Privacy Policy

Version 21.12.2021

Thank you for playing the games and game services developed and/or published by Elena Titarenko (the “Game” or “Games”). In this Privacy Policy “You” and “Your” refer to you, the person playing our Games and using other related services of Elena Titarenko (hereinafter referred to as “Services”). “We”, “Us” and “Our” refer to the staff, sites, and other resources of Elena Titarenko and all its affiliates provided in this Privacy Policy. By playing our Games and using our Services, you agree with the provisions of this Privacy Policy.

1. What Information Is Collected?
We may collect and process the following categories of personal data :
a) Contact information (such as name or nickname or email you submit as part of your register for our Services or log-in or via social networks);
b) Data about the build version, your account, game progress and in-game events;
c) Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
d) Data about your device, such as manufacturer, operating system, CPU and language, current time;
e) Broad location data (e.g. country or city-level location);
f) Precise geolocation data (GPS, with your consent);
g) Usage data;
h) Purchase history, including details of orders (purchase ID, amount spent, currency, date, time, vouchers or offers used);
i) Data from platforms that the games run on (such as to verify payment);
j) Data for advertising and analytics purposes, so we can provide you with a better Service;
k) Your email address and your messages to the Services;
l) Other data you choose to give us.

We may automatically collect certain information whenever you interact with our Services, including:
- Cookies. Cookies are small pieces of information stored on your device’s hard drive which work by assigning to your device a unique number that has no meaning outside of the Services.
- Third-Party Platforms: When you connect your account to external platforms, we may receive data from those platforms.
- Social Media Integration: If you use social media login to create your account or share Services content on social media, we may collect data from those platforms.
- Advertising Partners: Our advertising partners may provide us with data about your interests and preferences to help us deliver targeted advertising.
- Analytics Providers: We work with third-party analytics providers who help us understand how users interact with the Service.
- Customer Service/Technical Support Platforms: We may work with third-party platforms and service providers to assist in providing customer and technical support, as well as community and social media management.
When any third parties share personal data with us, we will process that personal data according to this Privacy Policy.
Third-party services, such as platform providers, social media networks, and advertising partners, have their own privacy policies that govern their data collection and use. We recommend reviewing the privacy policies of any third-party services you engage with through the Services, since this Privacy Policy only cover Our data processing practices.

2. Why do we collect Your personal data
Type of
personal data		 Examples Purpose of
processing		 Legal basis for
processing
Account
information		 Usernames, names, location, birth date, profile pictures and avatars, and other identifying information

Contact information, such as your email address,

Security information, IP addresses, and other information related to the security of your account,

Payment and purchase information related to your
purchases on the Service		 To create and maintain an Account for you on the Service, or to allow you to play games and otherwise provide you with the Service.

To provide customer support and technical support to you.

For marketing and promotional activities, including operating
contests, sweepstakes, and marketing campaigns and
newsletters.		 Performance of a contract (GDPR Art. 6(1)
(b))

Legal obligation
(GDPR Art. 6(1)
(c))
Device
information		 Device information, such as your hardware model and operating system

Unique device identifiers (such as an Advertising ID or IP Address)

Network information, including information about where you accessed the Service, access times, pages and portions of the Services viewed		 To operate the Services and
ensure that it functions properly on your device

For analytics purposes

To provide customer and technical support to users

To make improvements to the Service		 Performance of
a contract
(GDPR Art. 6(1)
(b))

Legal obligation
(GDPR Art. 6(1)
(c))
Gameplay/
Analytics
Information		 Information about your gameplay, such as your in-game
progress, the games modes
you have played, matchmaking
times, and information about other Accounts with whom you
played online matches.		 To operate and improve the Services Performance of
a contract
(GDPR Art. 6(1)
(b))
Advertising
Information		 On portions of the Services which display interest-based advertisements, we may collect your device's unique Advertising ID or similar information To allow interest-based advertisements on certain portions of the Services Legitimate
interests (GDPR
Art. 6(1)(f))
Third-Party
Platform
Information		 Any information which is shared
with us by the third-party
platform that you are using
the Services on, such as the
Apple App Store, Google Play
Store

Any information, such as your
username and other third party
account information, which is
provided by a social media
platform (like Facebook) or third-party login service (like a
Google sign-on), that you connect
to the Service		 To create and operate your
Account on the Service

To operate and improve the
Service

To connect and offer sharing
functionality on the Service

To ensure that any purchases
are credited to your Account

To contact you for customer
support and technical
support purposes, and
other Service-related
purposes		 Performance of
a contract
(GDPR Art. 6(1)
(b))
3. How information is used, shared and disclosed. In order to operate the Services, we need to share certain personal data we collect from you with third parties, including: 4. How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of Services to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.

5. Transfer of your personal data

Regardless of your location, by using the Service, you acknowledge and consent to the processing and transfer of your personal data to countries where We have facilities or engage service providers. The countries where cloud servers are located may have data protection laws that differ from those in your country of residence. Safeguarding your personal data is extremely important to Us. To protect your privacy, we take all reasonably necessary measures when transferring your personal information to another country. We do this according to applicable data protection laws and in line with this Privacy Policy. We use various methods, such as implementing appropriate safeguards, and including the use of European Commission-approved standard contractual clauses and other contractual provisions, to ensure that we give your personal data necessary level of protection. Note that in some cases, certain parties (such as courts, law enforcement, and regulatory agencies) in the countries where your data is transferred may be legally entitled to access Your personal data.

6. Security

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once it is received. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, Elena Titarenko and its third-party partners and vendors take appropriate security measures to protect against unauthorized access or disclosure of the information collected by Elena Titarenko. For Elena Titarenko, this includes, but is not limited to, ensuring that all personal and Financial Information is disclosed only on a “need to know” basis and ensuring that all Personal Information collected by Elena Titarenko is done so via secured connections and protected and encrypted (using secure socket layer technology, “SSL”) by industrial grade security software to guard against unauthorized access.

7. Children’s privacy

We do not knowingly collect Personal Information from children under the age of 13 without parental consent. We require Device owners to specify their age before any Personal Information is collected. Parents have the right to consent to collection and use of Personal Information from their child without also consenting to its disclosure to third-parties, as Elena Titarenko does not share information that may be collected from your child.
If we become aware that Personal Information has been collected from a child under the age of 13, we will delete this information as quickly as possible. If you believe we may have collected Personal Information from or about a child under the age of 13, please contact us.

8. Your Rights

You as the data subject have the following rights relating to the processing
of Your personal data:
- Right of access: You have the right to request access to your personal data and information about how we process it.
- Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
- Right to erasure: You have the right to request that we delete your personal data in certain circumstances.
- Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in certain situations.
- Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
- Right to object: You have the right to object to the processing of your personal data in certain circumstances, such as for direct marketing purposes.
- Right to withdraw consent: You have the right to withdraw your consent to the processing of your personal data at any time, where processing is based on your consent. This will not affect the lawfulness of processing prior to the withdrawal of your consent.

To exercise any of these rights, please email us at titarenkodev@gmail.com. We may ask for additional info to verify that you’re the owner of the data.

9. Changes to this privacy policy

We may update this privacy policy to reflect changes to information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on Our website, www.titarenkodev.com prior to the change becoming effective. We encourage you to periodically review this page for the latest information on its privacy practices.

10. Contact us

If you have questions or comments regarding how we protect your information, please contact us at:
e-mail: titarenkodev@gmail.com
Address: Tikhvinskiy per 6-6, Moscow 127055, Russia