1. General Provisions
1.1. This Policy shall be read in conjunction with our User Agreement available at http://tltgames.ru/license-agreement-en
(hereinafter, the Agreement). In the event of any inconsistency between this Policy and the Agreement, this Policy shall prevail.
1.2. Concluding Agreement you, of your own free will and in your own best interests, consent in writing to the following types of processing your Personal Information may be subject to: collection, recording, organization, storage, specification (updates, amendments), retrieval, use, transfer (distribution, submission, access), depersonalization, blocking, archival or deletion for the purposes set forth herein, using any, all or no means of automation, as tltGames, in its sole discretion may see fit.
1.3. The terms and definitions used here and further in this Policy shall be as set forth in the Agreement, unless it is stipulated otherwise in this Policy or so follows therefrom. In such cases, the terms used in this Policy shall be construed in accordance with, first, the law of the Russian Federation, second, international legal acts and, third, customary business use or scientific doctrine.
2. Personal Information
2.1. In this Policy, Personal Information is understood as set forth below:
2.1.1. Information about self that the User voluntarily provides (when playing the Game or otherwise, as provided in the Agreement), including personal data;
2.1.2. User's depersonalized data transmitted automatically based on software settings.
2.2 tltGames shall have the discretion to determine what kind of Personal Information Users are to provide to be able to play the Game and/or perform under the Agreement, including but not limited to email address, information about the mobile device used (model, type and operating system version), screenshots of the Game profile, in-game purchase data (date, description/goods purchased, transaction identifier). Users, at their own discretion, may choose to also provide other information that has not been identified by tltGames as mandatory.
2.3. During the first connection to the tltGames' Game server, each User shall be assigned a unique identifier (user_id) associated with the information in said User's profile.
2.4. Public Information. Users may, at their own discretion, provide any other additional information about themselves for the purpose of communicating with other players, such as first and last name, gender, date of birth, city they live in or any other information in the format of their own choosing. By disclosing this information in the Game chat room, the User makes it available to an unlimited number of persons, i.e. makes it public.
2.5. tltGames does not verify Personal Information it receives for accuracy, nor checks if the User reporting same is in possession of any consents that may be required for processing same in accordance with this Policy. It is presumed that Users act reasonably and in good faith, comply with the terms of this Agreement, keep all the information up-to-date and possess any and all consents necessary from the owners of any personal information.
2.6. Users acknowledge and consent to the use in the Game of third-party statistics and analysis software (such as GameAnalytics, Google AdSense and AdMob) that may enable such third parties to transmit and receive depersonalized information described in para 2.1.2 herein.
Such information generated by third party software may include:
- browser information (type, version, cookies);
- operating system information (type, version, screen resolution);
- request information (time, click-through source, IP address).
The composition and scope of depersonalized data collected by third party software is determined by the owners of copyright to said software.
2.7. tltGames shall not be liable for the use of any Personal Information by any third parties the User may interact with when playing the Game or performing under the Agreement.
3. Reasons for Processing Personal Information
3.1. tltGames will process (including collection and storage) only that Personal Information, which is needed for making the Agreement with the User and performing thereunder.
3.2. tltGames may only use Personal Information for the following purposes:
3.2.1. Making the Agreement;
3.2.2. Discharging obligations under the Agreement, including granting to the User of access to the Game;
3.2.3. Maintaining Game functionality;
3.2.4. Identifying the User for the discharge of its obligations under the Agreement therewith;
3.2.5. Providing technical and other support for playing the Game or for other purposes set forth in the Agreement. Users shall communicate with the technical support service via the Internet using specific software (the Game's pages on Google Play, AppStore, Facebook, Vkontakte) and/or email;
3.2.6. Keeping in contact with the User to improve information services and Game performance. Contact with the User will be maintained as set forth in para 3.2.5 herein;
3.2.7. Conducting marketing research, statistical analysis or other studies using depersonalized data.
Data collected by the systems indicated in para 2.6 herein is depersonalized and used to determine how much time Users spend playing the Game and what their interests and preferences may be.
4. Personal Information Security Requirements
4.1. tltGames shall store Personal Information and protect it against unauthorized access and sharing in accordance with its internal rules and regulations and subject to the requirements of applicable law. Personal Information is processed at the tltGames office.
4.2. Personal Information shall be kept confidential, except for its public component, if any, as per para 2.4 herein, or where User-selected software settings allow for open sharing of information with other Game Players or any other Internet Users.
4.3. tltGames may only share Personal Information with third parties under the following circumstances:
4.3.1. Where the User has given his or her consent for same, including where User-selected software settings do not limit sharing of certain information;
4.3.2. Where such sharing may be necessary for the User to be able to use Game functionality or where the Game's specific features require same;
4.3.3. Due to the Game being transferred to a third party to possess, use or own, including assignment to said third party of the rights under the Agreement with the User;
4.3.4. If ordered by a court or another authorized government body, as set forth in the law;
4.3.5. To protect tltGames' rights and lawful interests in the event of the User violating the Agreement.
4.4. Personal Information shall be processed and stored for as long as it may be needed for the purposes for which it had been collected.
5. Changes in Personal Information
5.1. The User may remove his or her Game account or exercise the right to withdraw consent to processing of Personal Information, by writing to tltGames at email@example.com.
5.2. To raise the quality of the Game and services rendered thereunder, and to ensure availability of legal recourse, tltGames may maintain electronic logs of actions taken by Users when playing the Game or when making the User Agreement and performing thereunder—for a period of one (1) year from the moment any such action is taken.
6.1. tltGames may unilaterally change or terminate this Policy giving no prior notice to the User. Any new version of the Policy shall be deemed effective from the moment it is posted on tltGames website, unless stipulated otherwise in such new version of the Policy.
6.2. The current version of the Policy is available at the tltGames site, at http://tltgames.ru/privacy-policy-en
7. Contact Information
7.1. Please contact us with any questions regarding this Policy, at firstname.lastname@example.org.