Privacy Policy
Privacy
Policy
Last
updated: 15 February 2022
This
Privacy Policy explains how your personal data is collected and processed by
Graded Games when you use the our mobile applications (the "App").
The
App is a free to play game (with optional in-game-purchases), and in order to
maintain the high quality and a great game experience we process information
from and about you in particular to improve the entire experience in the App
and to support internal operations.
We
update this Privacy Policy from time to time. If we make changes, we will
notify you by revising the date at the top of the policy and, depending on the
specific changes, we will provide you with additional notice or require a
renewed consent.
Collection
of information
Information
we collect automatically through the app
When
you access or use the App, we automatically collect general information about
you, including:
•
Log Information: We log information about your use of the App,
including the type of device you use, the features you use, access times and
your IP address.
•
Device Information: We collect information about the device you
use to access the App, including information about the device manufacture,
device model, device's OS, time zone of device, language of device.
•
Device identifiers: We collect online identifiers of the device
you use to access the App, including IDFA, Google Ads ID, Google Device ID,
Game Center ID, Google Play Account ID.
•
Usage Information: We collect information relating to your use
of the App, including your game progress, scores, achievements and interactions
with other players.
•
Consumption information: We collect information about your
consumption habits relating to your use of the App, including which purchases
you make with both virtual and real currencies and the reception of virtual
goods in-game.
•
Information
we collect from other sources
If
you log into the App using a third party site or platform such as Facebook,
Apple Game Center and Google Sign-In, we access information about you from that
site or platform, such as your screen name, profile information and friend
lists, in accordance with the authorization procedures determined by such third
party site or platform provided that you have given the third party site in
question such consent.
•
Use
of information – purpose and legal basis
We
use information about you for the following purposes in accordance with the
legal bases for each type of personal data as described below:
•
Log-, device-, usage-, and consumption information and device
identifiers are being processed:
◦
to provide and deliver the products and services you request and
send you related information as requested by you / as agreed with you;
◦
to provide and maintain the App and the game experience; and
◦
to send you technical notices, updates, security alerts, and
support and administrative messages;
Our
processing for the above purposes is necessary for the performance of a
contract to which you are party in order to support the operation of the App,
facilitate the delivery of requested products and services and enable
maintenance and update of the App, see Article 6(1)(b) of the GDPR.
◦
to provide news and information about the App that we think will
be of interest to you;
◦
to personalize and improve the App and provide tailored content
and features;
◦
to monitor and analyze trends, usage and activities in
connection with the App;
Our processing for the above purposes is justified by our
legitimate interests in providing advertisements and content of interest to you
and improving our services in accordance with Article 6(1)(f) of the GDPR (also
known as "the balancing-of-interest rule").
◦
to provide users that have given us consent to share their
advertising IDs with our ad network partners (as further specified under
“Sharing of Information”) for the purpose of serving them with personalized
advertisement in the App (behavioral advertising).
Our
processing for the above purpose is justified by our legitimate interests in
providing advertisements and content of interest to you in accordance with
Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third
parties for the purposes of behavioral advertising is based on your consent in
accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of
Information).
•
Information from other sources are being processed:
◦
to provide and deliver the products and services you request and
send you related information;
Our processing for the
above purpose is necessary for the performance of a contract to which you are
party in order to facilitate the delivery of requested products and services,
see Section 6(1)(b) of the GDPR.
◦
to link or combine information we get from others to help
understand your needs and provide you with better service; and
◦
to provide news and information about the App we think will be
of interest to you;
Our processing for the above purposes is justified by our
legitimate interests in providing content of interest to you and improving our
services in accordance with Article 6(1)(f) of the GDPR (also known as
"the balancing-of-interest rule").
We
only process your information to the extent that is necessary to achieve the
purposes for which the information has been collected.
Storage
of information
Graded
Games will store your personal data for as long as necessary in order to
provide you with the App or otherwise fulfil the purposes as described above,
unless further storage is required in order to establish, exercise or defend a
legal claim or to comply with applicable law, including accounting rules.
Your
personal data are deleted or anonymized as soon as it no longer serves one of
the above mentioned purposes and in any event no later than three (3) years
after your interaction with Graded Games has ceased.
Children
Use
of the App is limited to users aged 13 years and above, except in European
Economic Area, where the App is limited to users aged 16 years and above. If
you are accepting this Privacy Policy and using the App, you warrant you are 13
(or 16, depends what is applicable) or more years old.
If
you have additional questions about Graded Games's privacy practices related to
children under the applicable minimum age, please contact us at
mygradedgames@gmail.com.
Security
Graded
Games takes reasonable measures to help protect information about you from
loss, theft, misuse and unauthorized access, disclosure, alteration and
destruction.
YOUR
RIGHTS
Rights
of EEU residents
We
process and answer your requests without undue delay and in any event within
one month of our receipt of the request unless a longer period is required due
to the complexity of the request. In this case, our response time can be up to
three months in total as permitted by Article 12 of the GDPR.
Right
to request access
You
have the right to request access into the data that we are processing on you,
see Article 15 of the GDPR, including information about:
•
the purposes of the processing;
•
the categories of personal data concerned;
•
the recipients or categories of recipient to whom the personal
data have been or will be disclosed;
•
the envisaged period for which the personal data will be stored.
Furthermore,
you have the right to obtain a copy of the personal data undergoing processing.
Please note that the access may be restricted due to intellectual property or
trade secrets.
The
right to object
You
have the right to object to our processing of your personal data on grounds
relating to your particular situation when the data are processed based on the
balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of
the GDPR. In this case, we will cease the processing unless there are
compelling legitimate grounds for the processing which override your interests,
rights and freedoms or if the processing is necessary for the establishment,
exercise or defense of legal claims.
You
have the right to object to our processing of your personal data for direct
marketing purposes at any time. We will cease the processing of your personal
data for this purpose after the objection.
Right
to rectification
You
have the right to have inaccurate personal data rectified, see Article 16 of
the GDPR.
The
right to restriction
You
have the right to obtain restriction of processing in certain circumstances,
see Article 18 of the GDPR. If you have the right to restriction, we will only
process your data with your consent or for the establishment, exercise or
defense of a legal claim or to protect a person or important grounds of public
interest.
The
right to withdraw consent
If
we have asked for your consent to our processing of your data, you have the
right to withdraw your consent at any time, see Article 7 of the GDPR.
If
you withdraw your consent, we will cease processing of the data for which you
have withdrawn consent, unless we have a legal obligation to keep some or parts
of your data.
The
withdrawal of your consent does not affect the lawfulness of processing based
on your consent before its withdrawal.
The
right to data portability
You
have the right to receive the personal data you have provided us with which we
process in a structured, commonly used and machine-readable format and have the
right to transmit those data to another controller if the processing is based
on consent or contract performance, see Article 20 of the GDPR.
Right
to opt out
Under
CCPA each California resident can request any business stops selling personal
information to third parties.
Right
to be informed
You
have a right to be informed about what categories of personal data we are
collecting, including the purpose of the collection. You can freely find this
information in our Privacy Policy. We update our Privacy Policy at least once
every 12 months.
Right
to deletion
You
can request us to delete the personal data we have collected on you in the past
12 months.
We
fully recognize you right to deletion, however, we would like to note that in
some cases we are obliged to keep your personal data for certain period of
time. For instance, if we need to provide services to you, detect or resolve
issues security or functionality-related issues, comply with the law, conduct
research in the public interest, safeguard the right to free speech or carry
out any actions for internal purposes that you might reasonably expect. If we
do not have obligations to perform any of the above actions, we can delete your
personal information at your request.
Data
Deletion Request
You
may request Graded Games to erase without undue delay your personal data when
it is no longer necessary for Graded Games to retain such data.
In
order for your data to be erased you can contact Graded Games by info@Graded
Games.by with request.
Right
to equal services and prices
California
residents are protected against any discrimination that a business might
subject them to based on the exercising of their CCPA rights.
We
will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
•
Deny you the App,
•
Charge you different prices or rates for the App, including
through granting discounts or other benefits, or imposing penalties,
•
Provide you a different level or quality of the App,
•
Suggest that you may receive a different price or rate for
services or a different level or quality of the App.
Contact
Graded
Games has the following contact information:
Graded
Games
Address:
Opera Business Hub, Mota Varachha
E-mail:
mygradedgames@gmail.com
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