Privacy and Cookies Policy
Effective Date: November 2, 2023
Table of Contents
1. Introduction and Applicability of This Policy
2. Data Controller Details
3. Purposes of Data Collection
4. Data We Collect and Receive
5. How We Use Data
6. Who We Share Your Data With
7. International Data Transfers
8. Data Retention
9. Security Safeguards
10. Age Limits
11. How To Exercise Your Personal Data Rights
12. Contact US
13. Changes to This Privacy Policy
2. Data Controller Details
3. Purposes of Data Collection
4. Data We Collect and Receive
5. How We Use Data
6. Who We Share Your Data With
7. International Data Transfers
8. Data Retention
9. Security Safeguards
10. Age Limits
11. How To Exercise Your Personal Data Rights
12. Contact US
13. Changes to This Privacy Policy
1. Introduction and Applicability of This 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.
2. Data Controller Details
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
Contact E-Mail: privacy@synthez.games
3. Purposes of Data Collection
3.1. We process your personal data for the following purposes:
3.2. For more information on what type of data we collect and how we use it please refer to the Section 4 and Section 5 respectively.
- To make the Services work and make them more suitable to you
- To show personalized advertisement
- To keep the Services safe and fair
- To Analyze and monitor use of the Services and its social features
3.2. For more information on what type of data we collect and how we use it please refer to the Section 4 and Section 5 respectively.
4. Data We Collect and Receive
4.1. In order to provide the Services, we may collect or receive data, which may include the information voluntarily provided in the course of filling special forms in the Game, the information provided during subscription to the Services, publication of materials and request for other services or information collected automatically during the course of providing the Services.
4.2. Data You Provide Us With
4.2.1. Account Data To create or update an Account, you may be asked to provide Personal Data including, but not limited to, your username.
4.2.2. Communication and Content Data When you communicate with us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, we may process all of this information.
This data includes:
Please note that information that you voluntarily make public, or which you post publicly (for example in the game-chat), will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions.
4.2.3. Anonymous data We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
4.2.4. Sensitive Information We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.
4.2.5. Other Data We may request any information required to organize and conduct events in the Game when you register to participate in such events initiated by us.
4.3. Data We Collect Automatically
4.3.1. Usage Data The browser (when visiting our Site) or a client program may transfer certain information about the details of visits to the Services, including
In most cases, when you use the Services, we also create for you an in-game identifier such as an Account ID.
4.3.2. Cookie Files and Similar Technologies 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 Services.
Cookies or similar technologies stored on your computer or device through which you use the Services have amongst others but without limitation, the following functions:
Core functionality. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
Marketing. We may use cookies or similar technologies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services and action tags to measure advertising effectiveness and allow more effective targeted advertising, but use of those third-party cookies would be subject to the service provider’s policies.
Performance, Analytics and Research. Cookies or similar technologies help us learn how well our Sites and Services perform. We also use cookies or similar technologies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your computer or your mobile device.
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, Facebook Analytica, AppFollow, myTracker, 1Link, MRGS, adsadvisor.io, ironSource Mobile (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.
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, general geolocation 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:
Facebook Analytics
Solution for analytics that helps to understand how You use our Services. For more information about Facebook Analytics privacy practices, please see the https://www.facebook.com/policy.php.
You can opt-out of Facebook Analytics by following the instructions provided by Facebook in its Data Policy and Cookies & Other Storage Technologies section.
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.
myTracker
myTracter collects information such as User’s device identifier, general geolocation information, IP address and etc. to analyze the performance of Game and advertising campaigns, including their effectiveness, User’s interactions with them, installations and downloads.
To learn more about myTracter privacy practices please visit the page https://tracker.my.com/legal/privacy-policy.
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.
1Link
We use 1Link to analyze statistics data such as events, registrations, etc. For more information about privacy practices, please visit this page https://documentation.my.games/terms/mygames_tou.
Adsadvisor
AdsAdvisor helps us to measure and analyze the effectiveness of certain events and actions within the Game, which enables us to make informed decisions regarding app marketing and performance optimizations. To learn more about AdsAdvisor privacy practices, please see the https://documentation.my.games/terms/mygames_tou.
MRGS
MRGS collects information about performance of the Game and how You use it, in order to constantly improve the content of the Game, to optimize Your user experience, to understand any errors that You may encounter while using the Services. For more information about privacy practices, please visit this page https://documentation.my.games/terms/mygames_tou.
ironSource Mobile
We use ironSource Mobile to manage all the third-party ad networks that serve ads in the Game. Learn more about ironSource Mobile privacy practices, please see https://ironsource.mobi/privacypolicy.html.
The following are third parties that we use to display You advertisements created by third-party advertisers within the Game:
Google AdMob
To learn more about Google AdMob’s privacy practices please visit the page https://policies.google.com/privacy?hl=en.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android device and selecting “opt-out of interest based ads” (Android).
Facebook Audience Network
For more information about Facebook privacy practices, please see the https://www.facebook.com/policy.php.
You can opt-out here: https://www.facebook.com/adpreferences/ad_settings/?entry_product=account_settings_menu.
Unity Ads
Learn more about Unity Ads privacy policy here: https://unity3d.com/legal/privacy-policy.
AppLovin
For more information about AppLovin privacy practices, please visit the page https://www.applovin.com/privacy/.
Vungle
Learn more about Vundle’s privacy policy here.
To Opt-out: please visit the page https://vungle.com/privacy/#section-2-4.
AdColony
Learn more about AdColony’s privacy policy here: https://www.adcolony.com/consumer-privacy/.
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.
4.2. Data You Provide Us With
4.2.1. Account Data To create or update an Account, you may be asked to provide Personal Data including, but not limited to, your username.
4.2.2. Communication and Content Data When you communicate with us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, we may process all of this information.
This data includes:
- email address that you provide to contact you;
- data that you post, comment or like in any of the Games’ Sites;
- data you provide through our support channels;
- payment details, when you purchase a product or service from us, including information necessary to process your orders, which may include which purchase was made by You, purchase price, purchase date, currency of payment, the amount of any transaction, but will not include your name, financial information or cardholder data; this information is collected and stored by your platform (e.g. Google Play) or your platform’s payment processor.
- information other than the Account data you provide to us when participating in competitions, contests and tournaments, responding to surveys, e.g. your contact details;
- information regarding your profiles on social networking sites in order to allow integration with such social networking sites.
Please note that information that you voluntarily make public, or which you post publicly (for example in the game-chat), will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions.
4.2.3. Anonymous data We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
4.2.4. Sensitive Information We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.
4.2.5. Other Data We may request any information required to organize and conduct events in the Game when you register to participate in such events initiated by us.
4.3. Data We Collect Automatically
4.3.1. Usage Data The browser (when visiting our Site) or a client program may transfer certain information about the details of visits to the Services, including
- information about traffic, log-files, user activity information;
- IP-address and mobile device identifiers (such as your device ID, IMEI, advertising ID (IDFA, IDFV);
- Google Play ID
- general location data;
- information about your device, such as device name and operating system, system version, device model, memory, browser type and system language, system country, display width/height, device time zone;
- necessary cookies
- data about your use of the Services, such as gameplay data and your interactions with other players inside the Services, profile creation date, last login inside the Service and other information.
In most cases, when you use the Services, we also create for you an in-game identifier such as an Account ID.
4.3.2. Cookie Files and Similar Technologies 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 Services.
Cookies or similar technologies stored on your computer or device through which you use the Services have amongst others but without limitation, the following functions:
Core functionality. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
Marketing. We may use cookies or similar technologies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services and action tags to measure advertising effectiveness and allow more effective targeted advertising, but use of those third-party cookies would be subject to the service provider’s policies.
Performance, Analytics and Research. Cookies or similar technologies help us learn how well our Sites and Services perform. We also use cookies or similar technologies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your computer or your mobile device.
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, Facebook Analytica, AppFollow, myTracker, 1Link, MRGS, adsadvisor.io, ironSource Mobile (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.
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, general geolocation 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:
Facebook Analytics
Solution for analytics that helps to understand how You use our Services. For more information about Facebook Analytics privacy practices, please see the https://www.facebook.com/policy.php.
You can opt-out of Facebook Analytics by following the instructions provided by Facebook in its Data Policy and Cookies & Other Storage Technologies section.
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.
myTracker
myTracter collects information such as User’s device identifier, general geolocation information, IP address and etc. to analyze the performance of Game and advertising campaigns, including their effectiveness, User’s interactions with them, installations and downloads.
To learn more about myTracter privacy practices please visit the page https://tracker.my.com/legal/privacy-policy.
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.
1Link
We use 1Link to analyze statistics data such as events, registrations, etc. For more information about privacy practices, please visit this page https://documentation.my.games/terms/mygames_tou.
Adsadvisor
AdsAdvisor helps us to measure and analyze the effectiveness of certain events and actions within the Game, which enables us to make informed decisions regarding app marketing and performance optimizations. To learn more about AdsAdvisor privacy practices, please see the https://documentation.my.games/terms/mygames_tou.
MRGS
MRGS collects information about performance of the Game and how You use it, in order to constantly improve the content of the Game, to optimize Your user experience, to understand any errors that You may encounter while using the Services. For more information about privacy practices, please visit this page https://documentation.my.games/terms/mygames_tou.
ironSource Mobile
We use ironSource Mobile to manage all the third-party ad networks that serve ads in the Game. Learn more about ironSource Mobile privacy practices, please see https://ironsource.mobi/privacypolicy.html.
The following are third parties that we use to display You advertisements created by third-party advertisers within the Game:
Google AdMob
To learn more about Google AdMob’s privacy practices please visit the page https://policies.google.com/privacy?hl=en.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android device and selecting “opt-out of interest based ads” (Android).
Facebook Audience Network
For more information about Facebook privacy practices, please see the https://www.facebook.com/policy.php.
You can opt-out here: https://www.facebook.com/adpreferences/ad_settings/?entry_product=account_settings_menu.
Unity Ads
Learn more about Unity Ads privacy policy here: https://unity3d.com/legal/privacy-policy.
AppLovin
For more information about AppLovin privacy practices, please visit the page https://www.applovin.com/privacy/.
Vungle
Learn more about Vundle’s privacy policy here.
To Opt-out: please visit the page https://vungle.com/privacy/#section-2-4.
AdColony
Learn more about AdColony’s privacy policy here: https://www.adcolony.com/consumer-privacy/.
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. How We Use Your Data
5.1. To Provide the Services to You
To provide the Services to you and to perform our contract with you, we use your information, which is necessary:
5.2.1. To provide a great Service to our players, we have a legitimate interest in collecting and processing the necessary data to
5.3. To Keep The Services Safe And Fair
5.3.1. In order to keep the Service and its social features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to:
5.4. With Your Consent
5.4.1. With your consent, we may process your data for additional specific purposes.
5.4.2. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time (to find out what to do in this case, please refer to section 11.9.), but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.
To provide the Services to you and to perform our contract with you, we use your information, which is necessary:
- to administer your Account, and to verify your details,
- to provide you with the Services you request;
- to verify and confirm payments;
- to communicate with you including via email or push notification about your Account or transactions with us and send you information about features on our Services or changes to our policies;
- to provide support including, but not limited to, product updates, product patches and fixes and other similar communications;
- to arrange your participation in competitions, rewarding you with gifts and awards to which you may be entitled as a result of winning an online or offline competition, etc.
5.2.1. To provide a great Service to our players, we have a legitimate interest in collecting and processing the 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;
- Notify you and provide you with information including via email or push notification about features on our Services, new product releases and service developments, and to advertise our products and services;
- Provide you with special offers inside the Service as well as in other websites and services, and by email;
- Send you related information including via email or push notification, such as updates, security alerts, and support messages;
- Enable you to communicate with other players.
5.3. To Keep The Services Safe And Fair
5.3.1. In order to keep the Service and its social features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to:
- Analyze and monitor the use of the Services;
- Take action against fraudulent, cheating or disruptive players.
5.4. With Your Consent
5.4.1. With your consent, we may process your data for additional specific purposes.
5.4.2. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time (to find out what to do in this case, please refer to section 11.9.), but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.
6. Who We Share Your Data With
6.1. We share information we collect about you in the ways discussed below and only when necessary for the performance of a contract with you, compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties.
6.1.1. Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services.
6.1.2. Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests.
6.1.3. External Moderators and Testers: some limited data about you (such as your nickname, IP-address) may become available to third-party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games.
6.1.4. Developers of the Game Software: for the purpose of developing and supporting the Game Software, we may share your nickname, e-mail, IP-address and some other information with third-party developer companies.
6.1.5. Advertising and Advertising Measurement Partners: we may share your email, nickname, IP-address and other information you provide to us in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, or otherwise facilitate the transmission of information that may be useful, relevant, or of interest to you. For more information please see section 4.3.2. of this Privacy Policy.
We may also share User’s data with the MY.GAMES VENTURE CAPITAL LTD for the purposes of marketing and promotion of the Game via the Internet.
6.1.6. 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.
6.1.7. Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you and that cannot reasonably be used to identify any individual user, for instance to show trends about use of the Services. We may also allow our third party advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web-beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
6.1.8. Publicly available information: our Sites may offer publicly available chats, forums and blogs that are viewable by others. Please note that you post publicly available information at your own risk. We are not liable for any information that you voluntarily choose to be public through such and/or other explicit actions. You should be aware that any information you provide on these communication services —including your Account information — may be read, collected, and used by any member of the public who accesses these communication services. Your posts and certain Account information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as specified below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to, and why.
6.1.9. 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.
6.1.1. Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services.
6.1.2. Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests.
6.1.3. External Moderators and Testers: some limited data about you (such as your nickname, IP-address) may become available to third-party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Games.
6.1.4. Developers of the Game Software: for the purpose of developing and supporting the Game Software, we may share your nickname, e-mail, IP-address and some other information with third-party developer companies.
6.1.5. Advertising and Advertising Measurement Partners: we may share your email, nickname, IP-address and other information you provide to us in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, or otherwise facilitate the transmission of information that may be useful, relevant, or of interest to you. For more information please see section 4.3.2. of this Privacy Policy.
We may also share User’s data with the MY.GAMES VENTURE CAPITAL LTD for the purposes of marketing and promotion of the Game via the Internet.
6.1.6. 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.
6.1.7. Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you and that cannot reasonably be used to identify any individual user, for instance to show trends about use of the Services. We may also allow our third party advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web-beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
6.1.8. Publicly available information: our Sites may offer publicly available chats, forums and blogs that are viewable by others. Please note that you post publicly available information at your own risk. We are not liable for any information that you voluntarily choose to be public through such and/or other explicit actions. You should be aware that any information you provide on these communication services —including your Account information — may be read, collected, and used by any member of the public who accesses these communication services. Your posts and certain Account information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as specified below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to, and why.
6.1.9. 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.
7. International Data Transfers
7.1. Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We may transfer, process and store some of your personal information on our servers or databases outside the European Economic Area (EEA) including in Russia. Whenever we transfer your information, we take steps to protect it.
7.1.2. International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Russia 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.
7.1.3. 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-U.S. and Swiss-U.S. Privacy Shield Frameworks, 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.
7.1.2. International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Russia 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.
7.1.3. 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-U.S. and Swiss-U.S. Privacy Shield Frameworks, 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.
8. Data Retention
8.1. 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.
8.2. 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.
8.3. Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.
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.
8.2. 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.
8.3. Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.
9. Security Safeguards
9.1. 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.
10. Age Limits
10.1. 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.
11. How To Exercise Your Personal Data Rights
11.1. 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.
11.2. 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.
11.3. 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.
11.4. 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.
11.5. 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.
11.6. 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.
11.7. 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.
Opt-Out of Direct Marketing:
You can opt-out of receiving any direct marketing communications that we may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting. To opt-out of interest-based advertising on mobile Games please check the privacy settings of your Android device and select "opt-out of interest-based ads" (Android).
To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.
You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. Even after you opt-out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
11.8. 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.
11.9. 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.
11.10. 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.
11.2. 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.
11.3. 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.
11.4. 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.
11.5. 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.
11.6. 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.
11.7. 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.
Opt-Out of Direct Marketing:
You can opt-out of receiving any direct marketing communications that we may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting. To opt-out of interest-based advertising on mobile Games please check the privacy settings of your Android device and select "opt-out of interest-based ads" (Android).
To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.
You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. Even after you opt-out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
11.8. 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.
11.9. 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.
11.10. 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.
12. Contact US
12.1. 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
SYNTHEZ GAMES LTD
Address: Eleftheriou Venizelou, 9, MILIADOU COURT, Flat/Office 104, Paphos, 8021, Cyprus
Contact E-Mail: privacy@synthez.games
13. Changes to This Privacy Policy
13.1. 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.
13.2. 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.
13.3. 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.
13.4. 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.
13.2. 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.
13.3. 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.
13.4. 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.