1. Introduction and Applicability of This Policy
2. Data Controller Details
3. Purposes, categories and grounds for processing users' personal data
4. Cookies and similar technologies
5. Terms of personal data processing
6. International Data Transfers
7. Data Retention
8. Security Safeguards
9. Age Limits
10. How To Exercise Your Personal Data Rights
11. Contact US
12. Changes to This Privacy Policy

1.1. This Privacy Policy describes how we collect, use and disclose your personal data, and what choices you have with respect to that personal data.

1.2. This Privacy Policy applies to our games (“Games”), websites (“Sites”), apps, Game Account ("Account") and other official related products, sites, communications and services (including support services, forums), which we collectively call “the Services”, but excluding services which are offered under a different privacy policy or services provided by third parties. This Privacy Policy applies to registration, each access or actual use of any of our Products or Services, you are invited to familiarize yourself with the provisions of this Privacy Policy and the terms of processing of your data, including your personal data.

1.3. This Privacy Policy should be read together with and in addition to our End User License Agreement, as well as other legal documents on the site intended for individual categories of Users. For the purposes of this Policy, the definitions of Section 1 of the End User License Agreement shall apply.

1.4 We strive to make the Privacy Policy more accessible and understandable, for this purpose we:
● highlight the sections listed below in the Contents,
● provide examples to help illustrate how we implement this Privacy Policy,
● We capitalize terms that are used more than once.

1.5. We do not verify the information we receive from you, except when such verification is necessary for us to fulfill our obligations to you. However, we assume that you provide accurate and sufficient information about yourself and update it in a timely manner.

2.1. Throughout this document, “Company”, “we”, “us”, “our” and “ours” refer to SYNTHEZ GAMES LTD (“Data Controller”) Address: Eleftheriou Venizelou, 9, MILIADOU COURT, Flat/Office 104, Paphos, 8021, Cyprus
Contact E-Mail: privacy@synthez.games

3 .1. The Company may process personal data solely for the purposes for which they were collected or received. In particular, the Company may process the following personal data to achieve the stated purposes:

3.1.1. To ensure normal and safe operation, control of use and improvement of the quality of the Products or Services, save the User's preferences, conduct statistical, analytical and other studies of the use of the Products or Services by the User, aimed at adjusting the content of the Products or Services in accordance with the User's preferences: IP address, individual network number of the device (device ID), information about the User's equipment (device name and operating system, system version, device model, memory, browser type and system language, system country, display width/height, device time zone), IP address and identifiers of the mobile device, game data (e.g. interaction with the game and with other players in the game using the Server log files, player ID), cookie data, information about the browser, operating system, access time, visit time, search queries, the corresponding website addresses automatically collected by the web analytics systems used in the Products or Services. The Company processes this data for the time periods established by applicable law. For more information about cookies and web analytics systems, see the COOKIES AND SIMILAR TECHNOLOGIES section.

3.1.2. In order for the Company to provide the User with the rights to use the Game under the terms of a simple non-exclusive License (Game operation), registration and authorization of the User in the Products: the User's nickname, the User's ID in the game, the User's age. The data required for the operation of the services are marked in a special way, other information is provided by the User at his own request and at his discretion. The Company processes this data for the entire period of use of the Products or Services by the User, as well as for no more than 5 years from the date of the last authorization.

3.1.3. To comply with the law, respond to a request, comply with the requirements of the legislation on personal data and the legislation on consumer protection: first name, last name, middle name, telephone number, email address, and other information that Users independently make available through the User's request. The Company processes this data for at least 5 years from the date of receipt of the User's request. All correspondence received by us (written or electronic requests) is classified as information with limited access and cannot be disclosed without your written consent. Personal data and other information about you cannot be used without your consent for any purpose other than to respond to a request, except in cases expressly provided by law.

3.1.4. For the Company to grant the User the rights to use the Game under the terms of a simple non-exclusive License (the User providing profile information on a social networking site to ensure integration with such social networking sites, logging into the game): User ID in GOOGLE. To access the Games, you may be asked to log in using your account. We do not have access to your account and password, as the login process is performed on third-party servers. You enter your username and password on the third-party site. You are responsible for protecting your account information and for any actions using the Game.

When you connect to and/or use the Game through your account on a third-party resource, you will be asked to allow the Game to access certain information stored in that resource. We use your account information only in accordance with the privacy settings you have set for your account. Accordingly, we use this information only to provide you with the opportunity to use the Game at that moment (but do not store) such information.
A third party site's use of personal information that you provide in connection with your use of the Game is governed by and controlled by that site's privacy policy, and not by this Privacy Policy or by us.

3.1.5. To process payments for activation of rights to non-activated data and commands, fraud monitoring: purchase information (order number, payment currency). When you purchase a Digital Content from us, we receive the information necessary to process your orders, which may include the transaction amount, but does not include financial information or bank card holder data, which will be transmitted directly to the payment service provider via secure protocols; you can find additional information in the current data protection policies of the relevant payment service providers. If you make payments in a mobile application, we do not collect or have access to your name and payment information, this information is collected and stored on your platform (Google Play) or the payment service provider of your platform.

3.2. The Company has the right to enter personal data into information systems for the specified purposes, store and process it in any way that does not contradict the law. Upon achieving the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by law or otherwise separately agreed upon by the parties, the processed Personal Data shall be subject to destruction.

3.3. The Company does not process biometric data, as well as information related to race, nationality, political views, religious or philosophical beliefs, or the intimate life of the subjects of Personal Data.

3.4. The processing of personal data for the purposes specified above is carried out by the Company on the following legal basis:
- performance of a contract to which the data subject is party — End User License Agreement;
- legitimate interests in operating our Products or Sevices;
- consent: the individual has given clear consent for you to process their personal data for a specific purpose;
- legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

In order for the Services to function properly, we may use Cookies. Cookies are small bits of record-keeping text information that are automatically created and stored in your computer or other device in order to associate and identify activity with the User (“Cookies”). Cookies do not typically include names and/or email addresses and/or other Personal Data. In fact they typically contain anonymous information that is required for the better functionality of the Products or Services.

Third Party Cookies are stored for no more than one year and allow you to track the quality of the website and its usage characteristics.

The Company's websites use the following types of web analytics tools:

We may use third-party analytics providers software to allow us to better understand the functionality of our software on your device, including but not limited to AppsFlyer, AppFollow, AppAnnie, DEVTODEV (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Services, the events that occur within the Services, aggregated usage, performance data, and where our Software was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Services.The information about your use of our Services, may be transmitted to and stored by Third-Party Analytics Providers’ servers, which may also be located outside of the European Economic Area.

This policy does not cover the use of third party tools, to learn more about their privacy policies and opt-out options, please follow the links below:

AppsFlyer
AppsFlyer provides us attribution and marketing analytics services that enable us to measure and analyze the effectiveness of certain events and actions within the Game. AppsFlyer also helps us to identify and protect against fraudulent behavior related to our marketing campaigns. Learn more about AppsFlyer’s privacy policy here: https://www.appsflyer.com/services-privacy-policy. 
To opt out, please visit this page: https://www.appsflyer.com/optout.

AppFollow
We use AppFollow to mobile apps and games monitor and management,  app store optimization (ASO). For more information about AppFollow privacy practices, please see the https://appfollow.io/privacy.

AppAnnie
AppAnnie helps us analyze app download statistics, usage activity, and profitability. Learn more about AppAnnie's privacy policy at https://www.appannie.com/en/legal/privacy/.

DEVTODEV
DEVTODEV provides us with attribution and marketing analytics services that allow us to measure and analyze the effectiveness of certain events and actions in the Application. Learn more about DEVTODEV's privacy policy at: https://www.devtodev.com/policy.
We may also share anonymous or aggregated information or other data with third parties that does not directly identify you and that cannot be used to identify any individual user, for example, to show trends in the use of our products.
Visiting and using websites by default involves the generation and storage of cookies.
You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.

5.1. Information processing is carried out by the Company, as well as other third parties who are engaged by the Company in processing, or to whom Personal data is transferred for the specified purposes. Such third parties may include, in particular:

5.1.1. the Company's counterparties providing website hosting services and support for the information systems used, third-party administrators, moderators and testers, developers of gaming software, User support services, organization of events for collecting and processing User feedback, conducting surveys and research among Users, and other services acquired by the Company for the purposes specified above;

5.1.2. state/municipal authorities in cases established by law.

5.2. Data collected by the web analytics systems used may also be received and processed by third party providers of such systems, including those located in other countries. In this case, the processing of personal data is carried out within the framework of providing the Products to the User for the fulfillment of the terms of the End User License Agreement.
The Company has the right to involve third parties in the processing of the received Personal Data and/or transfer the received data to them, as well as receive data from them for the specified purposes without the additional consent of the User, provided that the specified third parties ensure the confidentiality and security of the personal data during processing. The processing of Personal Data by the specified third parties with and without the use of automation tools is permitted. The processing of personal data by a third party may be carried out only on the basis of an agreement that defines the list of actions (operations) that will be carried out with the personal data and the purposes of processing, as well as provisions for ensuring the security of personal data, including the requirement not to disclose or distribute personal data without the consent of the User.

5.3 Publicly accessible information: Our resources may offer publicly accessible chat rooms, forums and blogs that may be viewed by third parties. Please note that you post publicly accessible information at your own risk. We are not responsible for any information that you voluntarily choose to post. You should be aware that any information you provide through these communication services, including account information, may be read, collected and used by anyone who uses these services. Your messages and certain account information may remain even after your account is terminated. We strongly recommend that you consider the sensitivity of any information you enter into these services. To request removal of your information from the publicly accessible resources we operate, please contact us as specified in the “How to Contact Us” section below. If in some cases we are unable to remove your information, in which case we will notify you of this and the reasons why we are unable to remove the information.

5.4. Links to Third-Party Sites: the Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

5.5. Change of control: we may share your data as part of our company’s sale, merger or change in control, or in preparation for any of these events. Any entity that buys us, or part of our business, will have the right to continue using your data, but only in the manner set out in this Privacy Policy, unless you agree otherwise.

6.1. Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your personal information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services.. Whenever we transfer your information, we take steps to protect it.

6.1.2. International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to countries outside the European Union and allow access to that information from countries in which our owned or operated companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our customers and users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.

6.1.3. International transfers to third-parties. Some of the third parties described in this privacy policy that provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. When we share the information of customers in the European Economic Area or Switzerland, we make use of the EU–US Data Privacy Framework, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. We will provide you with a copy of the standard data protection clauses upon your request.

7.1. We retain your data for as long as your account is active, or as long as is needed to provide you with the Service. We will 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.

7.2. Content you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Services. For example, we continue to display messages you posted on the forum, and continue to display content you provided.

8.1. 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. The Company takes all necessary organizational and technical measures to protect the personal data of Users from unauthorized or accidental access to them, destruction, modification, blocking, distribution, as well as from other illegal actions with it.

The Company has appointed persons responsible for organizing the processing and ensuring the security of personal data.

In internal documents that are mandatory for all employees of the Company, as well as in relevant agreements with partners, contractors and other third parties

9.1. We do not knowingly collect or solicit personal data from 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 the age of 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.

10.1. You have certain choices available to you when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.

10.2. You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.

10.3. Your requests and choices may be limited in certain cases, such as when fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.

10.4. Access Your Data (Right of Access): Upon your request, we will provide you with a copy of your personal data in a structured, electronic format.

10.5. Change or Correct Your Data (Right to Rectification): You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

10.6. Delete Your Data (Right to Erasure): In certain territories (including the European Union) you can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and game-related information linked to the Account, subscriptions to forums, and the possibility to access other services for which you are using the Account. Please note that once your Account has been deleted, you will lose your gaming experience and all Digital Content. If you want to request data deletion please contact us at privacy@synthez.games.

10.7. Request That We Stop Using Your Data (Right to Object): In certain territories (including the European Union) where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims.

10.8. For European Union users only. Data Portability: Data portability is the ability to obtain some of your personal data in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.

10.9. You may withdraw consent where processing of your personal data is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

10.10. We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.

You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.

11.1. If you have any questions about how your personal data is collected, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at:
SYNTHEZ GAMES LTD
Address: Eleftheriou Venizelou, 9, MILIADOU COURT, Flat/Office 104, Paphos, 8021, Cyprus
Contact E-Mail: privacy@synthez.games

12.1. The Company hereby reserves the right to suspend, add, end, amend and/or supplement this Privacy Policy together with the documents forming an integral part of this at any time as the Company may deem appropriate, provided the prior notice as follows: the Company will post updated version of this Privacy Policy on the Internet Site, and/or within the mobile application, and/or the Company will inform you of the particular changes in advance via e-mail or provide other sufficient notice as the Company may elect in its sole discretion no later than the day when such changes shall come into effect. Any changes will enter into force from the moment of making the corresponding changes and the posting of the updated version on the Internet Site. You shall be deemed to have accepted these changes (i) unless you have notified the Company of your objection to such changes within ten (10) calendar days from the moment of receipt the notification from us, or (ii) if you use the Game or the Internet Site after the changes have entered into force.

12.2. In case you object to any changes the previous version of the Privacy Policy shall continue to apply. However, in that case the Company will have the right to close your Account and terminate the EULA with fourteen (14) calendar days’ notice. In case the Company decides to close your Account, upon your request the Company will reimburse payments for Digital Content purchased, which by the time of effective termination (i) have been purchased and applied to the account and (ii) have not been redeemed in the Game already.

12.3. The Company highly recommends that from time to time the User revises this Privacy Policy in order to have knowledge of any modified version of this Privacy Policy.

12.4. The Company is under no obligation to verify whether the User uses the Game and/ or Internet Site according to the updated version of this Privacy Policy. Save for the above, the version posted on the Internet Site is the effective version, and that which the User should use as reference. It is the User’s responsibility to inform himself of this Privacy Policy, as well as being familiar with any modifications that affect the User and/or will and/or might affect the User.