Privacy Policy

Effective date: September 18, 2021

To provide access to the Games, we need information about you. Protecting your privacy is very important to us. We only use your data when we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play any of our games, visit our sites, purchase promotional items from us, or participate in face-to-face events and promotions (hereinafter collectively - "Services").

You should also read the terms of the Terms of Service between you and FlashCross.

1. Who decides on how your data is used?

FlashCross is the data controller responsible for deciding how your personal data is used.

If you have any questions or comments on this policy, you can contact us using the contact details indicated on the Site.

2. What information we collect about you and how we use it

This Privacy Policy sets out how we use any information that may or could be used to identify you ("Personal Data"). It does not apply to information that cannot be used to identify you ("Anonymized data").

We need to collect and use certain Personal Data in order to provide you with the Services and to fulfill our promises made by us in the User Agreement:

When you subscribe to the Services, you provide us with your Personal Data voluntarily, giving it to us, for example, when creating an Account. We collect and use such data to enable you to authenticate yourself when logging into your account and using the Services, in order to ensure that you are eligible and able to access the Services and to ensure that you receive the correct version of the Services. Such information includes Nickname, email address, Last name, First name, gender, Country and City of residence, age, telephone number.

In order to use our Services, you may also have an account with a third-party service that we maintain that provides single sign-on functionality. In this regard, the composition of the Personal Data we collect will also depend on which third-party accounts you choose to use, on the privacy policies of the respective services and on the fact that your privacy settings on these services allow us to see when you use the services of these services to obtain access to the FlashCross Services.

If you choose to link your Google account to the Services, we will receive your Google email address and an authentication token from Google.

Depending on which particular Service you subscribe to, we may support other third-party SSO services and receive additional Personal Data from them.

Some third party providers may notify you that they provide us with additional information, such as your public profile information, when you use the service to log in through such services. We do not collect such information from them.

We collect and use information about the location of your device when you use our Services, including about your movements and events during the game. We locate your location using a variety of technologies, including GPS, WiFi hotspots that you connect to when using the Services, and the location of mobile / cellular repeater towers.

We also collect and use data about your actions and achievements in the Game, as well as certain information about your mobile device (including device identifiers, device operating system, its model, configuration and settings, as well as programs installed on it), allowing us to adjust the operation of the Services to your requirements and personalize your gameplay and user interface.

To store photos and videos, Applications need to provide access to your device's media storage.

In addition, we use the above information to provide you with technical and customer support.

In addition, we have a legitimate interest in using your Personal Data for the following purposes:

1. Your IP address, type of browser, your operating system, web pages that you visited before accessing our Services, the pages of our Services that you visited, or the functions you used, and the time you spent on these pages or with these functions, links-transitions to our Services, activated by you, device identifiers and ad networks, age, as well as actions taken by you during the games.
2. Your contact information, namely your email address and telephone number, in order to contact you for technical and customer support.
3. To provide social functions in our games so that you can interact and play with other players, including saving your correspondence, content and other information that you share with these players, find your friends and allow other players to find you.
4. To offer new or additional features of our Services.
5. Data about your actions and achievements in games, as well as certain information about your mobile device (including device identifiers, device operating system, its model, configuration and settings, as well as about third-party applications and programs installed on it) - to implement measures to combat fraud and cheating ("cheating") - actions prohibited by our User Agreement, in order to be sure that we provide equal gaming opportunities to all game participants.
6. To disclose information when required by law, as well as when it is necessary to assert claims, exercise rights or defend against third party claims.

For the following purposes, we will use your Personal Data only with your consent:

1. We will send you marketing materials via email or app notifications.

We also rely on your consent when using cookies and similar technologies. Insofar as cookies collect Personal Data, we will process it in an anonymized or pseudonymized form.

3. Who do we share information with?

We will share any Personal Data received from or about you only in the following situations:

Communication of information to our service providers. We engage third-party service providers to work with us to administer and provide the Services. As part of this process, they will process your Personal Data on our behalf. Such third party service providers will only have access to your Personal Data to provide services on our behalf and in accordance with this Privacy Policy. We make sure that each of the service providers is bound by contractual obligations and does not disclose or use your Personal Data for any other purpose. The service providers we use help us:

1. run, administer and maintain our Services using third party platforms and software tools;
2. perform content moderation and crash analysis;
3. сonduct email and mobile messaging campaigns;
4. to carry out game and marketing analytics;
5. сonduct face-to-face events, competitions, sweepstakes and promotions, including player registration, registration and attendance management, event eligibility checks, and awarding of prizes;
6. determine the origin of payments;
7. provide technical and customer support;
8. to process payments for participation in the Games.

Some third-party service providers may also collect information directly from you (for example, a payment processor may request your billing or financial information) as third-party providers in accordance with their own policies for the protection of such information. These third party service providers do not share your financial information with FlashCross, such as a credit card number, but may only provide us with limited information related to your purchases.

Communication of information to other players. When you use the Services, in particular when you play our Games, engage in social features (including cross-play features) or participate in face-to-face activities, we will share your Personal Data with other players. Such Personal Data includes your in-game profile data (such as your Nickname, your team, Country and City of residence), your in-game actions and achievements, real world locations associated with your playthrough of the game and with those resources with which you interact in games and Your in-game messages, as well as related content that you share with other players.

Publicly Disclosed Information: When you use the Services, in particular when you play our games, use competitive functionality or participate in our forums, the following information may be displayed on web pages that are accessible to everyone and therefore become publicly available: Your Nickname, Teams in which you were, the Country and City of your residence, statistics (rating), the history of your participation in the Games, your routes during the passage of the Games.

Information communicated to third parties. We share anonymized data with third parties for industry and market analysis purposes. We may share data with our third party publishing partners for their direct marketing activities, but only with your express consent. We do not share Personal Data with any other third parties for direct marketing purposes.

Information Disclosed to Protect Us and Others. We assist government and law enforcement agencies or private organizations to ensure compliance with the law. We disclose information about you to government and law enforcement agencies or private organizations when, in our reasonable judgment, it is necessary or appropriate: (a) to respond to claims, procedural documents (including subpoenas and orders); (b) to protect and ensure the safety and security of our property and our rights, as well as the safety of third parties or society as a whole; and (c) to detect and suppress any conduct that we deem illegal, unethical, or liable.

Information disclosed in connection with transactions. The information we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition or acquisition of a property complex, or if our assets are acquired by a third party in the event of our exit from business or initiation of bankruptcy proceedings, some or all of our assets, including your Personal Data, will be disclosed or transferred to the acquirer in connection with such a transaction.

4. How your Personal data is transferred

FlashCross provides its Services in Ukraine. Your Personal Data may be transferred outside your country and stored in another country, including the United States, EEA countries, for the purposes specified in this Privacy Policy, if permitted by applicable law. The laws of these countries on the protection of personal data may differ from the laws of your country.

If we transfer your Personal Data from the UK or EEA to other countries, including the United States, we will ensure that the level of protection of your Personal Data is the same as in the UK or, as the case may be, in the EEA by ensuring that so that at least one of the following conditions is met:

The country to which your Personal Data is transferred, in the opinion of the European Commission (or the UK Government if you are located in the UK), provides an adequate level of protection for Personal Data, as in the UK or, as the case may be, in the EEA.

When engaging service providers, we use special contracts in the form approved by the European Commission (or the UK Information Commission if you are in the UK), which provide the same protection of Personal Data that they enjoy in the UK or, depending on the situation, in EEA.

5. How We Protect Your Personal Data

We use appropriate legal, organizational and technical security measures to protect your Personal Data from accidental loss, unauthorized use or access, improper alteration or disclosure. We also provide access to your Personal Data only to those employees, agents, contractors and other third parties who need it to work. They will only process your Personal Data on the basis of our instructions and are bound by confidentiality obligations. We have implemented procedures that establish a course of action in the event of suspicions of a breach of confidentiality (leakage) of Personal Data. In the event that we have such a legal obligation, we will notify you and the competent supervisory authority of such a leak.

6. How long do we keep your Personal Data

We store your Personal Data for the entire period of providing the Services to you and until the goals specified in this Privacy Policy are achieved. This also applies to everyone with whom we share your information and who provides services on our behalf.

When we no longer need to use your Personal Data and store it in accordance with our legal obligations, we will either delete it from our systems or anonymize it so that it can no longer be associated with you. When we delete Personal Data, we will take commercially and technically reasonable steps to ensure that such Personal Data cannot be restored or reproduced.

7. Your rights and choices

You have certain rights in relation to your Personal Data. To exercise these rights, please contact us using the contact details indicated on the Site.

You can:

1. delete or correct your Personal Data. The easiest way to update your account information is to change the information in your account or in app settings.
2. to ask us to stop processing your Personal Data, including for advertising and marketing purposes such as personalized awards, promotions and other offers.

The law provides for exceptions to these rights in certain circumstances. When you are unable to exercise any of these rights due to such an exclusion, we will explain the reason to you.

We offer you a choice in the collection, use and transfer of your Personal Data and will respect your choice. Please note that if you choose not to provide us with the Personal Data we are requesting, you may not be able to access all the features of the Services.

After you contact us, you can receive an email in order to verify the authenticity of the appeal. We will strive to provide you with information or to fulfill your other request within 30 days or within a shorter period provided for by the legislation of your country.

8. Children

Unless otherwise specified for a specific Service, children are not allowed to use the Services and we do not collect their Personal Data.

In order for the Child to access the Services that allow the participation of children, verified consent of the parents or legal guardians of the Child ("Parents") must be provided.

Parents have the right to check the Personal Data of their child, request the deletion of their child's Personal Data, and withdraw their consent to the collection, use and (or) disclosure of their child's Personal Data by sending us a notification.

If we learn that we have received Personal Data from a child without parental consent, we will take action to remove such information from our files as soon as possible.

9. Changes to this Privacy Policy

Any Personal Data we collect will be subject to the Privacy Policy in effect at the time it was collected. We may make changes to this Privacy Policy. You will be notified in advance and in due course of any significant change.

10. Third parties

When using our Services, you may access links to sites and services owned or operated by third parties (each such service is a "Third Party Service"). Any information that you provide to a Third Party Service or on a Third Party Service or collected through a Third Party Service is provided directly to the owner or operator of the Third Party Service, and its confidentiality mode is determined by the policy of such owner or operator. We are not responsible for the content, security or reliability of any Third Party Services and for the methods and rules they use to protect information. In order to protect your information, we recommend that you carefully read the privacy policy of any Third-Party Service to which you access.