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Privacy Policy for our Games

Privacy Policy for our Games

Xi4G Sp. z o.o., located at Św. Mikołaja 51/52, 50-127 Wrocław in Poland (“Xi4G” or “we”), is a developer and publisher of games and mobile games made available on iTunes App Store, Google Play and Amazon Appstore, also on other platforms in the future, such as Facebook (our “Games”).
Xi4G is responsible for providing Games and related services (such as our website, support services, competitions, advertising etc.) (collectively, the “Services”) and for data processing. In this data privacy policy, we will share with You the meaning of terms, such as “personal data” or “personally identifiable data” as well as information on how we collect the specific data, how we process it, for what reasons and why. It will also be explained how we strive to protect players’ data, the situations of data deletion and what the rights of your as a data subject are. Personal data is tantamount to individual information, such as your name, address, e-mail address, IP addresses and device-related identifiers. This personal data is processed at all times at the time when you use our Games.
We would like to inform all players that we strive for the best entertainment experience for our users, however, that also means that you can also share your experiences on social networks. We aim to ensure that your data is protected. If you use third party services, such as logging in to Facebook through our Game, please be noted that those service providers will also collect personal data and that remains something that is not part of our service.

Who should I contact in case of inquiries?

We as Xi4G are responsible for our Services and for the protection of your data as a player of our Games. If you have any questions about your own personal data, how we process it, the deletion of it and other related issues, contact us here:

Xi4G Sp. z o.o.
ul. Św. Mikołaja 51/52
50-127 Wrocław, Poland

Phone: +48 692 987 335
E-mail address: office@xi4g.com

What are my rights?

Also, if you wish to make use of any of the following right, you can also contact us at the above mentioned address:
Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you can always contact us if you wish to cancel a previously given consent)
Right to access your data in accordance with Art. 15 GDPR (e.g. you can always contact us if you wish to know what data specifically we have stored about you)
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can always contact us if your e-mail address has changed and you would like to ask us to replace your previous e-mail address)
Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can always contact us if you would like us to delete certain data that we have stored so far about you)
Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can always contact us if you would not like us to use your e-mail address)
Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can always contact us to receive your data, if you would like to upload it to another service)
Right to object to how your data is being dealt with by us in accordance with Art. 21 GDPR (e.g. you can always contact us if you refuse to agree with any analytics procedures that are specified in this privacy policy text)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 GDPR (e.g. you may contact the data protection supervisory authority directly)

Deletion of data and storage periods

We will delete or anonymise your data as soon as it is no longer required, unless a situation specifically requires it. Your data will also be automatically deleted or rendered anonymous, if and when the mandatory storage period expires (e.g. those required by law for payment transactions). Such data may be needed for longer time spans for legal reasons only. You may always request any kind of information concerning personal data we have stored about you if you wish to do so.

Data collected in our Games

During your use of our Services, we may collect, store and process certain data about you in order to improve our Games and Services, improve your general user experience and to provide you with certain customised offers (e.g. some in-game purchase offers that you may prefer, based on your playing preferences):

Temporary unique device identifiers (e.g. IDFA and Android ID) and random device identification numbers (client IDs) as well as user identification numbers (user IDs)
Your unique progress in our Game and your unique playing behaviour (e.g. how fast you reached a certain level or which Upgrades you chose to make)
In-app purchases (e.g. how many Coins you purchased for which price)
Game version (e.g. v1.1.15)
Language Settings (e.g. system language English)
IP address (e.g. 96.92.316.example or 2a02:7122:8337:1112:bdb2:651f:example)
Approximate location based on IP range (e.g. “Warsaw & surrounding area”)
Date and time of your game session (e.g. 11:45 on 25.05.2018)
Operating system (e.g. Android)
Mobile device (e.g. Samsung Galaxy S9)

It may be known to you that your IP address and other unique identifiers can theoretically be traced back to you or to the device that you’re currently playing. In order to ensure protection of your privacy, we aim to delete or render anonymous identifiers in our database and most of the technical data after your game session is complete. Other data will be used only for statistical purposes so that we could further improve and optimise the game. We also use it to serve interest-based ads and to offer a more personalised overall experience of the Game. The reason why we temporarily store this data is to be able to process information that will allow us to provide a more personalised gaming experience. What forms our legal basis is the contract with you in accordance with Art. 6 para. 1 lit. b GDPR and also the legitimate interest that stands in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR. We also strive to implement the aforementioned measures to protect your data.

Mobile app and app permissions

When you download our Games or you are making in-app purchases inside the Games through a given app platform (e.g. Apple App Store or Google Play Store), you give specific information to that platform, such as your account data, e.g. your name, device identifiers, e-mail address and payment information. We have no influence on this data collection and are not responsible for it.
Some features of our Games require the app to access certain functions and services on your device. The type of mobile operating system of your devices determines the app permissions. Those permissions are as follows:

iOS

Push notifications: If you choose OK in the “Allow push notifications” pop-up on your device, you allow the app to notify you of certain events inside the game, even in the situation, in which your app is not currently active. This means you will receive notifications with sound, messages or symbol indicators.
Game Center: We may provide a connection to the Game Center service from Apple and Google Play services, which are subject to those platforms’ individual Privacy Policies. When you use the service, for instance if you wish to receive notifications about achievements, the personal information you share is visible to other users and can be read, collected, or used by them. You only have to consider which personal information you choose to submit.

Android

External Storage (Change or delete the contents of your external storage, read the contents of your external storage): This is a function that enables the app to temporarily store content on your given device. This is solely for memory storage. Other data on the external storage will not be read, erased, modified.
Internet Connection (Get Internet data, full network access and Wi-Fi connections): These functions enable the app to receive data from the Internet and to decide whether a connection to the Internet exists via a Wi-Fi network or via a mobile data connection. This is conducted in order to prevent larger amounts of data from being used too much of limited data quantities.
Deactivate hibernation: This function enables the app to deactivate the dormant state of the device (e.g. to display videos without switching off the screen).
In order to protect your privacy, all specific app permissions are optional, with the exception of technical permissions needed for the app to run. You can always refuse to accept (by clicking “no” or “do not accept” in device settings). You can always revoke app permissions after doing so by changing the related settings on your device. The basis for asking for those app permissions is to keep you as a Player updated on game updates, game news and notifications. The legal basis is your consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR.

Connecting with Facebook

In our Game you may log in with your Facebook account details. If you choose to do so, in some of our Games you may be able to use your Facebook account to log in on multiple devices and synchronise your game progress. We will not save your friend lists and contacts, and there is no connection whatsoever between your Facebook account and our Game. You may always log out of your Facebook account while playing. The underlying service is provided by Facebook and further details can be found in Facebook’s Privacy Policy. We never post anything to your Facebook page without your permission. We will receive some of the following Facebook account information, depending on what you choose to provide:

Public profile information (e.g. Facebook name, your profile picture and other public information etc.)
E-Mail address (the e-mail address you use to log in to Facebook)
Facebook game specific ID related to your profile and the game you are playing (not your Facebook ID)

We use this information to improve your gaming experience, and also for market research and advertising, but only when we render this information anonymous.
In order to protect your privacy and the privacy of your friends, we ensure that personal information is deleted or made anonymous, so that it cannot be traced back to you in our systems. Please note that some Facebook services are located in the USA and thus in a country outside the EU and the EEA (a third country), further protection measures are required to make sure that your data is protected in accordance with a European level of data protection. Facebook has been certified under the EU-US Privacy Shield for the ad-related services and has displayed a necessary level of data protection (link). The aim of collecting and storing such information is for you to receive in-game rewards by logging in to Facebook in the Game, to synchronise your game progress and to offer you personalised offers. The basis is your consent – when choosing to connect your Facebook account - in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR.

Support and contact form

When you personally write to us with inquiries, this is the kind of information we handle:

Game you are playing
Your name or nickname
Your e-mail address
Platform you are playing on
Your type of issue
Your language
Your user ID or Facebook game specific ID
Your problem description
Uploaded file (optional)

The purpose of collecting such information is to be able to answer any user requests we receive. We strive to answer all user inquiries and issues. The legal basis are the contract with you in accordance with Art. 6 para. 1 lit. b GDPR and the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR. We also provide aforementioned safeguards to protect your data.

(Personalised) Advertising

In our Games we actively use advertising technologies and exchange ad identifiers with external advertising networks to allow personalised advertising for the players. We and our trusted partners collect and process the Apple Advertising ID (IDFA) on iOS devices and the Google Advertising ID on Android devices to enable interest-based advertising and gauge the success of such advertising. Advertising IDs are always unique, however, they are also non-personalised and non-permanent identification numbers provided by your operating system and device.

In order to protect your privacy, we only collect personal information temporarily. We also strive to make sure that our external partner always commit to a professional level of data protection, also by concluding data protection agreements. Our aim for doing so is to improve our Games and provide the player with more relevant ads. The information collected helps us improve our websites and Games. The basis for it is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR.

Job application

You can always apply for an open position at Xi4G through external websites and our job pages. To apply for a job at us, we require the following information from you:

Your first name
Your last name
Your e-mail address
Your phone number (optional)
Your uploaded resume or cv
Your cover letter (optional)
Your portfolio (optional)
Information related to how you heard about us (you can select “other” if you do not want to tell us)

The aim of collecting and storing aforementioned data is solely for recruitment process. The reason for extended storage is based on Polish legal requirements. The legal basis for this is Polish Data Protection Act, which allows the processing of employee and applicant data when it is necessary to make a final hiring decision.

Cookies

We use cookies on our main website. Cookies are typically small text files and they are usually kept in a folder from your browser. They contain information about your current or last visit to our website:

Name of the website
Expiration date of the cookie
Its random value

If it happens that cookies do not store an exact expiration date, then they are stored temporarily and are automatically deleted at the moment you close your browser or choose to restart your device. Cookies with an expiration date will then still be stored even when you close your browser or choose to restart your device. Such cookies will not be deleted until the specified date or if you delete them manually.

We use three types of cookies on our website, and they are as follows:

required cookies (the typically required type, e.g. to display the website correctly for you and to store certain settings temporarily)
functional cookies (cookies that help us in improving our website, e.g. in order to evaluate technical data of your visit and avoid errors)
advertising and analytics cookies (cookies that serve analytical purposes and serve personalized ads needs)

You can always block, edit and delete cookies in your browser settings. If you delete all cookies from our website, please note that some functions of the website may not be shown fully correctly. Further information on cookies and how you can edit them is here in English.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics utilises the advertising and analytical cookies described in the previous section to analyse the website performance in terms of user behaviour. The information that’s then generated is subsequently transferred to a Google server in the USA and remains stored there. Please note that there is no direct link to your IP address, as it is shortened before the usage statistics are evaluated. Google will make use of this anonymous information gathered by the cookies to evaluate the usage of the website and to generate reports on website activity. Please note that Google may transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google.

You can always edit your browser settings to refuse cookies, or you can prevent Google from collecting and analysing the data by downloading and installing a browser plug-in from Google. Alternatively, you can set an opt-out cookie to prevent potential future collection by Google Analytics within this website (the opt-out only works in the browser and only for this domain). If you delete your cookies in this browser, you please note that you must click this link again.

In order to protect your privacy, we use the anonymisation component offered by Google as mentioned above. Analytical measures are not based on you as a person, but only on a statistical basis. In addition, security standards of Google platform and its data privacy policy apply (link). Please rest assured that Google is certified under the EU-US Privacy Shield and has demonstrated a sufficient level of data protection (link). The reason why we use Google Analytics is to analyse usage behaviour of our websites in an anonymous form. The information collected helps us in improving our websites and games. The legal basis is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR.

Last updated: April 2019