Who we are
SBL with its seat in Poland, registered at Warszawa 02-972, ul. Prymasa Augusta Hlonda, No. 4g, lok. 18 is a producer and publisher of games for mobile devices (applications), which are available in online stores such as the iTunes App Store, Google Play Store, Amazon Appstore and Windows Store. SBL is responsible for the provision of games and related offers (e.g. support, website, competitions, newsletters, advertising, etc.) (generally referred to as Services) and for the processing of the collected data.
Personal data controller
The administrator of personal data within the meaning of the provisions on the protection of personal data in the European Union is SBL. You can contact us by sending an email to the following address: firstname.lastname@example.org or by traditional mail to the following address: SBL Warszawa 02-972, ul. Prymasa Augusta Hlonda, No. 4g, lok. 18, Poland.
TYPE OF PROCESSED PERSONAL DATA, PURPOSE AND SCOPE OF DATA COLLECTION
SBL works with Trusted Partners, developers and publishers, providers of payment methods, customer service software and other entities (hereinafter referred to as the Trusted Partners).
We will not knowingly collect personal information from children under the age of 16. If for any reason we decide to collect personal data of children between 13 and 16 years of age, we will ask for the consent of their parents or legal guardians. If you are a parent or legal guardian and have questions regarding the processing of your child’s or ward’s personal data, please contact us at: email@example.com .
The type of information collected
As part of the Egalicon game for Android and iOS mobile devices:
- user settings (language, background setting, selected colors etc)
- the number of app launches and the number of games played
- the number of times your ads were viewed, coins collected and purchases made with them
- pieces moves executed during the played game
- device ID
- in-app purchases
- game version
- date and time of the game session
- operating system (iOS, Android)
- hardware (Intel processor, ARM)
- In case of a network game. When creating an Egalicon account, we will ask you for basic personal information, including username, date of birth and email address. We need this information to enable you to use the Egalicon account features and play with other users.
When you use the Services, we may also collect the following information:
- Technical data on the devices with which you access the Services, including: internet and / or network connection data (including IP address), mobile device ID, your operating system, type of browser or other software, hardware data or other details technical provided by your browser. The above technical data about our users, their actions and patterns of behavior, will not contain personal data;
- Details of your use of the Services, including but not limited to: measurement data of when and how you use the Services, your preferences and choices for example subscriptions, your preferred language and currency, list of your Egalicon gaming friends, your chat communications , game reviews, forum posts or other services.
- Other information required to assist you with requests through the customer support system, including the content of communications between us. Objective
- In order to protect your privacy, we delete or anonymize the identifiers in our databases and most technical data after the end of the session. All other data is collected only for statistical purposes to optimize the game, to activate personalized advertising (for more information, see “Personalized advertising” below), and to offer you, as users of our services, personalized gaming experiences (e.g. adjusting the course of the game depending on the player’s behavior). The purpose of the temporary storage of data is to create a connection to game servers, which is necessary to provide the Services, and to offer you a personalized gaming experience. The legal basis is a contract with you pursuant to Art. 6 sec. 1 lit. b GDPR.
Personal data archiving period.
Users’ personal data are stored by the administrator if the basis for data processing is the performance of the contract, as long as it is necessary to perform the contract, and after that time for a period corresponding to the period of limitation of claims. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business – three years. If the basis for data processing is consent, as long as the consent is not revoked, and after revocation of consent for a period of time corresponding to the period of limitation of claims that may be raised by the Administrator and which may be raised against him. Unless a special provision provides otherwise, the limitation period is six years,and for claims for periodic benefits and claims related to running a business – three years. When using the Services, additional information may be downloaded, in particular: the IP address assigned to the user’s computer or the external IP address of the Internet provider, domain name, browser type, access time, type of operating system. Navigation data may also be collected from users, including information about links and links in which they decide to click or other activities undertaken on the website. The legal basis for this type of activity is the Controller’s legitimate interest (Article 6 (1) (f) of the GDPR), consisting in facilitating the use of electronic services and improving the functionality of these services. Providing personal data by the user is voluntary.Personal data will also be processed in an automated manner in the form of profiling, provided that the user agrees pursuant to art. 6 sec. 1 lit. a) GDPR. The consequence of profiling will be assigning a profile to a given person in order to make decisions about him or to analyze or predict his preferences, behaviors and attitudes. The administrator takes special care to protect the interests of data subjects, and in particular ensures that the data collected by him are:
- processed in accordance with the law,
- collected for specified, lawful purposes and not subjected to further processing inconsistent with these purposes,
- factually correct and adequate in relation to the purposes for which they are processed and stored in a form that allows the identification of persons to whom they relate, no longer than it is necessary to achieve the purpose of processing.
SHARING OF PERSONAL DATA
Users’ personal data are transferred to the Trusted Partners used by the Administrator when providing the Services. Trusted Partners to whom personal data is transferred, depending on contractual arrangements and circumstances, or are subject to the Administrator’s instructions as to the purposes and methods of processing this data (processors) or independently define the purposes and methods of their processing (administrators).
We have integrated advertising videos in our offers and games in various places. Advertising partners provide selected content that we play for them. We would like to point out that the free2Play system is also maintained by advertising partners, and we make every effort to implement advertising in games in the user’s interest. By watching the commercials made available, you can receive premium currency or in-game functions.
We work with the following advertising video providers:
We work with the partner Unity Technologies (Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA; Unity Technologies GmbH, Ritterstrasse 11, 10969 Berlin, Germany). Unity uses technologies to control and optimize the display of advertising videos for the user.
As part of the protective measures, only pseudonyms of the usage data are processed, in addition, the user has the right to object. If you do not want to consent to the collection of anonymised information, you can do so here https://unity3d.com/legal/cookie-policy#cookies . Alternatively, this can be done in the application in the data processing settings under the link “unity Privacy”.
In addition, we have concluded an appropriate Data Processing Agreement with Unity in accordance with the requirements resulting from Art. 28 of the GDPR, according to which both we and Unity are responsible for data processing.
In connection with the above, you can contact us and Unity if you have any questions regarding data protection and processing. Contact details can be found at: https://unity3d.com/contact/addresses
In order to secure and justify international data transfers between its own companies, Unity concluded the so-called Binding Corporate Rules (BCR). These are data protection agreements that ensure a uniform level of data protection across all companies.
The purpose of data processing is to reproduce advertising materials in order to enable the free2Play offer.
The legal basis is the so-called legitimate interest, which has been checked for the purpose and within the above-mentioned protective measures, as well as in accordance with the requirements of European data protection law pursuant to Art. 6 sec. 1 lit. f GDPR.
b) Google Admob
We use the Admob service from Google LLC., 1600 Amphitheater Parkway Mountain View, CA 94043, USA, EU seat: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
Thanks to Admob, a personalized advertisement can be displayed in the application. Using a program integrated in a given application, Google collects information from the device, mainly regarding the device, use and location. This data allows Google to select an advertisement that is relevant to your interest and display it to the user. Furthermore, Google uses this data to optimize its website. Information on data processing by Google can be found in the data protection declaration: https://policies.google.com/technologies/partner-sites .
As part of the service, Google transfers this data to advertising networks. You can find a list of these networks and their data protection declarations here: https://support.google.com/admanager/answer/9012903 .
Only pseudonymised data is processed as a protective mechanism. You can make changes to data processing in the respective application under the link “Admob Privacy”.
The use of the service is subject to the requirements of an agreement under which Administrator and Google are separately responsible for data processing: https://privacy.google.com/businesses/controllerterms/ . If you have any questions about data processing, we suggest you contact Google directly, as only Google collects personal data.
Because Google is based in the US being the so-called a third country, additional regulations are necessary to guarantee the European standard of data protection.
Google has certified under the so-called EU-US Privacy Shield and thus demonstrates an appropriate data protection standard: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
The purpose of the use of Admob and the associated data processing by Google is the use of advertising measures to enable our free offer.
The legal basis is consent pursuant to Article 6 para. 1 a) GDPR expressed by activating the videoplayer and playing advertising films by clicking on the button of the preceding page.
During the payment process, we may also share information about you with the following categories of partners who process it independently as so-called data administrators:
- Payment processors for payment processing
- Banks, financial institutions to obtain payments
- External service providers to verify payment fraud
THE RIGHT TO CONTROL, ACCESS AND CORRECT OWN DATA
The data subject has the right to access their personal data and the right to rectify, delete, limit processing, the right to transfer data, the right to object, the right to withdraw consent at any time without affecting the lawfulness of the processing that was carried out on the basis of consent before its withdrawal. Legal basis of the user’s request:
- Access to data – art. 15 GDPR
- Data rectification – art. 16 GDPR.
- Removal of data (the so-called right to be forgotten) – art. 17 GDPR.
- Restriction of processing – art. 18 GDPR.
- Data transfer – art. 20 GDPR.
- Objection – Art. 21 GDPR
Withdrawal of consent – art. 7 sec. 3 GDPR. In order to exercise the rights referred to in point 2, you can send an appropriate e-mail to the following address: firstname.lastname@example.org. In the event of a user having the right resulting from the above rights, the Administrator fulfills the request or refuses to meet it immediately, but no later than within one month after receiving it. However, if – due to the complexity of the request or the number of requests – the Administrator will not be able to meet the request within a month, it will meet them within the next two months, informing the user within one month of receiving the request – about the intended extension of the deadline and its reasons. If it is found that the processing of personal data violates the provisions of the GDPR, the data subject has the right to lodge a complaint with the President of the Office for Personal Data Protection.
The Administrator’s website uses “cookies”. The installation of “cookies” is necessary for the proper provision of services on the website. The “cookies” files contain information necessary for the proper functioning of the website, and also provide the opportunity to compile general statistics of website visits. The website uses the following types of “cookies”: session and permanent “Session” cookies are temporary files that are stored on the user’s end device until logging out (leaving the page). “Persistent” cookies are stored in the user’s end device for the time specified in the parameters of “cookies” or until they are deleted by the user. The administrator uses his own cookies in order to better understand how the user interacts with the content of the website.The files collect information on how the user uses the website, the type of page from which the user was redirected, and the number of visits and the duration of the user’s visit to the website. This information does not record specific personal data of the user, but is used to compile statistics on the use of the website. The user has the right to decide on the access of “cookies” to his computer by selecting them in the window of his browser. Detailed information on the possibilities and methods of handling “cookies” is available in the software (web browser) settings.