vK Games Ltd. – Privacy Policy

This policy is effective as of 1st March 2020.

Your privacy is important to us. It is vK Games Ltd.’s policy to respect your privacy regarding any information we may collect from you via our website, applications, and other associated services.

1. General

1.1 About this document

This document contains the privacy policy (“Privacy Policy”) of vK Games Ltd. (“vK Games”), UK registration number SC655009. Contained within is an explanation of how information about you is collected, used and disclosed by us, when you use our website, our applications and our other online products and services (collectively referred to as the “Services”) or when you interact with our Services in other ways.

We collect, store, and use your personal information as a data controller and according to this Privacy Policy in order to provide and improve our Services.

By using or accessing a Service you consent to the processing, use and disclosure of your data in accordance with this Privacy Policy, including the collection and use of your data by us and our trusted partners for the purposes of direct marketing, advertising and promotion of our Services. You may at any time withdraw your consent to the collection and use of your data for marketing, advertising and promotion purposes. The ways you can do so are described at the relevant places in this Privacy Policy.

If you do not want your data to be collected, processed and used or you do not agree to this Privacy Policy, do not install or use the Services.

1.2 Amendments

We reserve the right to change this Privacy Policy. When we change the Privacy Policy, we change the date at the top of the document and we may also provide you with a notice such as adding a statement to our website’s homepage or sending you a push notification or email. If you want to stay informed about our Privacy Policy we encourage you to periodically read the Privacy Policy.

1.3 Consent

All our Services are governed by this Privacy Policy.  By accessing or using our Services, you consent to the terms of this Privacy Policy. 

1.4 Children

Our Services are not targeted at children. In the United Kingdom, the minimum age to use our Services is 13. Other countries may have different minimum ages, and therefore, if you are under the relevant age for your country, you may not use our Services.

We do not knowingly collect personal information from children under 13 years of age. If we learn that we inadvertently received personal data from children under 13 years of age, we will take reasonable measures to delete such personal data.

2. Information we collect

2.1 Information you provide

When you register an account with vK Games, participate in a contest and promotion, communicate with us via third party social media sites, request customer support, send us an email or otherwise interact with us, we may ask for and collect this information. Collected information may include your Name, Email Address, Social Media Profiles, Date of Birth, Phone or Mobile Number, Home Address, Work Address, Payment Information, and any other information you choose to provide.

2.2 Log data

Your use of our Services is logged.

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

When you access our servers via our applications, we may automatically log the standard usage data provided by your device. This data may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details.

Additionally, when you encounter certain errors while using the app, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information that may have contributed to the problem.

2.3 Device data

We may also collect data about the device you’re using to access our Services. This data may include the device type, device’s operating system, software and hardware, Media Access Control address (“MAC address”) and other, unique device identifiers, device settings, and geo-location data, device tokens, as well as information on your mobile network and your time zone.

Our app may also access and collect data via your device’s in-built tools, such as; your identity, Location data, Camera, Microphone, Accelerometer, Body sensor, Storage, photos and/or media, Notifications, Voice assistance, Background data refresh, or Device/app history. What we collect can depend on the individual settings of your device and software, and the permissions you grant when you install and use the app.

We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

2.4 Usage data

The applications that you use, your game progress, game scores, game achievements and interactions with other players in the games.

2.5 In-App purchases

When you purchase products (e.g. resources) inside our games, we also receive data.

2.6 Business data

Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our Services.

2.7 Information we collect from third parties

We may obtain information from third parties and combine that information with information we collect ourselves through our Services. If you access our Services using a third-party platform or site, for example a social network or gaming services, we may receive information about you from that third party. This includes your screen name, your profile information and your friend lists. The information is collected in accordance with the procedures determined by such third party. When you download or update one of our applications from an app store we may also receive information.

3. Legal bases for processing

We will collect and process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so, according to UK and EU personal data protection laws, including the GDPR.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where: it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us); it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests; you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. We will also store and use the information as long as we are required by any law that is applicable to us. Be aware that the above also applies to cases where you decide to delete your account with vK Games, or we delete your account in accordance with our User Terms or Terms of Service.

While we retain your information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

We advise that you take enough precautions and act carefully when sharing your information via the Internet. We hereby notify you that the information we collect might be transferred and processed in countries outside the European Union and the European Economic Area. Please, be aware that these countries may not have the same data protection rules as the ones in your country or the EU. We undertake that we take reasonable and appropriate steps and measures to ensure that there are adequate safeguards in place (including standard data protection clauses) to allow your personal data to be transferred to such countries.

If your information is collected and processed based solely on your consent, you may at any time withdraw your consent by contacting us using the contact information below.

4. Collection and use of information

by installing, accessing and using our Services you consent to the use of your information by us and by our trusted partners as described in this Privacy Policy.

Information we collect, hold, disclose and use is for various purposes, and personal information will not be further processed in a manner that is incompatible with these purposes: to enable you to access and use our Services and associated social media platforms;  to enable you to customise or personalise your experience of our Services; to provide you with our app and platform’s core features; to contact and communicate with you to provide customer support or respond to your questions and your requests; to enable communication between players; for technical assessment, including to operate and improve our Services, associated website and applications, and associated social media platforms; to maintain and to improve the functioning and safety of our Services; to determine potential problems and to observe certain trends with our Services; to test new features of our Services; to keep statistics of how our Services are used; to send technical notifications; to provide updates; to provide security alerts; to process any transactional or ongoing payments; to contact and communicate with you; for internal record keeping and administrative purposes; for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms; to run competitions and/or offer additional benefits to you; to invoice our customers; to comply with our legal obligations and resolve any disputes that we may have; to prevent crime and fraud; to consider your employment application; for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; providing tailored advertisements; sending push notifications or alerts related to our Services; updates; promotions; and other messages to your device.

5. Disclosure of personal information to third parties

To market, advertise and promote our Services we collaborate with certain trusted partners with whom we might share your information and whose analytics, tracking and ad-serving technologies are integrated into our Services. Our partners help us to serve you advertisement, promotions and targeted content. To do this they combine the data we collect about you with information which they have obtained elsewhere. 

Please be aware that this Privacy Policy does not apply to the collection of your data by our partners.

We may also disclose personal information to: third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; our employees, contractors and/or related entities; sponsors or promoters of any competition we run; credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and third parties to collect and process data.

By installing, accessing and using our Services you consent to the use of your information by us and by our trusted partners for marketing and advertising purposes as described above. You can opt-out of us collecting the information with the purpose of providing tailored advertising by adjusting the global advertisement settings on your device. You can do so by limiting the ad tracking, resetting your device’s ad identifier and clearing your tracked data. Please, be aware that the settings might differ based on the device you use, but on most devices, you may find these settings in “ads” or “privacy”. You should be aware that if you do such opting-out, some or all of our Services may become entirely or partially unavailable for you. We hereby notify you that we consider the processing of your data for marketing and advertising purposes as our legitimate interest.

You have the right to object to processing of your data for marketing and advertising purposes at any time by contacting us using the contact information below.

You can always deactivate the receiving of the push notifications described above by changing the notification settings on your device.

Please note, that even if you opt out of us collecting information with the purpose of providing tailored advertisement, you will still see some advertisement, but it will not be personalised and targeted directly at you. 

6. International transfers of personal information

The personal information we collect is stored and processed in the United Kingdom, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

7. Sharing and disclosure of information

Your information will not be shared and disclosed, unless we have obtained your consent to do so, or when it’s necessary in order to provide you with our Services, or to carry out requests on your behalf, or when it is permitted or required by the applicable law. Without prejudice to the above, we may share information about you with other players, including requests to join multi-player games, and on leaderboards. We may also share information about you with our trusted partners and other service providers who need access to such information to carry out work on our behalf, including vendors and consultants.

7.1 Government requests etc.

If a government or other public authority requests information about you and we believe disclosure is in accordance with or required by applicable law we may share information about you with such government. If private persons or entities request information about you and we believe we are required by applicable law, we may share information about you with such private persons or entities.

7.2 Consent

With your consent or at your direction we may share information about you in other ways than described above.

7.3 Aggregate, non-identifiable

We may also share information about you together with information about other users so that it cannot reasonably be used to identify you.

7.4 Advertising and Analytics Services Provided by Others

We allow some third parties to serve advertisements and some third parties to provide analytics services in connection with our Services. These entities usually use cookies, web beacons and other technologies to collect information about your use of our Services, including the above-mentioned technologies. This information may be used by vK Games and others to track and analyse data, assess the popularity of certain content, deliver advertisements and deliver content targeted to you and your interests. By installing, accessing and using our Services you consent to such use of your data. 

7.5 Application Program Interfaces

Our Services may also have third party application program interfaces (also called APIs) integrated that allow third parties to collect and process information about you, including your geo-location information. This allows the third party and/or us to provide you with tailored advertisements and promotions. You can control the collection of your geo-location information at all times. We don’t allow third parties to access this information without you opting-in. You may disable location-based services at any time by adjusting the settings of your device.

7.6 Social Sharing Features

Our Services may offer social sharing features and other tools integrated in the Services. One example is the Facebook “Share” button. When using such features information about you is shared with your friends or with the public, depending on your Facebook settings or the settings on the other social media that provides the social sharing feature. You can obtain more information about this by reading the privacy policies of the social media that provide these features.

8. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us that you have, your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or products and services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

9. Cookies

We use cookies to collect information about you and your activity across our websites. It is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. 

Our applications also use cookies. In these circumstances, an app may store data on your device. This data would typically contain a unique identifier that allows the app servers to recognise your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie, self-maintenance information about the cookie itself; to allow access to core features of our Services, to track app usage and performance on your device; to tailor your experience of our app based on your preferences; and to serve advertising to your device. 

Any communication of cookie data between your device and our servers occurs within a secure environment. Please refer to our Cookie Policy for more information at www.vkgames.studio/legal/cookie.

10. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

11. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

12. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of our Services after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

13. Contact Us

If you have any questions about this Privacy Policy, including exercising your rights as a data subject, you can contact the Data Controller at support [at] vkgames.studio