Effective Date: May 25, 2018
DP Games (or “we”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). This Online Privacy and Cookie Policy (the “Policy”) has been crafted to inform you as to the ways we collect, store, use, and manage the information you provide in connection with any DP Games website (collectively, the “Site”), or any DP Games game or application (the Site, games and applications are, collectively, the “Service”). Please note that the scope of this Policy is limited only to information collected by DP Games through use of the Service. This Policy does not apply to the practices of third parties that DP Games does not own or control.
DP Games offers its games also to users resident in the EU. DP Games is the data controller for personal information collected of those users. In compliance with the EU General Data Protection Regulation (“GDPR”), we have appointed DP Games Europe as our representative for GDPR purposes in the EU. Users who are resident in the EU may address questions relating to the way we collect, store, use and disclose their personal information either to DP Games at the address identified below, or to our representative at the following address 9, Allée Scheffer, L-2520 Luxembourg.
For users not located in the EU
When signing up for the Service, you are invited to agree with this Policy and the processing of your data, including your personal information, also called personal data in some jurisdictions (we refer to this information/data collectively as “personal information” throughout this Policy), in the manner provided in this Policy and our Terms of Use. We therefore process your personal information based on your consent. In any event, any use of the Service will be construed as your agreement with this Policy and our Terms of Use. If you do not agree to these terms, please do not use the Service.
Specifically for users located in the EU
This Policy is merely informative about how DP Games collects, stores, uses and discloses your personal information. We are not asking you to consent to this Policy. If we require your consent we will ask for it in separate notice and consent forms. Please note that if you provide us with consent, you have the right to withdraw this consent at any time by contacting us at dpgames@gmail.com.
It is advised that you review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).
We collect information about you directly from you, from third parties, and automatically through your use of our Service. We may combine the information that we collect about you from these various sources.
Information we collect directly from you
We will also collect any information that you provide to us through your use of our Service. The types of personal information we collect may vary depending on your activity. Personal information may include:
When you pay for products offered for purchase though the Service, we will also collect your billing address and complete credit card information that enables us to receive your payment. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Service without having to re-enter it each time. We do not directly access or store your credit card information and we will not use your payment information we collect except as needed to fulfill your purchase and/or communicate with you regarding your transaction.
If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.
Additionally, we may acquire information from you through your access and participation in message boards on the Service. This information may include posts, comments, photos or screenshots, videos, ratings, and in-game messages. If you post content to our Service, such information may be available to other users of our Service (e.g., in-game messages will be available to the recipient of your message and if you upload a profile picture, your image may be available to all other users of our Service). If you post your own content on our Service, your posting may become public and DP Games cannot prevent such information from being used in a manner that may violate this Policy, our Terms of Use, the law, or your personal privacy.
Information we collect about you from third parties
When you install any of the Service, we may collect and record the information you provide us voluntarily through a social networking website in accordance with their policies and terms.
If you log into our Service using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
If you log into our Service using Google, you must enter your Google email address and password. By logging in through Google, you are granting us access to your Google profile information, which may include your name, location, email, birthday, and any demographic data.
You may also be able to log into our Service using other third-party services, such as Mail.ru. We encourage you to read the privacy policies of third-party platforms that you use to log into your gaming accounts to understand how those third parties use and disclose your information. We have no control over how any third party site uses or discloses the personal information it collects about you.
Information we collect automatically about your use of our Service
When you use the Service, we may record information regarding the use of the Service, and we may collect other information that is visible on your social network page in accordance with the relevant terms of use associated with that page.
The Service will also record game play information such as your high scores or game session duration. When you invite new members into your network on the Service or send messages through the Service, we collect and maintain the information associated with those messages, including email address and content.
If you use the Service on your mobile telephone or other mobile device, including iPads and tablets, we collect mobile device identifiers, including Media Access Control (MAC) address, and possibly IP address. In certain games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, general location (based on your Internet Protocol ("IP") address) or e-mail address. This information is useful to us for troubleshooting and helps us understand usage trends.
Except as described in this Policy, we will not share this information with any third party. If you no longer wish to allow us to track or use this information, you may turn it off at the device level. Please note, the application may not work properly if we are unable to tell where you are coming from (country specific).
In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your account information to track the DP Games games you are playing.
Please see the Cookies section below for more information about the information we automatically collect about you.
Public Information
Some of the information you give us when you register to play our games is open to the public, such as your profile picture, number of friends, your username, the list of games that you play and the date of registration. Should you wish to hide any of the information that is made public, you can do so by changing the settings to "only me" in the privacy settings tab of your profile.
We need the above personal information for the purposes as described in this Policy, and not providing this information will have an impact on our ability to provide you with the Service. DP Games’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. This includes sending you electronic communications related to the Service, from which you can unsubscribe at any time using the instructions in such communications. In addition, we may use user information for the following purposes:
Providing and improving our Services.To facilitate payments and communications between users; to provide and maintain the Service; to improve the Service; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use the Service; and for other customer service and support purposes.
Marketing and communications.To communicate with you, including via email or push notification, about your account and use of the Service, including to send Service and product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. For more information about opting out of certain communications, please see the Your rights and choices in relation to your personal information section below.
Research and analytics.To analyze how you interact with the Service; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Protecting rights and interests. To protect the safety, rights, property, or security of DP Games, the Service, any third party, or the general public; to detect, prevent or otherwise address fraud, security or technical issues; to prevent or stop activity which DP Games, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy and our terms of use.
Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
Specifically for our users who reside in the EU, we rely on the following legal bases for the collection and use of your information:
To the extent you provide information about friends and family members, you will present them this Privacy Policy and obtain their consent to provide the information. If you do not have their consent, do not send us their personal information.
Like many services, DP Games uses server log files and automated data collection tools, such as cookies and web beacons (collectively, “Data Collection Tools”) when you access or use our Service. We tie the information gathered by these means to our customers’ personal information. These Data Collection Tools automatically track and collect certain technical information that your computer or device, such as your IP addresses, browser types, browser language, referring and exit pages, URLs, platform type, the number of clicks, domain names, landing pages, clickstream data, pages viewed and the order of those pages, the amount of time spent on particular pages, game information and the date and time of activity on our Service, and other similar information. In some cases, we will associate this technical information with your ID number for our internal use. By using our Service, you consent to our use of cookies, web beacons and Data Collection Tools.
We use cookies for a variety of reasons, including to: (i) analyze the usage of our Service; (ii) provide a more personalized experience; (iii) manage advertising; (iv) allow you to more easily login to our Service; (v) help make your use of our Service more efficient and more valuable by providing you with a customized experience and recognizing you when you return.
We may also employ web beacons or other technology for a variety of reasons such as: (i) allowing us to know if a certain page was visited or whether an email was opened; and (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.
You can set your web browser to warn you about attempts to place cookies on your computer, limit the type of cookies you allow or refuse cookies all together. We invite you to visit the support websites of the various browsers you may use to learn on how to block the use of Data Collection Tools. However, you may not be able to use some or all of the features of the Service if you refuse/disable cookies.
Our Service does not respond to Do Not Track signals. You also may opt out of interest-based advertising by following the instructions in the "Your rights and choices in relation to your personal information" section below.
Please note that third party partners/providers, such as analytics companies or companies delivering advertisements in our games or on the Service, may also use cookies or other technologies, and those practices and providers are subject to their own policies.
We use mobile analytics software to allow us to better understand the functionality of our mobile software 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. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
Our Service may contain third party tracking tools from our service providers. Such third parties may use cookies, APIs, and SDKs in our services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their services under their respective privacy policies. This Policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties. The following are examples of the third parties that we use for analytics:
Google Analytics
DP Games uses a tool called “Google Analytics” to collect information about use of this Service. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. DP Games uses the information it gets from Google Analytics to understand Service usage and patterns and to improve its Service. Google Analytics collects only the IP address assigned to you on the date you visit a Service, rather than your name or other identifying information. DP Games does not combine the information collected through the use of Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a Service, the cookie cannot be used by anyone but Google.
Google’s ability to use and share information collected by Google Analytics about your visits to our Service is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see the Google Privacy Policy. To prevent Google Analytics from using your data through a web browser, you can get the Google Analytics Opt-out Browser Add-on.
Adjust, Game Analytics and Soomla
DP Games also uses thirdparties, including Adjust, GameAnalytics, and Soomla, to help understand usage of the Service and effectiveness of our advertisements. For more information about Adjust'sprivacy practices, please see the Adjust Privacy Policy; for more information about GameAnalytics' privacy practices, please see the GameAnalytics Privacy Policy; and for more information about Soomla's privacy practices and how to opt out of Soomla's use of your information for marketing or advertising purposes, please see the Soomla Privacy Policy.
Except as set forth in this Policy, DP Games does not share your personal information with any third parties. In the event we offer services or promotions where your information is separately collected and used according to the privacy policy of a third party, we will inform you of that at the time of collection and you may elect not to participate in the service or promotion.
We will share your information with other DP Games users as necessary to provide our Services. For example, if you post a profile picture, that picture may be available to all other users of our Services.
We also may share your information with third parties as required by legal or regulatory obligations; as requested by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; or as DP Games otherwise deems necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to DP Games or others.
We may share your information with third party companies that perform services on our behalf, including payment processing, order fulfillment, data analysis, marketing services, email campaigns, hosting services, and customer service. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested service.
In conjunction with the running of our games we may partner with a third party to assist us in providing you with our Service. We will share the information you provide us through your social network, such as (1) your first and last name; (2) your profile picture or its URL; (3) your user identification number of the pertinent social network, which is linked to publicly available information such as name and profile picture; (4) the login email you provide to the pertinent social network upon registration; and (5) game play information with these third parties so they may facilitate the use of our Service as well as contact you about other games which may be of interest to you, service notifications and to solicit your feedback and input. If you do not wish to have this information shared please do not use our Service. If you wish to no longer have your personal information used by our partners you may contact us at dpgames@gmail.com and we will facilitate your request to the partner.
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
We may use and share with third party advertisers (and other third parties) certain technical information and other non-personal information to show general demographic and preference information among DP Games users. We may also allow advertisers to collect technical information and other non-personal information, which they may share with us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience). Please see the your rights and choices in relation to your personal information section below for more information about opting out of behavioral advertising.
Information about our users is an integral part of our business. We share your personal information only as described in this Policy.
Specifically for our users resident in the EU, please note that DP Games is located in Israel, a country that is deemed to provide an adequate level of data protection according to the European Commission. Where DP Games onward transfers your personal information to a company located outside of Israel or the EU, we will take steps to ensure that your information is given a similar level of protection as that given in Israel or the EU. You have the right to request from us information about, including a copy of the contractual safeguards DP Games put in place to achieve this.
The personal information we collect, as described in this Policy, is being stored on servers in the United States and is accessible to our offices in Israel, Ukraine and Russia. You expressly agree with your personal information being stored and processed in those countries.
Specifically for our users who are resident in the EU, we are not asking you to consent to the storage of your information in the above mentioned countries. Rather, we have put in place appropriate contractual safeguards to protect your personal information in compliance with applicable laws. As indicated above, you have a right to request information on those contractual safeguards.
We will keep you information for as reasonably necessary for thepurposes set out above, though generally no longer than 3 years.
We may keep your personal data for longer if required by applicable laws.
We strive to protect personal information while it is under our control. If you have an account with us, your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You acknowledge that you provide your personal information at your own risk. You are also responsible for all uses of the DP Games games and applications by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.
We have implemented commercially reasonable technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums.
In the event that personal information has been or is compromised as a result of a breach of security, DP Games will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.
To protect your privacy and security, we may take reasonable measures (such as requiring a unique password) to verify your identity before permitting you access to your account or the Service. You are responsible to maintain the secrecy of your unique password and account information, and for controlling access to your email communication or interaction through the Site or DP Games's authorized social networking at all times.
Accessing, correcting, or deleting your personal information
DP Games takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others' privacy), you can request information from us about the personal information we hold in relation to you and you can correct any inaccurate data we hold.
Furthermore, you can change or delete any personal information by changing the applicable information found in your DP Games account. However, if you decide todeleteor anonymize your personal information, you may no longer have access to certain content (e.g. information of your game progress) and your account may become deactivated.
In certain territories (including the EU), you also have a legal right to ask for a restriction of processing, to object to processing as well as the right to data portability. However, these rights are subject to conditions and may not always be applicable.
You have the right to withdraw your consent, on the basis of which we process your personal information, at any time, by closing your account or otherwise clearly indicating your withdrawal of consent. However, this does not affect our lawful processing based on your consent before this withdrawal.
Marketing communications
Subject to applicable legal provisions, we may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Service you have requested or received from us.
Push notifications
We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.
Behavioral advertising
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Pagefor information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Users in the European Union may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or App or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). If your browser is configured to reject cookies when you opt out on the DAA, NAI, and/or EDAA websites, your opt out may not be effective. Please note that if you use multiple devices you will have to opt out on each individual device.
Links from the DP Games Service to third party websites or applications are provided for your convenience. In addition, content in the Service may be hosted by other websites or applications. Any personal information you provide on the linked pages or applications is provided directly to that third party and is subject to that third party's privacy policy, not ours. These other websites and applications maintain their own policies regarding cookies and the collection and use of personal information. It is up to you to review those policies yourself.
Most of DP Games's Services are general audience and are not directed to children under the age of 13. Through these Services, DP Games does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to access those Services.
Through other Services, however, DP Games may be more likely to collect some personal information about children under 13. For such Services, DP Games will request users’ ages and, if a user indicates that s/he is under 13, DP Games will only collect personal information, such as persistent identifiers (e.g., IP address and device information), necessary for internal operations of the Service. DP Games will only use such information to support internal operations of the Service and not for other purposes.
If you are under 13, please do not attempt to register an account with any of the Services or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information other than persistent identifiers used to support internal operations of the Services, from a child under the age of 13, we will delete that information as quickly as possible. We recommend that minors over the age of 13 ask their parents or guardians for permission before sending any information about themselves to anyone over the Internet.
If you are between 13 and 16 years old, you live in the European Union or United Kingdom, and we ask for your consent, make sure that under your country’s data protection laws you are able to provide valid consent without authorization of your parents or guardian. We will verify your age and as the case may be ask for parental/guardian consent.
DP Games may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Service or sending you an email. You are bound by any changes to the Policy when you use the Service after such changes have been first posted. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the Service.
While we prefer that you contact us in case you have any issue or feel we do not respond adequately to your questions or concerns, please note that you have a right to lodge a complaint with your competent supervisory authority.