This document “Privacy Policy” (hereinafter referred to as “Policy”) is the terms and conditions for collection and use of the Personal information of the User (hereinafter referred to also as “You”) by SPIRE CRAFT GAMES - FZCO (hereinafter referred to as “Controller”) when you use the gaming software “War Legends” that is comprised of the software programs and databases having the form of: I) software application for Android and IOs mobile devices (hereinafter – the Mobile application); II) the set of websites, forums, chats available at the sections and sub-domains of the common domain at https://spirecraft.games.
USER’S CONSENT:
By accepting this Policy, you with your own free will and for your benefit give your written consent to the processing of User’s Personal Information for the purposes and under the terms and conditions stipulated by this Policy.
1.1. This Policy is an integral part of the License Agreement for the Game that is posted and/or available on the Internet at https://spirecraft.games/terms.html (hereinafter referred to as the “Agreement”). Therefore, when executing the above said Agreement by methods defined therein including by starting the use of the Game you fully accept the terms of this Policy.
1.2. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion in the purposes established by this Policy with/without the use of automated facilities.
1.3. The terms and definitions provided for by the Agreement are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws and the business practice.
2.1. Personal Information in this Policy means as follows:
2.1.1. Information that User provides about him/her upon authorization as well as during further use of the Game.
2.1.2. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software including operating system of User’s device.
2.2. Controller is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Game. If certain information is not marked by Controller as mandatory, it is provided or disclosed by the User at his/her discretion.
2.3. To use the Game, the User doesn’t have to perform authorization and provide information about himself/herself.
Registration and authorization with the Game is implemented with use of such authentication services as Google Play Games Services и Apple Game Сenter, HUAWEI ID. Upon authorization User provides personal information through use of such authentication service as follows: identifier in relevant authentication service. In order to fill out an account in the Game, the User can also provide the following personal data about himself/herself: nickname.
To pay for the license to the Extended version of the Game via mobile operator, the User provides mobile phone number.
The User’s activity in the Game is recorded in the Game’s databases and server logs.
2.4. User acknowledges and accepts that at use of the Game depersonalized (anonymous) data may be collected automatically, including by the third party software in the Game.
The aforementioned third party software may include following analytic systems:
The above mentioned list of the third party software is not limiting. Controller may use other similar services (software) and/or cease the use of the listed one.
Anonymous data collected with such third party software may include:
The scope and conditions for collection and use of anonymous data by such software’s titleholders are determined directly by their titleholders and governed by documents available at their websites.
Accepting this Policy as well applying certain setting in his/her software including device’s operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.
2.5. Controller will not verify the reliability of the provided Personal Information and whether the User has the necessary consent for the processing thereof in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to keep such information up to date and obtain all necessary agreements of the subjects of personal data.
The legal basis on which Controller relies for the use of Personal information includes:
3.1. Processing of Personal information where User has given consent for one or more specific purposes;
3.2. Processing of Personal information that is necessary for performing a contract to which User is a party;
3.3. Processing of Personal information that is necessary for pursuing the Controller’s legitimate interests. Specifically, the Controller’s legitimate interests consist of ensuring safety and improving functionality of the Game; of data analysis; settlement of conflicts during the gaming process, protection Controller and the Users from fraud.
4.1. Controller does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Game. If Controller gets to know that the information was collected from a child under 16, Controller shall immediately delete such information.
4.2. We respect the privacy rights of parents and children, and we are committed to complying with the provisions of COPPA. If you are a parent (a person exercising parental authority) and you believe that we have collected your child's data in violation of the law, please contact us through e-mail indicated herein. We will delete this data per applicable law.
5.1. Controller performs processing, including collection and storage only personal data that is required for entering into and executing agreements with the User.
5.2. Controller is entitled to use the Personal Information for the following purposes:
5.2.1. Identification of the User within the fulfillment of the Agreement. Registered and authorized User is identified by identifier in relevant authentication service. The User that paid for the license to the Extended version of the Game is identified by mobile phone number.
5.2.2. Fulfillment of obligations under the Agreement, including providing the User with an opportunity to use the Game.
Within the scope of the relevant functionality of the Game Controller stores, organizes and displays in the Game the profiles of registered Users.
Payment for the license to the Extended version of the Game via mobile operator requires the User’s mobile phone number.
5.2.3. Marketing, statistical and other research based on anonymous data from the analytics systems stipulated in the paragraph 2.4 hereof.
Anonymous data stipulated in the paragraph 2.4 hereof is collected and analyzed to get an insight on the Users’ interests and preferences.
5.2.4. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 2.4 hereof.
Anonymous data stipulated in the paragraph 2.4 hereof may be used to provide advertisements which you can be interested in.
6.1. Subject to specific provisions of applicable law, the User has the right:
6.1.1. to be informed about the collection and use of his/her personal data.
6.1.2. to access his/her personal data and have it corrected if it is wrong or incomplete.
6.1.3. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Controller no longer needs the personal data for the purposes for which Controller has processed it.
6.1.4. to object to the processing of his/her personal data and also restrict its processing in those instances where Controller undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
6.1.5. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Controller that is based on the consent User had given before he/she withdrew it.
6.1.6. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
6.1.7. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
6.1.8. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Controller processes by automated means personal data that User has provided.
6.2. These rights may be exercised by contacting Controller with specific request through the methods described below. Controller will address any such requests in a timely manner and according to applicable law. In certain cases, Controller may ask User to verify identity before acting on User’s request. If User is unsatisfied with Controller’s response, User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.
7.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Controller will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Controller, whether or not any requests made by User from Controller have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Controller, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, Controller will update its systems.
8.1. Controller stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
8.2. With regard to the User’s Personal Information, its confidentiality is protected, except for the cases when the technology of the Game or the configuration of the User’s software provides for an open exchange of information with other Users of the Game or with any Internet users.
9.1. Controller is entitled to transfer Personal Information to third parties in the following cases:
9.1.1. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that do not limit the provision of certain information;
9.1.2. The transfer is necessary in the context of the User’s use of the Game’s functionality;
9.1.3. In connection with the Controller’s use of the services of third party providers. Such third party providers receive Personal Information under the confidentiality conditions and solely for the purposes of rendering services to Controller.
9.1.4. In connection with use in Game of third party software for collection and processing of User’s data. Specifically, Controller may use the third party software for collection and processing of User’s data according to clause 2.4. of this Policy.
9.1.5. Due to whole or partial transfer of Controller’s assets to the third party, including assignment of rights under agreements concluded with the User in benefit of such third party;
9.1.6. Upon request of a court or other state authority within the procedure established by law;
9.1.7. To protect the rights and legitimate interests of Controller in connection with failure to comply with the agreements entered into with the User.
10.1. User may send request for amendment or deletion of the Personal information to Controller to the email address stated below in this Policy.
10.2. Any questions and requests related to this Policy, use, amendment, deletion of the User’s Personal Information and/or exercising of any User’s rights with respect to the Personal Information can be mailed to Controller to the email address stated below.
11.1. This Policy may be amended or terminated unilaterally by Controller without prior notice to the User. The User is recommended to read this Policy in the current version regularly.
11.2. The new version of the Policy becomes effective upon its placement, unless otherwise provided for by the new version of the Policy.
11.3. The current version of the Policy is available at: https://spirecraft.games/privacy.html
SPIRE CRAFT GAMES - FZCO
Address: DSO-IFZA, IFZA Properties, Dubai Silicon Oasis
Email: spirecraftgames@gmail.com
Dated June 20, 2024
The UAE is outside the European Economic Area. An adequacy decision by the Commission with respect to the UAE is absent.
The representative of SPIRE CRAFT GAMES - FZCO in European Union is:
Name: Sergey Pugachev
Contacts: Azores, Lagoa Rua Almeida Garret 5, 9560-050, 1st floor
+351913459997
warlegendsrts.marketing@gmail.com