Privacy Policy

The protection of your personal data is fundamental to us. This confidentiality policy outlines information pertaining to the manner in which we collect and process this data.

“Personal data” or “Data” shall mean any information relating to an identified or identifiable natural person.
“Data controller” shall mean the person that determines the purposes and means of the processing.

The remit of the personal data protection policy

This personal data protection policy is applicable to all of our applications.

What data is collected?

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications:

• IDFA publicity identifiers (for iOS devices) and GAID (for Android devices)
• Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertisements we display (for instance, time spent on these, potential clicks).
• We are also likely to use cookies that correspond to small files containing letters and figures downloaded onto your device when you access our applications.

This data is collected via external tools (Software Development Kit or SDK) implemented by our partners, which are an integral part of the application.

You will find hereafter the list of our partners implementing SDKs through our applications:

• Games Analytics (analytical SDK)
• MoPub (SDK advertising)
• Admob (SDK advertising)
• UnityAds (SDK advertising)
• Applovin (SDK advertising)
• IronSource (SDK advertising)
• Facebook (SDK advertising)
• Tapjoy (SDK advertising)
• Vungle (SDK advertising)
• Mintegral (SDK advertising)

Purposes of processing undertaken by us and legal basis for processing

Data collected by us is used to:

• Provide our applications
• Guarantee use and improvement of our applications
• Develop new applications
• Understand your interests and, thanks to this profiling, propose targeted and relevant advertisements (SDK advertising)
• Make statistics on your use of the games, including the number of games played, your duration of use, or the advertisements you watch, which allows us to improve your gaming experience (analytical SDK)
• Communicate with you, notably when you contact us by any means whatsoever

We collect the data listed above, in whole or in part, only once we have your express consent for the purposes for which they are to be processed, through a pop-up in our applications.

At any time, you can withdraw your consent from the "Settings" page in our applications.

Term of data storage

We store your personal data for a maximum duration of 13 months after collection. Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited in any nature whatsoever.

Categories of recipients of data collected

The recipients of the Data are our internal teams who need to have access, as well as the partners mentioned above in article 2. We may, however, share Data collected with our technical service providers for the aforementioned purposes.

We stringently request that our partners always act in compliance with data protection legislation applicable and grant special attention to the confidentiality of this Data.

By application of the applicable regulation, any subcontractor who may process this personal data for us undertakes as follows:

• To solely process data for the purpose(s) which is/are sub-contracted
• To process data in pursuance with instructions
• Guarantee the security and confidentiality of Data

We may also disclose/transfer your personal data to third parties in the following particular circumstances:

• By virtue of legislation, as part of legal proceedings, a dispute, and/or a request issued by the public authorities in your country of residence or otherwise
• If the disclosure is necessary for national security, application of legislation, or any other matter of public interest
• In the event of restructuring, transfer, merger, or sale to the third party concerned

Data transfer

In such instances as your Data is transferred outside of the European Union, we ensure that:

• The personal data is transferred to countries recognized as offering an equivalent level of protection.
• Personal data is transferred via certified entities under the Privacy Shield.
• For personal data transferred outside of countries recognized by the National Data Protection Authority (CNIL)as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of template contractual clauses.

Personal data concerning children

If you are under the age of 18, you must obtain your parent’s permission to play our games while online or use any of our services.

If you are under the age of 13 (or 14, 15, or 16 in some locations), you are not permitted to use any of our Services or play any of our games.

All of our games are not intended for children under the age of 13 (or 14, 15, 16), and we do not knowingly market to or collect, use, or disclose information from children.

If Stavros Narlidis learns that we have inadvertently gathered personal information from children under such age, Stavros Narlidis will take reasonable measures to promptly erase such personal information from our records.

If you are a parent who wishes to have your child's accidentally collected information deleted, please contact stavros.narlidis@icloud.com or simply delete it from the SETTINGS section of the application.

Your rights concerning data collected

8.1. Your rights

You have the following rights concerning the data we collect:

• Right to confirmation of the existence of a data processing
• Right to access your Data
• The right to request rectification of your Data if incorrect
• Right to request deletion of your Data
• Right to limit processing
• Right to object to processing by withdrawing your consent
• Right to benefit from data portability
• Right to provide post-mortem guidelines
• Right to make a complaint to the National Data Protection Authority (CNIL)

Terms for exercising rights

Due to the obligation of security and confidentiality in Data processing incumbent upon us, you are hereby informed that your request will be processed only if you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

We will determine whether your request is admissible within one month following receipt. If deemed admissible, we will provide all requested information or implement the claimed rights within the aforementioned deadline.

If, due to the complexity of the request or the number of requests received, the deadline cannot be respected, we will notify you before expiry and may extend the deadline by a maximum of two months.

If we do not follow up on your request, we will inform you within the deadlines of the grounds for our decision and your option to file a complaint with the National Data Protection Authority (CNIL).

Personal data security

We take all necessary security measures to prevent, as far as practically possible, any alteration or loss of your data or any unauthorized access.

If we become aware of any illegal access to your personal data for which we are responsible, we undertake to notify you as soon as possible if this fulfills a legal requirement.

Updating this policy

This policy may be updated at any time, notably pursuant to legal and/or regulatory provisions and/or any recommendations of the National Data Protection Authority (CNIL).

We invite you to consult this page regularly.