PRIVACY POLICY

1.    ADMINISTRATOR

The administrator 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 “Gray Shark Apps”).

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 PERSONAL DATA WE COLLECT:

Data collected for your use of Application:

3.1.    Player user name and password;

3.2.    Data about your use of the Application, such as gameplay data;

3.3.    Data about purchasing transactions history. If you make a purchase, your card information is not held by us, it is collected by the store, who specialize in the secure online capture and processing of credit/debit card transactions (e.g. Google).

3.4.    Hardware-based device identifiers and operating system-based identifiers.

Most of the data is collected via services provided by our partners:
Unity Analytics (Unity Technologies)
Unity Analytics is a platform offered by Unity Technologies (“Unity”) that collects Application data and provides analytics for a game.
•    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
Firebase (Google Inc.)
Firebase is an application development platform service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of our Applications, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
For information about Google Privacy Policy, see: https://policies.google.com/privacy
Data collected for your use of Internal Testing Program:
If you are taking part in “Internal Testing Program”, apart from data listed above we might want to collect additional information required to perform Beta Testing and collect feedback:
3.5.    Name and surname;
3.6.    Contact information (such as e-mail address);
3.7.    Phone number if you wish to share your feedback via phone;

4.    THE PURPOSE OF PERSONAL DATA PROCESSING:

Grey Shark Apps uses the collected Personal Data for various purposes:
4.1.    To provide and maintain the Application;
4.2.    To notify you about changes to our Application;
4.3.    To create accounts and allow you to play our games and use our Application;
4.4.   To allow you to participate in interactive features of our Application when you choose to do so;
4.5.    To provide customer care and support;
4.6.  To provide analysis or valuable information so that we can improve the Application;
4.7.    To monitor the usage of the Application;
4.8.    To detect, prevent and address technical issues;

5.    THE LEGAL BASIS FOR THE PROCESSING PERSONAL DATA:

We process your personal data under article 6 point b GDPR, i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

6.    USER RIGHTS:

Users whose Personal Data are being processed have the right to:

6.1.    To have personal data removed;
6.2.    To rectification of their personal data;
6.3.    To restrict the processing of their personal data;
6.4.    To withdraw their consent anytime;
6.5.    To object to processing;
6.6.    To transfer personal data to another entity;
6.7.    To 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:

Grey Shark Apps shall store yours data as long as necessary in order to provide Application or to pursue the Grey Shark Apps’s legitimate interests. We may keep your 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.

To determine the appropriate retention period for personal information, we consider the
amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

8.    PROVISON PERSONAL DATA AS CONTRACTUAL REQUIREMENT:

Providing Personal data is fully voluntary. However, agreeing to provide them may be necessary to use the Application. Lack of consent to provide data by the user in such
a case may result in lack of access to the Application. We inform that providing data is necessary to conclude a contract and in the case of failure to provide the data it is impossible to conclude a contract.

9.    DISCLOSURE OF DATA

We may disclose your Personal Data in the good faith belief that such action is necessary to:
9.1.    To comply with a legal obligation;
9.2.    To protect and defend the rights or property of Grey Shark Apps;
9.3.    To prevent or investigate possible wrongdoing in connection with the Application;
9.4.    To protect the personal safety of users of the Application or the public;
9.5.    To protect against legal liability;

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 not use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

12.    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.

13.    INTERNATIONAL DATA TRANSFERS:

Data we collect about you will be stored within the European Union (EU) on a secured server.

14.    CONTACT US:

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

15.    REVIEW OF THIS POLICY:

This Policy was last updated in July 2019