Last modified: February 14th, 2020
• what types of information we may collect or that you may provide;
• how we process, store, and use the information and with whom we share it;
• how you can access and update that information or request its deletion;
• the choices you can make about how we collect, use, and share your information;
2. About Us
We are a company called UltimaPlay, LLC organized under the laws of Ukraine. Our registered address, Chervonopolska Street, 23/17, office 2, Kiev, 04123 Ukraine. We develop and distribute our games throughout the world in cooperation with other companies operating pursuant to a contract with UltimaPlay.
3. Information We can Collect and How We can Collect It Information We can Collect Automatically When You Play Our Games or Use Our Services
(a) On a Mobile Device
When you access our games and Services from your mobile device, we can automatically gather the following categories of information:
• Unique Player ID. automatically created for you by our game server. This ID is used, for example, for identifying your in-game actions, tracking your progress, and matching your purchases to your account. This information is what allows us to assist you if needed, such as correcting any errors with in-game purchases or assisting you to restore your progress.
• Device Information. We can collect certain types of information about your mobile device and internet connection for the purpose of game analytics, optimization of our games and Services for various devices, selection of appropriate localization version for your device, to offer you relevant promotions within our games and Services, and for marketing and advertising purposes as described in more detail below. We can collect and process the following:
o platform type/store you use for app purchases, such as iOS, Google, Amazon, etc.;
o information about your operating system;
o unique device identifier generated from the device, if permitted by your device settings, like your MAC Address, Identifier For Advertising (IDFA), Google Advertising ID (GAID), unique device identifier (UDID), and/or International Mobile Equipment Identity (IMEI);
o your IP address to determine the country;
o the country in which you are located;
o information about the make and model of your device;
o the language settings of your device;
o unique IDs for push notifications.
• Usage Details. We can collect the following types of information about your gameplay for game analytics and improving our games and Services by making them more responsive to your needs and to provide customer support:
o date and time you installed our game or Service;
o date and time you accessed our game or Service;
o your game progress and various in-game activities, such as, for example, spending in-game currencies; o system and game error reports.
• Payment Information. If you make in-game purchases, we receive limited information about the payment, such as unique transaction ID, date and time of payment, and the payment amount. We need this information to resolve any errors that may occur with payment processing through the appropriate store or platform to ensure that your purchase can be applied to your account.
• Creating a User Name. UltimaPlay provides you an option to create a nickname, which will be matched with your game profile, for the purposes of in-game competitions and leaderboards.
• Logging In with Social Network or Other Accounts. Where we make this available, you can choose to log in to your game profile using your account details with a third party network, such as Facebook, Apple Game Center, Google Play Game Services, or Amazon Game Circle. If you do this, you will be able to use your account to log in on multiple devices and synchronize progress across those devices. Where available, you will 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), or access other functionality we make available in our games and other Services, such as inviting friends to play or sending in-game gifts. If you choose to login with a social media or other account, we will also receive your first and last name, photo, and a list of your friends who play the same game or use the same Service. We will also receive access to your e-mail address, if the social media platform shares it, but we will not store it. You can control what information is shared with us from your social media account by reviewing the privacy controls on the appropriate third party network.
(b) On a Social Network
If you play UltimaPlay’s games or access any of our other Services on a social network like Facebook, UltimaPlay receives certain information about you from the social network automatically. The information we receive depends on the UltimaPlay game you are playing, the social network, and your privacy settings and your friends’ privacy settings on that social network.
We will automatically gather the following information when you play our games or access our Services through social media networks:
• Unique game ID automatically created for you by the social network. This ID is used, for example, for identifying your in-game actions, tracking your progress, and matching your purchases to your account. This information is what allows us to assist you should you encounter any issues with the games, such as correcting any errors with in-game purchases or assisting you to restore your progress.
• Device Information. We collect certain types of information about your device and internet connection for the purpose of game analytics, optimization of our games and Services for various devices, selection of appropriate localization version for your device, to offer you relevant promotions within our games and Services, and for marketing and advertising purposes as described in more detail below. We collect and process the following:
o platform type/store, such as Facebook or other social network;
o information about your operating system; o information about the computer you are using; o your IP address to determine the country; o the country in which you are located;
o the language settings of your device.
• Usage Details.
We collect the following types of information about your gameplay for game analytics and improving our games and Services by making them more responsive to your needs and to provide customer support:
o date and time you installed our game or Service;
o date and time you accessed our game or Service;
o your game progress and various in-game activities, such as, for example, spending in-game currencies;
o system and game error reports.
• Payment Information.
If you make in-game purchases, we receive limited information about the payment, such as unique transaction ID, date and time of payment, and the payment amount. We need this information to resolve any errors that may occur with payment processing through the appropriate store or platform to ensure that your purchase can be applied to your account.
• Creating a User Name.
UltimaPlay provides you an option to create a nickname, which will be matched with your game profile, for the purposes of in-game competitions and leaderboards.
When you choose to play our games or use our Services on the desktop version of Facebook or other social network, we will receive some of your account information, which will be automatically associated with your game profile. The kinds of information we will receive depends on your settings on your social network account, but generally your first and last name, profile photo, and a list of friends who play the same game or use the same Services. We may receive your e-mail address if the social network provides it, but we do not store it.
Information You Provide to Us
When you download our games or use our Services, we may ask you provide certain types of personally identifying and non-personal information. This may include:
• Information you provide to us when you enter a contest or promotion sponsored by us, and when you report a problem with the Services;
• Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us;
• Details of transactions you carry out through the Services and of the fulfillment of your orders.
If you purchase a license to use in-game virtual currency or virtual items in a game you play on a social network or that you downloaded on your mobile device, UltimaPlay does not receive or store any billing and payment information that you provide when your purchase is processed by a mobile app store (like Apple or Google) or by the social network (like Facebook). Please note that purchases of third-party credits or currencies may also be subject to those parties’ policies.
Customer Support Correspondence
When you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play and activity on our Services, and your UltimaPlay player and/or social network ID number, and other information as may be requested by our Customer Support team in order to assist you, such as screenshots or payment transaction ID. We will also store all communications you have with the Customer Service team and any information in those communications in order to provide support.
For your convenience, we provide the option of contacting our Customer Support from the mobile applications and the desktop Services. If you choose to use our in-game or in-Service interface, some information will be added to your support ticket automatically, such as your unique player ID assigned to you when you downloaded the game, platform, information about your operating system, information about your device or desktop computer, and your screen size.
Marketing and Advertising
Our games and Services may include advertising for third party products and services, and we, or our third party partners, may send you marketing communications about other UltimaPlay games and related services based on your interests. For example, we may serve ads within our games and Services or place ads on third party websites or apps. Unless you opt out as explained below, you consent to us and our advertising partners collecting and using information about you to improve marketing and advertising so that we can show you relevant third party ads in our games or Services.
We and our third party partners use ad identifiers, such as ID for Advertisers (IDFA), Google Advertising ID (GAID), or unique device identifier (UDID), and other information collected from your devices, social networks, and provided by you to offer you ads that may be relevant to you within our games and Services.
When you play our games or use our Services, the ad identifiers and other information from your device is collected and shared with advertising partners to enable the delivery of ads to your device. Our marketing and advertising partners may combine such information with data they collected from you elsewhere (for example when you used their services) and use it to serve you more relevant ads or to improve the accuracy of their targeting and measuring systems.
Opting out of interest based advertising and marketing will not prevent you from being able to play our games or use our Services and will not disable the advertising within the games or Services, but such ads will no longer be targeted based on the information that we hold about you. The ads may still be based on the game you are playing or the Service you are using or the region in which your device is located.
Information From Third-Party
Games When you play Third-Party Games, we do not automatically collect, process, store, or use all of the categories of information recited in this section. As a publisher, we only have limited access to aggregated depersonalized data. We receive such information from the platform you use to access the games (for example, iOS, Google, Amazon, or Facebook) or from third-party analytics tools, such as Appsflyer. The information that is collected by the platforms and third-party analytics tools is, in turn, governed by their respective privacy policies.
Information we receive in these circumstances is fully aggregated and depersonalized and could not be used to identify any specific user. For example, we can see the average number of game sessions by all users of a game on a specific day, number of users who started the game on a given day or in any given month, and how long on average all users play a specific game. This information allows us to work with our partners to improve the services we offer to you to provide you with the best game experience.
4. How We Use Your Information
We can use information that we collect about you or that you provide to us, including any personal information, to:
• operate, improve and optimize our Services and our players’ experiences;
• provide technical support and respond to players’ inquiries;
• protect UltimaPlay’s rights and property in connection with the Services and enforce the terms;
• notify you when in-game updates, new products or promotions become available;
• comply with our legal obligations, resolve any disputes we may have with you or other players, and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, or between us and third parties;
• conduct research;
• and fulfill any other purpose for which you provide it. The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual interests;
• Recognize you when you use the Services.
5. Sharing Information
We may disclose or publish anonymous aggregated information about our users (information about you and other players collectively that is not intended to specifically identify you) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, and advertising and other business purposes.
In addition, we may disclose personal information that we collect or you provide:
• To our subsidiaries and affiliates, contractors, service providers and other third parties we use to support our business. We contractually require these third parties to maintain the confidentiality of the information we share with them, and we contractually require them not to use your information for anything other than to provide services on our behalf.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• To facilitate your interactions with your friends on social networks. If you play through a social network, your social network friends will see your name, profile photo and descriptions of your game activity.
• With your consent.
• To provide you with Offer Walls. UltimaPlay games or their purchase pages may display an “offer wall” that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to players in exchange for interacting with an advertisement or completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by UltimaPlay. These offers may be made available to you based on certain technical information, like your geographic area or de-identified demographic information. To properly credit your player account and to prevent fraud, a unique identifier, in some cases your social network ID or UltimaPlay player ID, will be shared with the offer wall provider.
• To comply with any court order, law or legal process, including responding to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the Services EULA and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the UltimaPlay, our customers, or others.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the UltimaPlay’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by UltimaPlay about our players is among the assets transferred.
6. Your Choices about Our Collection, Use and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
• Information from Social Networks. To manage the information UltimaPlay receives about you from a social network, like Facebook, where you play our games or with which you link a game on your mobile device, you will need to follow the instructions on that site for updating your information and changing your privacy settings.
• Information from Your Mobile Device. You can manage some aspects of information collection and use by visiting the “settings” menu of your mobile device and reviewing the permissions for each application or “app.”
If you want to review, delete, or change the information UltimaPlay has about you or have additional questions, e-mail us at firstname.lastname@example.org. Please note that certain records, for example those related to customer service matters, will be held for legal and accounting purposes.
7. Legal Bases
Every time we collect and process your information, we do so in accordance with on of the following legal basis:
• Contractual Necessity—for data we use to provide you with Services you have requested;
• Legal Obligation—for data we use to comply with our legal obligation or to respond to a lawful request for information;
• Legitimate Interest—for data we use for purposes that are not harmful to your privacy and can be reasonably expected from the context of your use of our games and Services, such as analytics, research, marketing, advertising, and continuous improvement of our games and Services; and
• Consent—you consent to collection of data when you install our games and you can withdraw your consent at any time by uninstalling our games.
8. International Operations and Transfers of Information; Retention
We can store your information on servers, which are primarily based in Netherlands. We may also use servers and engage providers that are located outside the EEA, including in the Ukraine, United States and Russia, in order to process and store your information and to provide services to us. As part of our international operations, we may transfer data from time to time to affiliated entities or third parties to jurisdictions outside the EEA. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored may be different from the privacy laws applicable in the country where 10 you reside. We take steps to ensure that there are adequate safeguards and mechanisms in place to allow the transfer of your information across borders outside of the EEA.
9. Data Security
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
11. Contact Information