PRIVACY POLICY

The privacy of your personal information is important to us. This Privacy Policy describes the ways we collect, store, use, and manage the information you provide us or we collect in connection with Awem Games products, services, apps, websites (collectively, the «Services»).

We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by posting a notice in the Service prior to the change becoming effective or by sending you an email notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.


I.CONTROLLER’S NAME AND CONTACT DETAILS

Throughout this document, “Awem Games” or “us”, or “we” refer to

Awem Games Limited (“Data Controller”)
Address: Office 302, Central Court, Mantos Mavrogenous, 8011, Paphos, Cyprus
Contact E-Mail: privacy@awem.com


II. USE OF INFORMATION

Personal information

To access the Services, Awem Games may collect information or its combination that can be used to identify you as an individual («Personal Information»), but only if you voluntarily provide it to us. The Personal Information you provide us may include, but are not limited to:

  • your username,
  • your messages to the Service (such as support tickets),
  • other data you choose to give us (such as data to identify a lost account).

Information Collected Automatically

Awem Games may use tools or third party analytical software to automatically collect and use certain information, that  may include, but are not limited to:

  • IP address,
  • browser information,
  • unique device ID,
  • hardware type,
  • the version of your operating system («OS»),
  • your device name,
  • mobile phone carrier;
  • geographical data such as country code;
  • game progress and time used playing,
  • score and achievements, any other interaction with the Service, data about all of your interactions with the game and with the other players inside the game via server log files, other information as reasonably required by Awem Games to enhance the Services.

Information from our partners

In order to perform our contract with you and when processing is required in order to comply with a legal obligation to which we are subject, we may also obtain information about you from our partners:

  • information we receive if you link a third party tool with the Service: your Facebook id, email address, photo or other image (Facebook),
  • information to fight fraud (such as refund abuse in games or click fraud in advertising),
  • information from platforms that the games run on (such as to verify payment),
  • information for advertising and analytics purposes, so we can provide you a better Service.

Cookies

The Services may use cookies to store information about your visits such as but not limited to your preferences or a username and password. You can disable cookies at any time, although you may not be able to access or use features of the services.

We may use third-party analytics providers, including but not limited to, Google Analytics (collectively “Third Party Analytics Providers”). These Third-Party Analytics Providers use Cookies on our Sites. The information generated by the Cookies about your use of our Sites, may be transmitted to and stored by Third-Party Analytics Providers’ servers, which may also be located outside of the European Economic Area. The Third-Party Analytics Providers will use this information on our behalf for the purpose of evaluating your use of our Sites, compiling reports on website activity, and providing other services relating to website activity. The terms of cookies storage by a third-party shall be established by the respective third party. Learn more from their Terms of Service and Privacy Policy.

To Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.

You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you use the Services, and some services and functionalities may not work.

Sensitive Information

We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.

Facebook Login

To access some Services, you can be asked to log in using your Facebook account. We do not have access to your Facebook login and password, since the login process runs on Facebook’s servers. You enter your username and password on Facebook website. You are responsible for safeguarding the details of your Facebook account and for any activities or actions under your Facebook login using the Services.

When you connect to the Services and/or use the Services through your Facebook account, you will be asked to permit the Service to access certain information stored on Facebook. We use your information from Facebook account only in accordance with your privacy settings you have set up under your Facebook account. Accordingly we only use the information to provide you with the Service at the given moment (but do not store) such information, which you allowed Facebook to share with third parties subject to the privacy settings that you have set in Facebook.

The Facebook’s use of Personal Information and/or information on Facebook made available by you using the Services is governed by Facebook’s Data Policy and controlled by Facebook, not by this Privacy Policy or by us.


III. HOW WE USE YOUR INFORMATION

To Provide the Services to You

To provide the Services to you and to perform our contract with you, we use your information, which is necessary:

  • to register and administer your Account, and to verify your details,
  • to provide you with the Services you request;
  • to verify and confirm payments;
  • to communicate with you about your Account and send you information about features on our Sites or changes to our policies;
  • to provide support including, but not limited to, product updates, product patches and fixes and other similar communications;
  • to arrange your participation in competitions, rewarding you with gifts and awards to which you may be entitled as a result of winning an online or offline competition, etc.

To make the Service more suitable for our users

To provide a great Service to our users, we have a legitimate interest in collecting and processing the necessary information to

  • update and develop player profiles;
  • develop and improve the Service and player experience;
  • manage our relationship with you;
  • provide social features as part of the Service;
  • customize your Service experience;
  • respond to your comments and questions and provide player support;
  • notify you and provide you with information about features on our Sites, new product releases and service developments, and to advertise our products and services;
  • provide you with special offers inside the Service as well as in other websites and services, and by email;
  • send you related information, such as updates, security alerts, and support messages;
  • enable you to communicate with other players.

You may opt out of receiving promotional communications from us. To find out how to do this, please refer to section “Request That We Stop Using Your Information”.

To Keep The Services Safe And Fair

In order to keep the Service and its social features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to

  • analyze and monitor the use of the Services;
  • take action against fraudulent, cheating or disruptive players.

If the data can be used to prove that cheating, fraudulent activity, or Terms of Use violation has occurred, we will further store the data for the establishment, exercise, or defence of the legal claims for the duration of the applicable statute of limitations.

With Your Consent

With your consent, we may process your information for additional specific purposes.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time and withdraw your consent, but this will not affect any processing that has already taken place.  Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.


IV. RETENTION OF YOUR INFORMATION

We do not retain Personal Information that can be used to identify a user beyond the time period necessary to complete the function for which information was collected. We retain your Personal Information for as long as your account is active, or as long as is needed to provide you with the Service.
Note that if you ask us to remove your Personal Information, we will retain your information as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.


V. DISCLOSURE OF INFORMATION

We share information we collect about you in the ways discussed below and only when necessary for the performance of a contract with you, compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties. While a third party may have access to your Personal Information in connection with the performance of services for Awem Games, it may not use such information for any purpose other than providing its services.

Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services. Such partners include: Amazon Web Services, Inc.

Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests. Such partners include: Zendesk Inc.

Developers of the Game Software: for the purpose of developing and supporting  the game software, we may share your nickname, e-mail, IP-address and some other information with third-party developer companies. Such partners include: AG Production Limited Liability Company, Awem Limited Liability Company

Advertising and Advertising Measurement Partners: we may share your email, nickname, IP address and other information you provide to us in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, or otherwise facilitate the transmission of information that may be useful, relevant, or of interest to you. Such partners include: ironSource Ltd., Fyber Media GmbH, AppsFlyer Ltd.

Links to Third-Party Sites: the Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you, for instance to show trends about use of the Services.

Change of control: we may share your data as part of our company’s sale, merger or change in control, or in preparation for any of these events. Any entity that buys us, or part of our business, will have the right to continue using your data, but only in the manner set out in this Privacy Policy, unless you agree otherwise.

We reserve the right to disclose your personally identifiable information as required by any law and also when we believe that disclosure is necessary to protect our rights and/or to comply with judicial proceedings, court orders, or legal process.

We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.


VI. THIRD-PARTY WEBSITES AND SERVICES

Third parties may collect your information. There are a number of places on or through the Services where you may click on a link to access other websites, services or web resources that are not affiliated or connected with us and do not operate under this Privacy Policy. For example, if you click on an ad, you may be taken to a website that we do not control. These third-party websites may independently collect information, including your Personal Information, from you. We advise you to check the privacy policies of all third-party websites you visit.


VII. AGE LIMITS

Awem Games recognizes the special obligation to protect Personal Information from children age 13 and under and does not knowingly collect such information. IF YOU ARE 13 YEARS OLD OR YOUNGER, PLEASE DO NOT ATTEMPT TO USE OUR SERVICES. If Awem Games discovers that a child age 13 or younger has provided us with personally identifiable information, we will delete that child’s personally identifiable information from our records as quickly as possible.


VIII. SECURITY

We follow generally accepted industry standards to protect the Personal Information submitted, both during transmission and once we receive it. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your information from unauthorized access or against loss, misuse or alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while our goal to use commercially acceptable ways to protect your personal information, we cannot guarantee it is absolutely secure.


IX. INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services.  Whenever we transfer your information, we take steps to protect it.

International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Belarus and allow access to that information from countries in which our owned or operated companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our customers and users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.

International transfers to third-parties. Some of the third parties described in this privacy policy that provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. When we share the information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. We will provide you with a copy of the standard data protection clauses upon your request.


X. YOUR RIGHTS AND OPTIONS

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).

Access the Personal Information (Right of Access)

If you request, we will provide you a copy of your personal data in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.

Change or Correct Your Information (Right to Rectification)

You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

Delete Your Information (Right to Erasure): You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and game-related information linked to the Account, subscriptions, and the possibility to access other services for which you are using the Account. Please note that once your Account has been deleted, you will lose your gaming experience and all related information.

Request That We Stop Using Your Information (Right to Object): Where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims.

Opt-Out of Direct Marketing: You can also opt-out of our use of your information for marketing purposes by following instructions in promotional communications or by contacting us, as explained in the section “Contact Us”.  When you make such requests, we may need time to investigate and facilitate your request. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.

Data Portability: Data portability is the ability to obtain some of your personal information in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier).  Depending on the context, this applies to some, but not to all of your data.

You may withdraw consent where processing of your personal information is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

In most instances, we will respond to all requests within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.

You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.


XI. CONTACT US

If, for any reason, you are concerned with the way that we may be using your personal information, you have questions about the privacy aspects of the Services please contact us at:

Awem Games Limited
Address: Office 302, Central Court,
Mantos Mavrogenous, 8011, Paphos, Cyprus
Contact E-Mail: privacy@awem.com.