PRIVACY POLICY

ARMADA INTERACTIVE OY PRIVACY POLICY

Effective Date: June 6th, 2018

For the purposes of this Policy, the data controller is Armada Interactive Oy (“We” or “Armada Interactive”). We are registered in Finland under Business ID 2717300-8. Our registered office is at Erottajankatu 5 C 00130 Helsinki, Finland. If you have questions, requests or concerns about our Policy or practices, please contact us at legal@armadinteractive.com.

We are dedicated to protecting your privacy rights. This Privacy Policy (hereinafter the “Policy“) describes the ways We collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with all websites and web services owned and operated by Armada Interactive (the “Sites“) or any Armada Interactive games (“Service(s)“). Please note that the scope of this Policy is limited to information collected or received by Armada Interactive through your use of the Services.  Armada Interactive is not responsible for the actions of third parties, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those third parties.

By accessing our Sites, registering an account or otherwise using the Services, you expressly agree and give your consent to this Policy and to the processing of your data, including your personal information, in accordance with the terms of this Policy.  If you do not agree to these terms, please do not access our Sites, register an account or otherwise use the Services.

Personal Data We Collect

Armada Interactive’s primary goals in collecting and using information is to create your account, provide Services to you, improve our Services, contact you, conduct research and create reports for internal use. In addition, data may be used for the purpose of advertising our Services or services of our affiliates. Some of the data is provided directly by you, when/if you create an account for the Service or when submitting user content through the Services. We also get some data by using technologies such as cookies. We also obtain data from third parties, such as platform providers (e.g. Apple or Google) or social networking services (e.g. Facebook) when you grant Armada Interactive’s Services access to your data on such networks.

The data we collect may include the following:

  • Data from Social network services.  You may log in to the Services using sign-in services such as Facebook Connect or Apple’s Game Center. These services will authenticate your identity and provide you with the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities on our Services to your profile page and share such information with others within your network. We may collect and record information through the social network services in accordance with the policies and terms of that service. The information we collect when you connect your user account to social network service may include your name, your user name, your locale, city, state and country, your gender, your birth date, your email address, your profile picture or its URL, and the user identification numbers of your friends that are also connected to Services.
  • Passwords and login information.  We collect and store the password and user name of your account and similar security information used for authentication and account access.
  • Demographic data.  We collect data about you such as your age, gender, country and preferred language.
  • Device and usage data.  When you use the Services on a mobile platform, we may collect certain data regarding your device and your usage of the Services, such as:
  • Service usage data.  We collect data about you use of the Services and the virtual items you purchase and you in-game behavioral data.
  • Hardware data:  We may collect data about your hardware such as, your hardware type and your location based on your IP address.
  • Mobile Analytics.  We may use mobile analytics software to allow us to better understand the functionality of our Services on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
  • Error reports and performance data.  We may collect data about the performance of the Services and any problems you may have experienced with them. Data will be used to diagnose the problems of the Services and to improve our Services.
  • User Content.  We collect data about the user content you upload to the service, (e.g. chat messages).
  • In-game behavior.  Whenever you play our games, we collect data about all of your interactions with the game and with the other players inside the game via server log files. This information may be associated with your player ID, IP address or device ID for the purpose of providing you our Services and improving them. With your permission, we will also collect your exact location so that we are able to match you with other players in your area.
  • Customer Service.  We may collect you email address if you contact us. We may use that email address to contact you in connection with your reference and Service experience and notify you about news and promotions with regards to the Services.

Creating an Account

When you play our games, we will give you a unique identifier which we will associate with your device (“User ID”). User ID will be specific to the games played on an individual device and will remain anonymous unless you choose to add your personal information to that User ID. Other players in a game may be able to see your progress in the game and other information such as your game achievements, but no personally identifying information will be visible to other players. You can choose to add your personal information to your User ID so that you may log in on multiple devices and synchronize your progress in our games across multiple devices on multiple platforms, and also so that you may play with your friends.

Your User ID and the information it contains, such as your game achievements, will be visible to other users of our Services. If you choose to add personal information to your User ID it will be visible to your friends and other players anywhere in the world.

Connecting with Third Party Social Networks

You can choose to log into your User ID using your social network account (e.g. Facebook account) (“SN Account”). If you do this, you will be able to use your SN Account to log in on multiple devices and synchronize progress across those devices. We will receive some of your SN Account information and exactly what information we receive will depend on your settings in your SN Account. We may use this information for the purposes described in this Policy, including in order to advertise to you. Once connected in this way, you may also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress).

You can make changes to what data from a SN Account is shared with us, or stop our Services interacting with that SN Account by adjusting your settings with that third-party provider, however, you may find that you are not able to enjoy all of the same features of our Services in that event.

Legal Basis for Processing Your Personal Data

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only 1) where we need the personal information to perform a contract with you, 2) where the processing is in our legitimate interests and not overridden by your rights, or 3) where we have your consent to do so.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

We will process your information for the purposes of operating our Site and Services and communicating with you as necessary for those purposes and in our legitimate commercial interests, for instance, when responding to your queries, undertaking marketing activities, improving our Sites and Services or for the purposes of detecting or preventing illegal activities.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided above.

How We use Personal Data

We use the data we collect for three basic purposes described below in more detail: 1) to operate and improve the Services; 2) to communicate with you (including promotional communication); and 3) to show advertising.

In carrying out these purposes, we may combine data we collect from other sources such as social networks.

Operating and improving the Services.  We use the data to provide and improve the Services we offer to you. This includes operating the Services, improving the Services and developing new features to the Services. We may offer you the opportunity to invite your contacts from a social network service (e.g. Facebook) so that those contacts may be located in Services and/or you may invite them to join the Services. Such contact information will be used only for the purpose of sending communications to the addressee.  You or the third party may contact us to request the removal of this information from our database to the extent Armada Interactive stores any of this information.

Communication.  We use the data we collect to deliver and personalize our communications with you. We may contact you to provide you with promotions or news about the Services. We may also send you push notifications regarding the Services. You may opt-out from receiving these push notifications by turning off the push notifications in your device.

Advertising.  We may share the demographic and other data we gather with third parties for the purpose of personalizing the adds you see when using the Service. The adds you see may be based on your current location, your use of the Services or your demographic data (e.g. gender, age etc.). We may feature advertising within our Services. The advertisers may collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, geo-location information and IP address. They may use this information to provide advertisements of interest to you.

Third Party Tracking Tools

The third party tracking tools we use are:

  • Mobile and online measurement tools: systems & processes used for measuring user acquisition, engagement and monetization across Armada Interactive properties.
  • Customer support tools: systems & processes used for identifying and rendering Service support for users.
  • Technical monitoring tools: systems & process used for monitoring and controlling the performance of Services.
  • Website and web service monitoring tools: systems & process used for monitoring and controlling the performance of Sites.

Disclosure of YOUR Personal Data

We do not disclose your personal information to third parties, except as approved by you or described below:

  • With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies. If you no longer wish to allow us to share your information with third parties, please contact us. If you no longer wish to receive such communications from third parties, please contact that third party directly.
  • We may engage other companies and individuals to perform services on our behalf, such as analyzing data and providing customer support. These third parties may have access to your personal information in connection with the performance of services for us.
  • We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
  • We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our site of any change in ownership or users of your personal information.
  • We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.
  • We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and elsewhere and the use and disclosure of information about you, including personal information, as described in this Policy. Adequate safeguards that we or our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

Armada Interactive is not liable for the acts and omissions of third parties, except as provided by mandatory law.

Your Rights

  • Right to rectification.  If your personal information changes, or if you find your personal data stored in the Services to be inaccurate, you may correct, update, or delete inaccuracies by making the change within your account settings or by contacting us. We will respond to your access request within 30 days.
  • Right to erasure.  If you wish to discontinue using our Services you may request us to erase your personal data. We will retain and use your information only as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  • Right to access your data.  you have a right to access your personal data collected. You will be able to access your personal data through your user account. If you wish to have further access to your personal data, please contact us.
  • Opt-out of marketing emails and other direct marketing. You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
  • 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). For more information, see also: https://armadainteractive.com/partner-opt-out/.
  • Right to lodge a complaint. We will respond to all requests within a reasonable timeframe.  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority within the European Economic Area for unresolved complaints.

Changes to the Policy

We may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by posting a notice on our Sites or Services. Your continued use of Sites or Service after the effective date will be subject to the new Privacy Policy.

Security

We take reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.

Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.  Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you Services. Thereafter, We delete all aforementioned data within a reasonable timeframe. Armada Interactive does not verify the correctness of personal data.

Our Policy Regarding Children

Armada Interactive does not knowingly collect or solicit personal information form anyone under the age of 16 or knowingly allow such persons to use our Service. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.