Privacy Policy - Last updated June, 25th 2019

The data controller is Semeevs, represented by Irina Andreeva, “Individualnij predprinimatel”, incorporated in Russia (“Semeevs” / “we” / “us”), a developer of games and mobile applications (together “Applications”). This Privacy Policy applies and has effect in respect of all Applications and other related services developed by us, including our website https://semeevs.com (together “Services”).

“Personal data” or “Data” shall mean any information relating to an identified or identifiable natural person.

“Data controller” shall mean the person that determines the purposes and means of the processing.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which Personal Data we collect from you will be processed by us or on our behalf. We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully. It contains important information about the following:

What Data is collected.
Purposes and legal basis for processing.
If and how we disclose your Data to anyone else.
The choices and rights you have regarding the Personal data you have provided to us.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes.

If you have any questions or comments about this Privacy Policy, please contact us at games@semeevs.com

What Data is collected

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our Applications.

Identity-related data: for some of our Applications, we are likely to collect data from your Facebook account, when you login using Facebook connect: Public profile (surname, forename, age, gender, email address, profile photos, hobbies), friend list.
IDFA publicity identifiers (for IOS devices) and GAID (for Android devices).
Data pertaining to your activities on our Applications and notably the way in which you interact with our Applications (for instance, how and when you use our Applications) and with the publicities we display (for instance, time spent on these, potential clicks).
Data pertaining to your geographical position (IP address).

We are also likely to use cookies which correspond to small files containing letters and figures downloaded onto your device when you access our Applications.

This data is collected via external tools (Software Development Kit or «SDK»), which are an integral part of the application.

Purposes and legal basis for processing

Collected Data is used to:

Provide our Applications to you.
Guarantee use and improvement of our Applications.
Develop new Applications.
Understand your centers of interests and, thanks to this profiling, propose you targeted and relevant advertisements (SDK advertising).
Make statistics on your use of the games, including the number of games played, your duration of use or the advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).
Communicate with you, notably when you contact us by any means whatsoever.

Term of data storage

We store Personal Data no longer than is necessary to provide you with our Services. Beyond this term, your anonymous data may be stored solely for statistical use and will not be exploited, in any nature whatsoever.

Disclosure of your information

We will share your information with third parties, but only in the ways that are described in this policy:

We may disclose your information to our personnel, contractors and their subsidiaries. Such parties undertake to act in compliance with all applicable data protection laws, including the General Data Protection Regulation 2016/679;
As required by law, as part of legal proceedings, a dispute and/or request issued by the public authorities in your country of residence or otherwise;
If disclosure is necessary for national security, application of legislation or any other matter of public interest.

Data transfer

Your Data may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. This means that when we collect your Personal data, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy.

Personal data concerning children

We do not knowingly collect any personal data concerning children under 13 years old. In the unlikely event that we have (or you believe we have) collected information from a child, please contact us by emailing games@semeevs.com where we will take all necessary steps to purge the data from our systems.

Your rights concerning data collected

You have the following rights over how we process your personal data. We endeavour to respond to any request within 1 calendar month. To issue a formal request, please email games@semeevs.com with your device advertising identifier.

Right to confirmation of the existence of a data processing

You are entitled to obtain from the controller confirmation as to whether or not data related to you are being processed.

Right to access your Data

You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data. This right also includes that of receiving a copy of data processed.

Right to request rectification of your Data if incorrect.

You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect, incomplete or obsolete.

Right to request deletion of your Data

You are entitled to request deletion of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

Data is no longer necessary in light of the purposes for which it is collected or otherwise processed;
you’re withdrawing consent over which processing is based;
you object to processing;
you consider that your data has been unlawfully processed;
your data should be deleted to respect a legal obligation.

Right to limit processing

You are entitled to request that the data controller limit the use of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

you contest the accuracy of your Data for a period enabling us to verify the accuracy of this Data;
you consider that processing is unlawful, but you object to the deletion of your Data;
Data is still required for exercising or defending your rights in court even though we no longer require this Data.

Right to object to processing by withdrawing your consent

(with it being reiterated that this withdrawal may not harm the legality of processing based on the consent granted prior to its withdrawal).

Right to data portability

You have the right to receive your personal data provided to us, in a structured, commonly used and machine-readable format and the right to transmit these data to another controller.

Right to make a complaint

You have the right to make a complaint to a supervisory authority. You should contact us first so that we can attempt to resolve your issue. You can do this by emailing: games@semeevs.com - please include your device advertising identifier.

Reasons you may wish to do this include:

If you do not agree with the way we have processed your data.
You feel that we have not adequately responded to your request for deletion or gaining a copy of your data.

Due to the obligation of security and confidentiality in Data processing incumbent upon us, your request will be processed subject that you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

Personal data security

We take all necessary security measures so as to prevent as far as practically possible any alteration or loss of your data or any unauthorised access thereunto.

Despite all of the precautions and preventive measures we take, no security system or precaution can be 100% secure. If we do ever discover a breach of your personal data, we will notify you as soon as we can.

Contact information

If you have any questions, comments, or other queries, please don’t hesitate to contact us using the email address of games@semeevs.com.

We endeavour to respond to any request within 1 calendar month.