Privacy Policy

This Privacy Policy applies to Smart Project GmbH games, products, websites and related services, collectively called the Service. We respect the privacy of users and recognize the importance of protecting information collected from users. This Privacy Policy may be periodically updated by publishing a new version. Please make sure you rely on the most current version of Privacy Policy

This Privacy Policy informs how we collect, use and process the information that users provide. This Privacy Policy applies to all Services users. By using the Service, users agree that Smart Project GmbH collects, uses and processes personal information provided by users as defined below.

Please note that we do not sell User data or any other personal information.

Information Collected

When you use the Service we may collect the information about the efficiency of the Service as a whole and its single parts, whether through the Service or through social networks. When you make a decision to connect Application to your social network profile, Smart Project GmbH may collect and record the publicly available information you provide to Smart Project GmbH including your User ID and your friends’ User IDs.

We collect data you provide us: contact information (such as name and email address), username, gender, date of birth, player name and password, profile information (such as profile photo), your messages to the Service (such as chat logs and player support tickets), other data you choose to give us (such as data to identify a lost account).

Your Username, User ID, profile photos are collected if you made them public and can be seen by anyone, including people outside the social network. The first time the Service connects to a social network, we will be given the information about your preferred language and location. If you connect the Service to the social network, we may collect information you shared with the network, store it and keep it updated. The Service may update its records about your basic information including your age, language and location.

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, IMEI), data about your device, such as device name and operating system, browser type and language, data we collect with cookies and similar technologies, general location data, data about your use of the Service (such as gameplay data and your interactions with other players inside the Service). We may also create a game-specific ID for you when you use the Service.

Data we collect from our partners: data we receive if you bind to a third party tool with the Service (such as Facebook, Game Center or Google, social networks) including social network profile, your User ID and your friends’ User IDs, demographic data (such as to determine the approximate location of your IP address), data to fight fraud (such as refund abuse in games or click fraud in advertising), data from platforms that the games run on (such as to verify payment), data for advertising and analytics purposes, so we can provide you with better Service.

We collect technical data related to an End User’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier, unique identifiers that generally only identify a computer, device, browser or Application: IP address (which may also provide general location information), User agent, identifier for advertisers, Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers.

We collect information relating to the Customer’s ad campaigns and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.).

Publicly available information is not considered personal information.

Information the third parties provide us

We get the information about you from your friends in social networks as soon as they start using the Service and connect it to their profiles.

Other information we obtain

The Service has access to the information required for providing and enhancing the Service to enable Users to enjoy the Service and for the Service to work properly. We obtain and update the information about you each time you interact with the Application for example, when you start the Service, collect a bonus or make a micro-transaction via the Service.

Information regarding billing, a user's account, a user's Internet connection and the SPG software installed on a user's computer is uploaded to the server in connection with the user's use of Service. Service software automatically generates and submits to SPG bug reports upon a crash or other fault in the Service. This automatically generated bug report information may include information about other software or hardware on a user's system. We do not associate and store the automatically generated bug report information with users' personally identifiable information. Any bug reporting information manually submitted by users (e.g. through bug reporter form) is associated and stored with personally identifiable information sent voluntarily by the user through a bug report.

Service may provide chat rooms, forums, or instant messaging tools to users. Any information that is disclosed in chat, forums etc. should be considered public information, and users who message one another may not know each other personally. SPG has no obligation to keep private personally identifiable information that a user makes available to other users or the public using these functions. Users should exercise caution when deciding to disclose personal information in public forums. Users should also be aware that game play information disclosed during multiplayer game play (e.g. player name and current player statistics) is public information and may be displayed to other users.

Methods Customer Data may be collected

We collect data when provided voluntarily, when the Customer integrates SDK’s, API’s, pixels, redirect links, JavaScript tags, cookies or similar data collection technologies into their Applications, websites and/or ads, from the various advertising networks and third parties that are used by the Customer in connection with the measurement and analysis of Customer’s marketing campaigns and that have partnered with SPG.

Why do we collect your data

We collect data to make the Service work, create accounts and allow you to use our Service, operate the Service, verify and confirm payments, provide and deliver products and services you request, send you Service-related communications, to make the Service more suitable for our players.

To provide greater Service to our players, we have a legitimate interest to collect and process necessary data to: update and develop player profiles, develop and improve the Service and player experience, manage our relationship with you, provide social features as part of the Service, customize your Service experience, respond to your comments and questions and provide player support, provide you offers in the Service as well as in other websites and services, and by email, send you related information, such as updates, security alerts, and support messages, enable you to communicate with other players, display personalized advertisement, 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.

How we use the provided information

We use the obtained information about you only in order to fulfill the efficiency of options and Services you need, to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise. No personal information is provided to a third party.

We do not share any personally identifiable information with other parties except as described in this policy. We also process anonymous data, aggregated or not, in order to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. We may share anonymous data, aggregated or not, with third parties.

We do not share or disclose your data with any third party, except: upon Customer’s request, we have notified you, in particular through this Privacy Policy, to our subsidiaries as necessary to help us support and maintain the Services provided to Customers; to our service providers who help to support our Services – such as data hosting providers and payment processors; when legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements; to respond to, or prevent, fraud or to protect the safety of SPG, its Customers, End Users or the public; as part of any merger or acquisition of SPG, in which case your data may be transferred to the surviving or acquiring entity.

Your User ID allows personalization of your interaction with the Service, bringing together your profile in the Service with your profile in a social network. We also use the information about you for internal application management: for eliminating errors, data analysis, validation, research and improvement of the application functionality.

Personally identifiable information is used internally by SPG to deliver, develop and improve products, content and services, to answer users' requests, to establish matches between devices used by you; to detect fraud and to ensure more accurate attribution measurement and ad fraud protection for Customers using the Services. In addition, we may allow third parties performing services under contract with SPG, such as order or payment processors or merchandise warehouse and fulfillment services, located in and outside the European Union, to access and use personally identifiable information, but only to the extent necessary to provide Service.

We may use data provided by users to send them information about SPG, including news about product updates, contests, events, and other promotional materials, but only if the users agree to receive such communications.

Age Limits

Smart Project GmbH will not knowingly collect personally identifiable information from any person under the age of 15.

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 15 or knowingly allow such persons to use our Service. If you are under 15, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 15 may provide any personal data. If we learn that we have collected personal data about a child under age 15, we will delete that data as quickly as possible. We encourage parents to instruct their children to never give out personal information when online. If you believe that we might have any data from or about a child under the age of 15, please contact us.

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. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

Cross Border Transfers And Eu-Us And Swiss-Us Privacy Shield

Smart Project GmbH may need to transfer Customer Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws. With regards to the collection, use and retention of personal data transferred from the European Economic Area or Switzerland to the United States, we comply with the EU-U.S. and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce.

Who Can See Your Data

Apart from SPG, your data can be accessed by: other players and users may, for example, see your profile data, in-game activities and read the messages you have posted; our partners to perform services for us. These partners process your data only at and according to our instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention; 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.

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.

Your Rights And Options

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. You can opt-out of interest-based advertising on mobile applications by sending the request to our e-mail mentioned herein. For personalized in-game offers opt-out, you can use the options provided in the game settings. You also have the right to correct your data, have your data deleted, object and restrict how we use or share your data.

You have the following rights: to withdraw any previously provided consent; to access certain information about you that we process; to have us correct or update any Personal Information; to have certain Information erased; to have us temporarily block our processing of certain Information; to have Information exported into common machine-readable format; to object to our processing of Information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and to lodge a complaint with the appropriate data protection authority.

We will respond to all requests within a reasonable timeframe set out under applicable laws. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us immediately as described in this Privacy Policy. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions: (1) Your request should be in writing; (2) Provide sufficient information to enable Smart Project GmbH to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information. We rely on user game account access to verify the user identity and avoid unauthorized logins. Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request.

We have the right to refuse to process requests that are not meaningful/entangled, requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

Cookies And Similar Technologies

Like most online services, we and our partners may 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.

Security

Smart Project GmbH is concerned with safeguarding your information. 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.

Smart Project GmbH will retain your data for as long as your account is active or as needed to provide you the Service. Generally, this period equals the period you use the Service or have an application installed on your mobile device or PC. 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. We shall delete your data upon a request to delete the data.

Personally identifiable information provided to Smart Project GmbH by customers in the EU is controlled by Smart Project GmbH, with place of business set out below. Personally identifiable information provided to Smart Project GmbH will be collected, processed and stored by Smart Project GmbH in Switzerland and Germany.

Changes

We may update this Privacy Policy from time to time. Any material changes will be available to the Customer either through the Services, email or as otherwise agreed by the parties in the Agreement. We will also indicate that an update has occurred on the top of this page so you are encouraged to review this Privacy Policy from time to time. All previous versions of this document are stored in the archive.

Contacts

For any questions relating to this Services Privacy Policy or to contact our data protection officer please send us a mail to: support@smartproject.ua. You may also send us or our data protection officer regular mail: Kirchstrasse 52,Liebefeld, Switzerland, 3097

Effective date: 24 November 2020