Effective Date: 11 August 2022
“POLYKIDS LAB” SRL (“Publisher” or “We”) is dedicated to protecting the privacy rights of our users (“Users” or “You”). This Privacy and Cookie Policy (the “Policy”) has been crafted to inform You as to the ways we collect, store, use, and manage the information You provide in connection with any Publisher website (collectively, the “Site”), or any Publisher game or application (the Site, games and applications are, collectively, the “Services”).
Please note that the scope of this Policy is limited only to information collected by Publisher through use of the Services. This Policy does not apply to the practices of third parties that Publisher does not own or control. Publisher offers its Services also to Users resident in the EU. Publisher is the data controller for personal information collected of those Users. Users who are resident in the EU may address questions relating to the way we collect, store, use and disclose their personal information either to Publisher at the address identified below, or to our representative at the following address Bucuresti, str. Feleacu nr. 3, bl. 11E, sc. 2, ap. 20, et. 1, sector 1.
By downloading and installing our Services or use our Site, You are invited to agree with this Policy and the processing of your data, including your personal information, also called personal data in some jurisdictions (we refer to this information/data collectively as “personal information” throughout this Policy), in the manner provided in this Policy. We therefore process your personal information based on your consent. In any event, any use of the Services will be construed as your agreement with this Policy. If You do not agree to these terms, please do not use the Services.
This Policy is merely informative about how Publisher collects, stores, uses and discloses your personal information. We are not asking You to consent to this Policy. If we require your consent we will ask for it in separate notice and consent forms. Please note that if You provide us with consent, you have the right to withdraw this consent at any time by contacting us at [email protected].
It is advised that You review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).
1.1. The purpose of this Policy is to ensure the appropriate protection of information about Users, including their personal data, from unauthorized access and disclosure.
1.2. Activities associated with the collection, storage, dissemination, and protection of User information are regulated by this Policy, other official documents of Publisher, and current legislation. We aim to minimize how much personal information we collect from Users when they use the Services.
1.3. The current version of the Policy, which is a public document, has been drafted by Publisher and is available to any Internet User at: https://polykids.de/privacy-app-en.html.
1.4. Publisher has the right to make changes to this Policy. When changes are made to the Policy, Publisher notifies its Users about it by publishing the new version of the Policy on the Site; the changes take effect from the date when the new version of the Policy is posted on the Site.
2.1. The processing of personal data is based on the following principles:
2.2. The collection of personal data. Personal data of the User is transferred to Publisher with the consent of the User.
2.3. Storage and use of personal data. Users’ personal data is stored exclusively on electronic media and processed using automated systems. How long we store your personal information will depend on the purpose that we originally collected it. We will not retain personal information for longer than is necessary for our business or for legal requirements.
2.4. Transfer of personal data. Users’ personal data is not transferred to any third parties, except in cases expressly provided for in this Policy. The provision of Users’ personal data at the request of state (local) government bodies is carried out in the manner set forth by law.
2.5. When you make in-app purchases in the applications (Paid Services), we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. Applestore or Google Play) or your platform’s payment processor.
3.1. Please note that third party partners/providers, such as analytics companies, may also use cookies or other technologies, and those partners are subject to their own policies.
3.2. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often You use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the mobile application.
3.3. Our Services may contain third party tracking tools from our partners. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze User information on our behalf. The third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their Services under their respective privacy policies. This Policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties. The following are third parties that we use for analytics:
4.1. Publisher processes information about Users, including their personal data, in order to fulfill Publisher’s obligations to its Users regarding the use of the Services.
4.2. Publisher can use personal User information for the following purposes:
5.1. We collect and process the personal information of Users on the following conditions:
| Personal Information | Purpose(s) | Who |
|---|---|---|
|
— e-mail address; — additional information provided by the User at the request of Publisher in order to fulfill the obligations of Publisher to the Users regarding the use of the Services. Specifically, Publisher has the right to request from the User a copy of an identity document or any other document containing the User’s name, surname and photo, as well as any additional information that, at the discretion of Publisher, will be necessary and sufficient to identify the User and allow it to prevent abuses and infringements on the rights of third parties |
Marketing and communications, Legal compliance | Publisher |
| IP address | Providing and improving, Research and analytics | Publisher, Yandex.Metriсa, Google Analytics |
| Information about your gender and age | Research and analytics | Google Analytics, Yandex.Metriсa, AdMob, Yandex Mobile Ads, Firebase Crashlytics, Firebase |
| Location information, which means general information about the location from which You’re using the Services (e.g. country, and city) | Providing and improving, Research and analytics | Google Analytics, Yandex.Metriсa, AdMob, Yandex Mobile Ads, Firebase Crashlytics, Firebase |
| Device information, which means technical information about your device. When we refer to device Information, this means your device ID, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your device, the language You’ve set for your device, the version of the application installed on your device, and the name of your carrier | Providing and improving | Google Analytics, Yandex.Metriсa, AdMob, Yandex Mobile Ads, Firebase Crashlytics, Firebase |
| Information obtained as a result of the actions of other Users via the applications (e.g. purchase / subscription, bugs and errors) | Providing and improving | Google Analytics, Yandex.Metriсa, Firebase Crashlytics, Firebase |
| Android Advertising ID | Used for advertising and user analytics | AdMob, Yandex Mobile Ads |
| Users interests | Research and analytics | Firebase |
| Cookie | Providing and improving, Research and analytics | Google Analytics, Yandex.Metriсa |
6.1. Publisher takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others’ privacy), You can request information from us about the personal information we hold in relation to You and You can correct any inaccurate data we hold.
6.2. In certain territories (including the EU), you also have a legal right to ask for a restriction of processing, to object to processing as well as the right to data portability. However, these rights are subject to conditions and may not always be applicable.
6.3. You have the right to withdraw your consent, on the basis of which we process your personal information, at any time, however, this does not affect our lawful processing based on your consent before this withdrawal.
6.4.Push notifications
We may occasionally send You push notifications through our games, applications to send You game or application updates, high scores and other Services related notifications that may be of importance to You. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.
6.5.For Users in the European Union.
If You want to exercise any of these rights, please contact us at: [email protected].
7.1. Publisher takes technical, organizational and legal measures to protect the Users’ personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal activities.
7.2. We have implemented commercially reasonable technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes.
7.3. In the event that personal information has been or is compromised as a result of a breach of security, Publisher will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.
7.4. The security of your personal information is important to us. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our third party services stake appropriate security measures to protect against unauthorized access or disclosure of the information collected by us.
We do not knowingly collect children’s personal information without parental consent, except as permitted under applicable laws such as the U.S. Children’s Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, Publisher, its providers/ partners may collect personal information strictly to support Publisher’s internal operations and/or legitimate interests, such as analytics. If You are a parent of a child using the Site or applications (Services), You may review or have your child’s personal information deleted and refuse the further collection of his/her personal information by contacting us at [email protected]. Please contact us if You believe we are collecting a child’s personal information in violation of COPPA or the GDPR.
9.1. Users are entitled to send their queries to Publisher, including queries regarding the use of their personal data in writing to: Bucuresti, str. Feleacu nr. 3, bl. 11E, sc. 2, ap. 20, et. 1, sector 1, or in the form of an electronic document containing a qualified electronic signature in accordance with the legislation of the Romania to our e-mail address [email protected].
9.2. Publisher shall review and reply to the received User query within 30 (thirty) days of the receipt of the query. That period may be extended by two further months where necessary, taking into account the complexity and number of the request.
9.3. All correspondence received by Publisher from Users (queries in writing or submitted electronically) is considered information with limited access, and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the query cannot be used without the express consent of the User in any way other than to respond to the issue described in the query received or in cases expressly provided for by law.
This Policy does not apply to the actions and Internet resources of third parties. Publisher is not responsible for the actions of third parties who, as a result of using the Services, have access to information about the User, which, by the nature of the Services, is available to any Internet User. Publisher recommends that Users take a responsible approach to the amount of information they provide about themselves.