Privacy Policy

DATA PROTECTION INFORMATION

• General Information about this Privacy Policy:

We prioritize the protection of your personal data and treat it as confidential, adhering to the applicable data protection regulations and this Privacy Policy. When you engage with our games, various types of personal data are collected. The following information offers a clear overview of what data we collect, how we collect it, and the purposes for which we use this data during your gameplay. The term “personal data” encompasses any information that can directly identify you, such as your name, email address, or phone number, or indirectly identify you through means like your phone ID, cookie identifiers, or game data. For more comprehensive details regarding data protection, please refer to our Privacy Policy below. You can access this information at any time through our https://cgilabgames.com/privacy-policy/.

• Data Collection:
• How do we gather your data?
• Your data is collected through your active submission to us. This may include information you enter into a contact form or when you link your game to third-party accounts like Facebook or Google.
• Additionally, certain data is automatically collected when you download and use our games.
• We also collect information regarding the ads displayed, including their frequency of appearance, placement within the game, and your device’s identifier.
• We collect data about your interactions with ads, such as page views, time spent, and viewing duration.
• Purposes of Data Usage: For what purposes do we use your data?
• We use this data to provide you with our games, which includes optimization, handling support requests, preventing fraud, customizing and personalizing your gaming experience and in-game offers, verifying purchases, and offering supplementary services.
• We may also use the data to provide you with advertisements, products, services, or personalized content within our services or those of our partners.
• We may share the data we collect with our partners when you use our services.
• Additionally, this data may be linked to demographic, advertising, market research, or other analytical surveys.
• Your Rights: What rights do you have concerning your information?
• You have the right to obtain information about the source, recipients, and purposes of your stored personal data at any time without incurring a fee for such disclosures.
• You can also request the correction or deletion of your data.
• Feel free to reach out to us anytime using the contact details provided on this website’s imprint if you have questions or concerns related to data protection.
• You also have the right to lodge a complaint with the relevant supervisory authority.
• Furthermore, you can request restrictions on the processing of your personal data. Details on how to exercise your rights can be found in this Privacy Policy under “Your Rights.”
• Analysis Tools and Third-Party Tools:
• If you download and use our games, your usage data may be subject to statistical analysis. Such analyses are typically conducted anonymously, meaning they cannot be traced back to you. For more information about these tools and your options to object, please refer to our Privacy Policy below.

GENERAL INFORMATION

The entity responsible for overseeing and making decisions regarding the handling of personal data, as defined in the GDPR (referred to as the “controller”), can be an individual or a legal entity. In the context of data protection laws, the controller is CGI LAB SRL. If you have any inquiries or recommendations concerning data protection, please feel free to contact us via email at office@cgilab.co. You can also reach our data protection officer through the same contact information.

COLLECTION AND USE OF PLAYERS DATA

• Player ID:

When you initially start playing our games, we may automatically generate a pseudonymized user ID. This data is collected to grant you access to our games, including your saved progress and any unlocked or purchased content, in accordance with Article 6(1)(b) of the GDPR.

• Social Features and Game Center:

In certain games, you have the option to link your player account to third-party platforms like Facebook or Google to participate in social features and view highscores. You can also link your game to your Game Center account. If you decide to link your Facebook account to our games, the following data is shared with us: your name, profile picture, Facebook ID, and place of residence (if provided on Facebook). If you link your account to your Game Center or other third-party accounts, such as Google, we may collect a pseudonymized unique identifier for each connected third-party provider. Some of our games allow you to create a pseudonymized invitation link that you can share with friends to connect directly via the Social Feature.

• Please note that when you engage in social features, your friends and contacts who also

participate in the same game’s social feature may become aware that you are playing the game, and your name may appear in their highscore list. Additionally, when your account is linked to a third-party account, you may receive a list of friends who are also playing the same game and have linked their game to the same third-party account(s). You have the option to disconnect your Facebook account at any time by accessing Facebook settings and selecting the “Settings” option under “Apps and Websites.” The link between Facebook and the app can be removed from the “Apps and Websites” section. You can also disconnect your Game Center account within the settings menu of our games. To disconnect other third-party accounts, you can contact our Player Support Team via in-game chat or email at office@cgilab.co.

• We collect this data to fulfill our contractual obligations by providing our app and

connecting your account, if desired. We may also use this information based on our legitimate interest to re-identify your player profile, especially in cases where you lose access to your saved game. The processing of your data for the purposes of providing our app’s functions (e.g., player ID) is necessary to offer our games and their features. Without this data, we cannot provide these functionalities. However, you are not obligated to provide data from your third-party accounts or connect them to our games. Nevertheless, without this data, we cannot offer the corresponding functions of our app to you.

• Support Requests:

When you send support requests to us via email, integrated HelpShift chat within the games, or messages on social media platforms, we collect and process the data from your request and account, including your username and country. We only collect this data to appropriately respond to your inquiries, provide our app to you, and process your request based on the contract established when you accepted the Terms and Conditions.

• When you send support requests through the integrated chat system in our games, your

provided personal data will be transmitted to our help desk provider, HelpShift. By using the chat system to send support requests, you acknowledge and agree to the transmission of the necessary personal data required to handle your support request.

Data sent to us via contact requests is retained until you request its deletion, revoke your consent for storage, or the purpose for data storage ceases to exist (e.g., after your request is resolved). This retention complies with mandatory legal requirements, particularly statutory retention periods.

PERMISSIONS WE USE

Our app requests the following permissions and provides an explanation for each:

• Autostart: This permission is necessary to send notifications to the user.
• Network Connection Display: This permission allows the app to receive information about network availability and connection status.
• Google Play Billing Service (Android): This permission enables users to make in-game purchases.
• Full Access to the Network: The app requires this permission to send and receive data over the Internet.
• Location: This permission is needed to provide location-based and personalized customer experiences.
• Search & Siri Suggestions (iOS): When enabled, this feature allows the game’s information to appear in search results, lookups, and keyboard suggestions. Siri can also learn from app usage to provide recommendations.
• Notifications (Symbols, Tones, Banners, Vibration Control): With notifications enabled in the settings, important in-game events can be sent to the player via symbols, sounds, banners, and vibration alerts.
• Background Updates: If this function is enabled, the app can perform updates in the background.
• Mobile Data: Players can grant access to mobile data to ensure they can use all the game’s features even when not connected to Wi-Fi.
• Access to Local Storage: The app identifies and accesses local storage to carry out its services effectively.

STATISTICS AND ANALYTICS

To enhance the user experience and perform statistical analysis of our app’s usage, we gather pseudonymized data on how our apps are utilized and analyze it statistically. In this regard, we collaborate with third-party analytical tools alongside our own services. These partners handle your data solely based on our explicit instructions and may utilize cookies and other tracking technologies to gather information regarding your app usage. Our collection of this data is motivated by a legitimate interest in tailoring our services to meet user needs.

ADVERTISING NETWORKS WE USE

We utilize third-party analytical tools to deliver advertisements and content that align with your interests. These partners process your data under our explicit instructions and may employ cookies and other tracking technologies to gather information about your utilization of our apps. The data collected encompasses various aspects, including but not limited to installation data, in-app events, language, platform, device type, operating system version, and device identifiers like advertising IDs and usage data. We engage the following advertising networks to facilitate personalized advertising within our free apps:

• AppLovin
• AdMob/Google
• AdColony
• Chartboost
• Facebook Ads
• Unity Ads
• IronSource
• TikTok/Bytedance
• HyprMX

These networks gather specific data to offer tailored advertising, including:

• Device details (make, model, operating system)
• Device properties (screen size, orientation, battery usage)
• Carrier information
• Operating system details
• Location data (country, time zone, locale settings)
• Network connection type and speed
• IP address
• Internet browser user-agent
• Identifier for advertisers

We may also use this information for statistics on viewed video ads, app usage duration, in-app purchases, and more. The aim is to optimize and enhance the advertising experience. The networks may collect and process data related to the advertisements’ performance and user interactions, along with personal data, to improve their services.

You can exercise your right to object to personalized advertising based on our legitimate interest in supporting our app operations through advertising by adjusting your device settings:

• On iPhone or iPad, go to “Settings,” tap on “Privacy,” and select “Advertising.” Enable “Limit Ad Tracking.”
• For Android devices with Google Play Services, access “Google Settings,” tap on “Advertising,” choose “Disable interest-related ads,” and confirm with “OK.”

This decision allows you to control the use of personalized advertising according to your preferences.

SHARING OF INFORMATION

We may share your data with the following parties:

• Technical service providers who are involved in delivering our services. These service providers, acting as subcontractors, are bound by the same obligations as CGI LAB SRL to adhere to relevant personal data protection laws.
• Other companies, but only in the event of a transfer of CGI LAB SRL’s operations.
• Administrative or judicial authorities when necessary to verify the proper use of our services or for investigative purposes, in accordance with applicable law. CGI LAB SRL always ensures the legitimacy of such requests.

CGI LAB SRL may disclose your Personal Data in good faith when it believes such disclosure is necessary:

• To fulfill a legal obligation.
• To protect and safeguard the rights or property of CGI LAB SRL.
• To prevent or investigate potential misconduct related to our Products.
• To safeguard the personal safety of Product users or the general public.
• To defend against legal liability.

Regarding the disclosure of Personal Information:

• Within the EU: When we engage service providers to perform tasks on our behalf, the contractual relationships are governed in writing in compliance with the European General Data Protection Regulation (EU-GDPR) and the Federal Data Protection Act (new BDSG).
• Outside of the EU: If you have selected and consented to this arrangement, your data may be shared with our affiliated offices outside the European Economic Area for the purpose of processing your request. These offices are obligated to adhere to EU-GDPR regulations. Additionally, legally independent companies within the affiliated network have established written agreements for data processing on commission, based on standardized contractual terms.

REMOVAL OF YOUR DATA

Unless legal requirements dictate otherwise, we will erase or render your personal information anonymous when you request the deletion of your data or when it is no longer necessary for the purposes for which it was initially collected or used, as outlined in the previous sections. If legal obligations necessitate data retention, we will block the data, making it unavailable for further use.

AGE LIMITS

In order to utilize our services, it is essential that you confirm your full legal capacity. If your legal capacity is restricted, you must obtain the consent of your legal guardian to use our services. We do not intentionally gather or request personal information from children. If you are unable to confirm full legal capacity, please refrain from providing any data about yourself, including your name, address, or email address. If we become aware that we have inadvertently collected personal data from a child, we will promptly remove such data. If you suspect that we may possess data from a child, please contact us at office@cgilab.co.

YOUR RIGHTS

If you have any inquiries regarding this Privacy Policy or wish to exercise your rights as outlined below, please reach out to us via email at office@cgilab.co.

• Obtain a copy of your Data – “Right of access and data portability”: You have the option to request a copy of your Data at any time. You can also review the Data, use it for your own purposes, or transfer it to another service provider.
• Correct your Data – “Right to rectification”: You possess the right to rectify your Data if it is found to be inaccurate or incomplete (e.g., updating your address).
• Delete your Account – “Right to erasure (right to be forgotten)”: You have the ability to request the closure of your Account and the deletion of associated Data.
• Limit the use of your Data – “Right to restriction of processing”: You also hold the right to request that your Data not be used further or deleted while we are processing your request.
• Give and withdraw your consent – “Right to object and withdraw your consent”: You can withdraw your consent or object to the receipt of newsletters and promotional emails, the personalization of ads, or the sharing of your Data with our partners (except for technical service providers) by sending an email request to office@cgilab.co.

We do not discriminate and, therefore, will not refuse requests without a legal basis, provide a different level of service, or charge different prices to players who choose to exercise their rights. If you believe that your rights have not been upheld after contacting us, you have the right to file a complaint with the competent supervisory authority. For the Republic of Moldova, the competent authority is National Center for the Protection of Personal Data – MD-2004, Republic of Moldova, Chisinau municipality, Serghei Lazo str. 48, (022) 820 801.

MODIFICATIONS TO THIS PRIVACY POLICY

We maintain the right to revise this Privacy Policy as needed to adhere to the relevant data protection regulations. This allows us to align it with the prevailing legal prerequisites and consider modifications in our services, such as the introduction of new offerings. The latest edition consistently applies to your interactions with us. You can access the most recent iteration of this Privacy Policy at the following link: https://cgilabgames.com/privacy-policy/. Last revised: 06.10.2023.