XI-ART Sp.z o.o., hereinafter referred as “XI-ART”, “We”, “Us”. We Thank you for playing our games. Your privacy is most significant to us, and we deem it as our duty to care for it seriously; therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security. We hope the policy outlined below will help you understand what data XI-ART may collect, how XI-ART uses and safeguards that data and with whom we may share it. XI-ART is committed to respect the privacy of all visitors/users of its Website, mobile applications and other online products and services (collectively, the “Services”).

PRIVACY QUESTIONS, ACCESSING AND UPDATING YOUR INFORMATION

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly. If you wish to access, update, or delete your PII, please contact us. We may ask you to verify your identity before we can act on your request. In some cases, we may have to keep that information for legitimate business or legal purposes.

COLLECTION OF PERSONAL / NON-PERSONAL INFORMATION

Data you provide us

• Contact information (such as name and email address through which you have logged in)
• Your messages to the Service (such as chat logs etc)
• Whichever you have disclosed through support mail.

Data we collect automatically

• Data about your account and game progress
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address)
• Data about your device, such as device name and operating system, browser type and language
• Data we collect with cookies and similar technologies (see more below)
• Data about your use of the Service, such as game-play data and your interactions with other players inside the Service

In all cases, we also create a Unique ID and Encrypted ID for you when you use the Service.

Data we collect from our partners

• Data we receive if you link a third-party tool with the Service (such as Facebook, Google etc)
• Data from platforms that the games run on (such as to verify payment)
• Data for advertising and analytics purposes, so we can provide you a better Service

WHY WE COLLECT PERSONAL / NON-PERSONAL INFORMATION

To make the Service work

To perform the contract, we process data necessary to

• Create accounts and allow you to play our games and use our Service
• Verify and confirm payments
• Provide and deliver the products and services you request

To make the Service more suitable for our players

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

• Develop and improve the Service and player experience
• Update and develop player profiles
• Manage our relationship with you
• Provide social features as part of the Service
• Respond to your comments and questions and provide player support
• Enable you to communicate with other players

To show personalized advertisements

To show you personalized advertisements in the Service as well as in other websites and services we have a legitimate interest to process necessary data to

• Track the content you access in connection with the Service and your online behavior
• Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section ‘Your rights and options’ below.

To keep the Service safe and fair

Ensuring a level playing field in the Service is a top priority for us. In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyse and monitor use of the Service and its social features
• Moderate chats either automatically or manually
• Take action against fraudulent or misbehaving players

To analyse, profile, and segment

In all of the above cases and purposes, we may analyse, profile and segment all collected data.

With your consent

With your consent, we may process your data for explicit additional purposes.

DISCLOSURE OF PERSONAL/NON-PERSONAL INFORMATION

Apart from XI-ART, your data can be accessed by others in the following situations:

Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

Partners working for XI-ART

XI-ART has partners to perform services for us. These partners process your data only at and according to XI-ART instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising and Social Media partners

The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

GDPR CLASSIFICATIONS

Many types of data we process qualify for multiple legal bases for processing under the General Data Protection Regulation (GDPR). Below is the primary legal basis for each type of data that we process:

• We have a legitimate interest in conducting analytics, measurement of usage and conversions, and game telemetry to improve our services. We and our processors have multiple measures in place to minimize the privacy impact.
• We have a legitimate interest in storing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues.
• We have a legitimate interest in enabling third party ads and data collection on our sites and apps to help provide a more customized ad experience for our users and site visitors. Our reputable partners provide opt outs and numerous other privacy measures to minimize the privacy impact of online ads.
• We have a legitimate interest in periodic email and direct marketing, to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt outs for anyone not interested.

It is contractually necessary to process your username, email, password, cookie data, IP address, game network IDs, game information and similar information to fulfill our obligations in the terms of service to provide you with high quality games and a social game network from ourselves and our partners.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.

YOUR RIGHTS AND OPTIONS

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android).

Access the personal data we hold about you

You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information, and the law permits us to charge a fee for exercising this right of access. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 40 days of receipt of your request, evidence of ID and any applicable fee.

Right to correct personal information

We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us and we will correct it as soon as we can.

Data deletion

In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us. Please note that to ensure that we do not collect any further information you should also delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form.

Account deactivation

If you have created an account with us, you can ask us to deactivate that account by contacting us using the information above. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, will be lost and we may not be able to restore them in the future.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

HOW DO WE PROTECT YOUR DATA

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

LINKS TO NON-XI-ART WEBSITES

We may also provide you with general links to non-XI-ART websites. Your use of these links is subject to the third parties’ privacy policies, and you should become familiar with the third-party sites’ privacy policies before using the links. XI-ART is not responsible for the privacy practices or the content of those other websites.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to children or knowingly allow such persons to use our Services. XI-ART will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of “child” or “children” should take into account applicable laws as well as national and regional cultural customs.

AUTO-RENEWABLE SUBSCRIPTIONS

XI-ART outlines an auto-renewable subscription as one that allows a user to purchase dynamic content for a set period of time. Once that set period of time ends, the subscription renews again for the same amount of time. This continues until the user cancels the subscription. These subscriptions services allow users to choose their plan and the frequency of renewal. After the user makes a choice of a subscription, XI-ART requests the user to approve it. When the subscription starts, it is recorded under the user’s ID. Respectively subscription displays the date of renewal and the term. After listed, cancellation is easy. All a user needs to do is open up the particular subscription under manage subscription and hit “cancel subscription”.
In case of any queries relating to the requesting a refund or Reporting a problem relating to auto renewable subscriptions in Android platform, he is being strictly advised to contact XI-ART within 48hours of the issue/query, delaying to which the user may be refunded with only in-game virtual items not the money/amount.

LEGAL USES

We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.

UPDATES TO THIS PRIVACY STATEMENT

XI-ART may update this policy from time to time, so please review it frequently. We’ll notify you of material changes via a notice on our home page (www.xi-art.com). Your continued use of our products means you accept the changes. Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms.