quality of Services. Our main priority is the provision of uniform rules for all within the framework of the Services. In order to ensure the safe, conscientious and qualitative provision of the Services and their functions, in order to combat fraud and ensure acceptable other use, we have a legitimate interest to process necessary data to:
- Analyze and monitor use of the Service and its social features;
- Moderate chats either automatically or manually;
- Take action against fraudulent or misbehaving players.
Analysis. In all of the above cases and purposes, we may analyze, profile and segment all collected data.
3. WHO CAN SEE YOUR DATA?
In addition to the Company, including Company employees from the relevant departments (marketing, technical, support, etc.) in certain situations, your data can be accessed by others in the following situations:
- Other players and users.
- Other players and users may, for example, see your profile data, in-game activities, your results in the high score etc.
- Partners working for company.
- The Company has partners to perform services for us. These partners process your data only at and according to Supercell´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
- Other companies and public authorities.
- In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
- We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
- Advertising and Social Media partners.
- The Services includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
4. INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
5. YOUR RIGHTS AND OPTIONS
Right to opt-out of marketing emails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Right to opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).
Right to access the personal data we hold about you.
If you request, we will provide you a copy of your personal data in an electronic format.
Your other rights.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. All of the above actions can be performed by contacting our support team. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings. We will respond to all requests within a reasonable timeframe, but not more than 30 days.
6. COOKIES AND SIMILAR TECHNOLOGIES
7. HOW DO WE PROTECT YOUR DATA
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. For example, for security reasons, all data is stored on servers with limited access located in Germany, and the data itself is transferred to the server via a secure protocol. However, you should understand that in the world, there are no 100% safe systems and despite all the measures taken by the Company there is a possibility of unauthorized access to your information. Using the Services or providing us with data, you understand and accept this risk.
We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. AGE LIMITS
We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, 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 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, 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 13, please contact us.