PRIVACY POLICY

Last Updated: September 12, 2022

This Privacy Policy describes our approaches to the processing of information we get about you that can directly or indirectly identify you (the “Personal Data”) when you use our mobile games (each hereinafter referred to as the “Game”).

Vandrouka Games LTD (the “Vandrouka Games” or “we”, “us”, “our”) acts as a data controller.

Our contact details are:

Address: Spyrou Kyprianou, 78, MAGNUM BUSINESS CENTER, Floor 3, 3076, Limassol, Cyprus

E-mail: support@vandrouka.games

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE GAME

In this Privacy Policy we explain, among other issues:

How we collect and use your Personal Data
When we can disclose your Personal Data to third parties
How long we retain your Personal Data
Your rights and the way you can use them

This Privacy Policy may be updated from time-to-time to keep it in conformity with the Regulation of the European Parliament and of the Council (EU) 2016/679 (the “GDPR”), California Consumer Privacy Act, California Civil Code sections 1798.100 et seq. (the “CCPA”) and other relevant legislation. We will notify you if we make any material changes to our Privacy Policy. If such changes make it necessary to obtain your explicit consent for further processing of your Personal Data, we will request your consent or your renewed consent (in case it was obtained previously).

Collecting and Using Your Personal Data

We only collect and use your Personal Data as specified below:

1. Ensuring proper use of Game, including the ability to monitor and troubleshoot technical issues

Personal Data:

User ID
Technical data such as IP address, device ID, general location data, device model, date and time of access (the “Technical Data)”
Information about how you use the Game, i.e. (i) date and time of the beginning and end of game sessions, (ii) game state (number of game resources at User ID, its level, amount of game currency, XP experience) at different moments of the game, (iii) game settings (language, sound and music mode), (iv) notification settings (what game events the user wants to receive push notifications), (v) purchases of in-game resources paid for with game currency and paid for with real money (In-App Purchases) (the “User Data”)

Legal basis for the processing: Terms of Use

* Without providing this data you will not be able to use Game

2. Linking your Used ID to Facebook and/or Apple account

Personal Data:

You can optionally link a User ID to your Facebook or Apple account. This allows you to restore your game

on another device. We generally do not receive any Personal Dara from Facebook or Apple, but in any case,

it depends on your privacy settings in your Facebook or Apple account

Legal basis for the processing: Terms of Use

* Without providing this data you will be able to use Game, but not be able to get the additional feature

as described herein

3. Communicating with you

Personal Data:

E-mail, or
Phone number, or
Any other information that you have made public in the messengers you used to contact us at the time
of contacting us (name, photo, etc.)

* depending on what way of communication you choose

Information that you provide us with when you contact us

Legal basis for the processing: Our legitimate interest in receiving communication from you and reacting to it and your interest in getting

our response

4. Managing and optimising users’ experience by improving our knowledge of our users

Personal Data:

Technical Data
User Data

Legal basis for the processing: Our legitimate interest in evaluating and creating statistics on the use of Game and your interest in the Game updates which will be tailored to your needs

5. Providing you with advertising, including that is relevant to your interests

Personal Data:

Technical Data
User Data

Legal basis for the processing: Our legitimate interest based on the balance of interests while you have absolute right to object to direct marketing.

We do not collect or have any access to your Payment Data. When you make purchases in the Game,

such information is processed by the app store where you downloaded the Game (e.g. Apple’s Game

Store, Android’s Google Play).

Disclosure of Your Personal Data

Like most companies, we use tools from service providers that help us to support the Game and make the Game better for you. For that end, these service providers may have access to some of your Personal Data. List of such providers includes:

Google Firebase,

provided by Google, Inc. – mobile and web app development platform that offers several integrated

features such as a mobile app server, analytics tools, app promotion and monetization tools

Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA

Unity Analytics,

provided by Unity Technologies – data platform that provides analytics for Unity games

30 3rd Street, San Francisco, CA 94103 (United States contact)) or Unity Technologies ApS (address:

Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark (European Union contact)), DPO@unity3d.com

Devtodev,

provided by UAB Dev2dev – full-cycle analytics solution for app and game developers

Vilnius Tech Park, Antakalnio 17-4, Vilnius, Lithuania, 10312

Google Analytics,

provided by Google, Inc. – web analytics service

Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA

Appsflyer,

provided by AppsFlyer – SaaS mobile marketing analytics and attribution

platform to the attention of Legal Team/Data Protection Officer, 14 Maskit St., Herzliya, Israel, 4673314

Google AdMob,

provided by Google, Inc. – advertising service

Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA

Facebook Ads Manager,

provided by Meta Platforms, Inc. – tool that allows to create and manage ads

1601 Willow Road, Menlo Park, CA 94025, USA

We may also disclose your information when required to do so by law in connection with any legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal

rights (including providing information to others for the purposes of fraud prevention).

Retention of Your Personal Data

We retain your Personal Data for as long as needed to fulfill the purposes indicated in the section

“How do we process your Personal Data”. In certain cases, we may retain your Personal Data for a longer period when needed to comply with our legal obligations, to resolve disputes, establish and defend legal claims.

No Automated Decision-Making or Automated Profiling

We neither use automated decision-making nor refer to the automated profiling.

Rights that You have and the Way You Can Exercise Them

For EU residents:

The right of access: You may ask what data concerning you is kept by us and receive a copy of it, as well as other supplementary information.

The right to rectify the data: You may request at any time the modification of your personal data that you believe is inaccurate or not up to date.

The right to erasure of your Personal Data: You may request the deletion of data concerning you at any time. Please note, that we can retain your Personal Data if necessary to comply with our legal obligations or resolve disputes. If we have no grounds to continue processing your Personal Data, we will delete or remove it and notify you about such deletion or removal.

The right to restrict processing of your Personal Data: You may request the limitation of the processing of your personal data when one of the following applies: (a) the accuracy of the Personal Data is contested by you, (b) the processing is unlawful and you oppose the erasure of the Personal Data, (c) we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, and (d) you have objected to processing pending the verification whether the legitimate grounds override this.

The right to data portability: You may be entitled to obtain your personal data in a structured, commonly used and machine-readable form in order to transfer it to another data controller. Please note that this right only applies to information that we processed based on your consent or Terms of Use.

The right to object to the processing: You may object to the processing of personal data concerning you, where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to the processing on this ground. We will no longer process the Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to withdraw consent: You may withdraw your consent at any time where we are relying on the consent to process your Personal Data. If we have no other grounds for processing your Personal Data, after you send us a request to withdraw consent, we will stop processing your Personal Data that we were processing under your consent.

We aim to address your requests as early as possible and will do it not later than in 1 (one) month. Please note that in complex requests we might need to extend the answering time by a further 2 (two) months. In this case, we will notify you about the extension within 1 (one) month of receipt of your request and will explain you the reasons for such extension.

We may collect personal information about California residents who are afforded additional rights under the CCPA.

For California residents:

The right to opt out. Under the CCPA each California resident can request business stops selling Personal Data to third parties.

Please note that we do not, and will not, provide your Personal Data in direct exchange for money. Therefore, in the literal sense, we do not sell your Personal Data.

Other rights. You also have a right to be informed about what categories of Personal Data we are collecting: you can request us to disclose what Personal Data we have collected in the past 12 (twelve) months and right to get a free copy of your Personal Data disclosed in a readily usable and readable format. You can also request us to delete the Personal Data we have collected in the past 12 (twelve) months. We will not discriminate against you for exercising any of your rights granted under CCPA.

Mandatory Verification: As required by CCPA we will need to verify your identity before processing your request. In order to verify your identity, you will be asked to log in to your account or (if you do not have an account) we will try to match the information you provided with the information we handle about you. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you have requested us to delete your Personal Data.

As required by CCPA we endeavor to respond to a verifiable request within 45 (forty-five) days of its receipt.

If we require more time (up to 90 (ninety) days), we will inform you of the reason and extension period in writing. We will deliver our written response by e-mail.

How to exercise any of your rights? You may exercise your rights by sending a relevant request to the e-mail indicated in the contact details.

If you have any comments about how we process your Personal Data, please let us know and we will consider your claim. If you are not satisfied with our response to the complaint, you have the right to file a complaint with the competent authority.

Children’s Personal Data

We do not knowingly collect or solicit information form children under the age of 13 (or 16 – for European Economic Area residents) and do not knowingly allow such persons to use the Game. If we discover that we hold Personal Data of a user under 13 (or 16, where applicable), we will promptly delete such data from our records.

If you are under the age of 13, please do not provide any Personal Data to us.

If you are aware of anyone younger than 13 (or 16, where applicable) using our Game, please let us know and we will delete Personal Data about this person as soon as possible.