1.    DATA CONTROLLER

The controller of your personal data (i.e. the entity deciding how your personal data will be used) is Grey Shark Apps Spółka z ograniczoną odpowiedzialnością with headquarters in Warsaw, entered into the Register of Businesses of the National Court Register (KRS) kept by the District Court for the capital city of Warsaw in Warsaw, XIII Economic Division of the National Court Register under KRS No. 0000719146, address: 04-023 Warsaw, ul. Wąwolnicka 4/22, NIP (ID tax number): 113-29-63-351 (hereinafter “We” or “GSA”).

2.    GDPR:

All personal data are collected and stored in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC, the General Data Protection Regulation (GDPR) and in accordance with provisions of Act on Rendering Electronic Services from 18 July 2002 (with amendments).

3.    THE DATA GSA COLLECTS:

A)     Data collected automatically in application

We are using Advertising and Analytics services in our Application. As part of those services following data is collected automatically within our application:

• Device ID, IP address, Apple’s Advertising Identifier (IDFA), and Google Play advertising ID – (hereinafter: “Personal Data”);
• Device type, operating system, device name, country, device language;
• In-game behavior, game progress;
• Purchases related data (i.e. items purchased for the purpose of the game);

In order to use the Application, the Controller must process the data listed above. If you do not agree to provide us with the above information, you will not be able to use the Application.

Please note that if we no longer need your personal data to provide you with services related to the Application, we will delete or anonymize them.

Collection of data listed above is done only with your consent provided within the Application. You can withdraw your consent any time within the Application.

B)      Data you provide us

We might collect your email address if you decided to contact us via email or other data you choose to give us via email.

4.    THE PURPOSE OF PERSONAL DATA PROCESSING:

We process your Personal Data to:

1. Fulfill our obligations under EULA concluded between you and the GSA;
2. Make the Application work:

• To monitor the usage of the Application;
• To detect, prevent and address technical issues;
• To provide customer care and support;

1. To adjust the application and make it more suitable for users:

• Run analytics and understand how users interact with our Application so we can improve and optimize our Application;
• Identify/ adjust difficulty level of particular areas of Application to improve user’s experience.

 

5.    THE LEGAL BASIS FOR THE PROCESSING PERSONAL DATA:

We process your Personal Data under article 6 point f) GDPR (processing is necessary for the purposes of the legitimate interests of the GSA) and under article 6 point b) GDPR (to provide you with Controller services that you use i.e. to perform EULA concluded between you and the Controller).

6.    USER RIGHTS:

Users whose Personal Data are being processed by GSA have the right:

6.1.     Have personal data removed;
6.2.     Rectification of their Personal Data;
6.3.     Restrict the processing of their Personal Data;
6.4.     Transfer personal data to another entity;
6.5.     Submit a complaint to the relevant data protection body (i.e. Personal Data Protection Office with headquarter in Warsaw if you acknowledge that processing your personal data infringes the GDPR);

7.    THE PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED:

We may keep your Personal Data during the period of time necessary to fulfill our legal obligations or in order to execute, defend or establish our rights. We shall take appropriate steps to ensure that after that period has passed your Personal Data are immediately removed from our systems.

8.    DISCLOSURE OF DATA

We may disclose your Personal Data in the good faith belief that such action is necessary to:
8.1.    To comply with a legal obligation;
8.2.    To protect and defend the rights or property of GSA;
8.3.    To prevent or investigate possible wrongdoing in connection with the Application;
8.4.    To protect the personal safety of users of the Application or the public;
8.5.    To protect against legal liability;

9. RECIPENTS OF YOUR PERSONAL DATA

Please note, that your Personal Data may be disclosed to the Controller’s partners, i.e.
in particular partners who technically help to run the application efficiently (providers of IT services as well as providers of statistical, marketing or analytical services). The Controller ensures that he always provides the minimum information necessary to achieve the goals for which cooperation has been established.

10.    CHILDREN’S PRIVACY:

10.1.Our Application does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 13.

10.2. You represent that if you are under 16 your parent or legal guardian prior consent for your Personal Data processing is given or authorized by the holder of parental responsibility.
If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

11.    AUTOMATED DECISION MAKING:

We do may use automated decision-making methods which do not involve human involvement to process your information. We will not, however, make automated decisions based on profiling that could affect your legal situation (e.g. we do not present you with advertisements based on the Personal Data we have).

12.    DATA SECURITY:

We have implemented appropriate technical and organizational measures to keep your data confidential and secure. We use commercially reasonable efforts to make sure your data is secure when processed by us – however please be aware that no security measures are perfect and impenetrable.

13.    CHANGES TO THIS PRIVACY POLICY:

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14.    INTERNATIONAL DATA TRANSFERS:

As part of the Controller’s use of tools supporting its day-to-day operations made available by our partners, User’s Personal Data may be transferred to a country outside the European Economic Area, in particular to the USA. Appropriate safeguards for the transferred Personal Data have been provided through GSA by applying standard data protection clauses adopted pursuant to European Commission decisions and processing entrustment agreements that meet the requirements of the GDPR. When transferring data from Europe to the USA entities located there may additionally provide an adequate level of data protection under the Privacy Shield program.

 

15. DATA COLLECTED BY OUR PARTNERS:

We are using Advertising and Analytics services in our Application. Those services are provided by our partners. In order to provide those services some data may be collected by our partner that will be Controllers of such data. Partners are collecting your data using their own tools (Software Development Kits or SDK) implemented in our Application. Partners may access your data and use it according to their privacy policies. We encourage you to review those privacy policies to understand their practices and how to exercise your rights directly toward them. Additionally please notice that you have an option to opt-out of data collection and delete historical data. Please refer to our partners privacy policies for detailed instructions:

Unity Technologies (“Unity”) – To learn more please refer to Unity Privacy Policy and FAQ documentation:

•  For information about Unity and GDPR, see: https://unity3d.com/legal/gdpr
•  For Unity’s own privacy policy, see: https://unity3d.com/legal/privacy-policy

Google Inc. (“Google”). For information about Google Privacy Policy, see: https://policies.google.com/privacy

Facebook Inc. (“Facebook”). For information about Facebook Privacy Policy, see:  https://www.facebook.com/about/privacy

Please note, that GSA does not decide on the purposes of processing such data by our partners.

Additionally for sake of clarity we inform you, that if you make a purchase in the Application, the data about purchasing transactions history and your card information is not held by us, but it is collected by the store (Google or Apple), who specialize in the secure online capture and processing of credit/debit card transactions.

16.    CONTACT US:

If you have any questions about this Privacy Policy, please contact us by e-mail: privacy@greysharkapps.com

 

17.    REVIEW OF THIS POLICY:

This Policy was last updated in April 2020