PRIVACY POLICY AND INFORMATION CLAUSE

According to art. 13 item 1 and item 2 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, Regulation or GDPR) we hereby inform you regarding the personal data we collect in connection with your use of our games, and for which purpose the data is used. You can access this information at any time at [LINK to Vixa Games subpage] All use of Software is governed by this Privacy Policy and by using or accessing the Software you give consent to the processing, use and disclosure of your data. Please do not install or use the Software if you do not agree to this Privacy Policy. Not all of the data processing described herein will apply to you, as there may be differences in processing practices in respect of some of our Software (e.g. not all games include multiplayer or social network features).

1. DATA CONTROLLER AND CONTACT

The data controller within the meaning of data protection laws is: Scalac Spółka z ograniczoną odpowiedzialnością, with its registered office: Czesława Miłosza Str. 9/9, 80-126 Gdańsk, Poland (hereinafter Scalac Sp. z o.o.), owner of ‘Vixa Games’ brand. If you have any questions or suggestions about data protection, you can send us an email to gdpr@scalac.io

2. SCOPE OF DATA PROTECTION

The scope of data protection is personal data. In accordance with Article 4(1) GDPR, personal data encompasses all information relating to an identified or identifiable natural person, which includes, for example, names or identification numbers.

3. COLLECTION AND USE OF YOUR DATA

3.1 Social networks
We also may receive some of your Data from Social Network Services you participate in, especially when you connect to our Software using your account registered in some of such Social Network Services (e.g. Facebook). Such Data include: your username; profile picture; age range; gender; your friends using the same Software. You can cancel the connection with your Facebook account at any time by logging into Facebook and selecting the “Settings” option. The connection between Facebook and the app can be deleted under “Apps and Websites.” We collect this data in order to provide our app to you and to be able to connect your account if desired, Article 6(1)(b) GDPR. To the extent that we, as described above, process your data for the purposes of providing the functions of our app, you are contractually required to provide us with this data. Without this data, we are not able to provide these functions to you.

3.2 SUPPORT REQUESTS
If you send support requests to us by email, we collect and process the data from your request in order to be able to provide a response. For this purpose, it may also be necessary for you to provide us with information about your end device so that we can process the request and resolve any technical problems that may exist. We collect this data in order to provide our app to you and to be able to process your request, Article 6(1)(b) GDPR. You are not required to provide the above voluntary information. In particular, you are free to send the request to us under a pseudonym, without giving your real name.

4. PSEUDONYMOUS USER PROFILE

For the needs-oriented design and statistical analysis of usage of our app, we collect pseudonymous data about how our apps are used, and we evaluate this data statistically. We collect this data on the basis of a legitimate interest in needs-oriented design, for statistical evaluation, efficient marketing of our app, and the fact that your legitimate interests do not prevail under Article 6(1)(f) GDPR. There are some Data which you provide to us voluntarily, such as Data required to register an account (if applicable), to subscribe to marketing communication, to take part in a contest or sweepstake or to request help from our support. Such Data include your name, email address and other contact details. Other Data is collected automatically from you, your device and other services your are using. Such Data include: Mobile device identifiers (such as your unique device ID (persistent/non-persistent, hardware type, international mobile equipment identity ("IMEI"); Your communications within the Software Data and analytics about your use of our Software (e.g. in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, what friends you connect with, how you were directed to our Software); Your IP address and device identifiers such as your Advertising ID, Device ID numbers; Your device type and the operating system that you use; Broad geographic location (e.g. country or city-level location) based on your IP address; GPS location (if you provide your consent to provide us with such Data). Installation data, in-app events, uninstallation, A/B test buckets, language, platform, device type, operating system version, app version, screen resolution, date and time, device IDs such as advertising IDs and IDFA,IP address, country of installation, graphics card information, app IDs. Our Software may contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies, APIs, and SDKs in our Software to enable them to collect and analyze user and device related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below. The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we strongly advise you to check such privacy policies to learn more about their data collection and use practices, or use of tracking technologies.

5. ADVERTISING NETWORKS

We use the following advertising networks in order to be able to integrate advertising within our free-of-charge apps. These collect the data described for the purpose of providing personalized advertising. Advertisers on mobile devices and our third party advertising and analytics partners sometimes collect and use Advertising IDs to enable and optimize advertising. Advertising IDs are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising. These advertisers and third party advertising and analytics partners may collect and use data and information about you, such as your Software session activity, viewing of and interaction with an advertisement, device identifier, MAC address, IMEI, geo-location information and IP address for the purposes of analyzing, tracking and measuring advertisement performance and to provide interest based advertising. In addition, you may see our games advertised in other services. After clicking on one of these advertisements and installing our game, you will become a user of our Software. In order to verify the installs, a device identifier may be shared with the advertiser or third party advertiser or analytics partner. We inform you of such aforementioned collection practices, however we are not in control of data collected in such way, if you want to know more, you should revise privacy policies of such third party advertisers. You can object to the use of personalized advertising by making the following settings depending on your device type: On iPhone or iPad, first open “Settings,” tap on “Privacy,” and open “Advertising.” Here you can enable “Limit Ad Tracking.” If you use devices with Android and Google Play Services, first open “Google Settings,” tap on “Advertising,” then open “Disable interest-related ads,” then tap on “OK.” Use of the aforementioned advertising networks and the transmission of the data mentioned is based on our legitimate interest in recouping our investments for operation of our app through advertising and the fact that your justified interests are not overriding, Article 6(1)(f) GDPR.

6. DISCLOSURE OF DATA

As our business evolves, Scalac Sp. z o.o. may undergo organizational changes such as adoption of a new legal form or the establishment, purchase, or sale of subsidiaries and divisions or components of companies. Whenever such changes take place, customer information for each business unit is transferred together with the business unit. Each time personal information is disclosed to third parties as described above, we will ensure that the disclosure complies with this Privacy Policy and with applicable data protection laws. Transfer of data to processors is based on Article 28(1) GDPR. Alternatively, transfer can be warranted on grounds of our legitimate interest in the economic and technical benefits of using specialized processors, and due to the fact that your rights and interests in protecting your personal data do not prevail under Article 6(1)(f) GDPR.

7. DELETION OF YOUR DATA

We will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs. As a rule, we store your personal data as long as you use the site or for the term of any applicable contract, unless the data must be kept longer for legal reasons, for criminal prosecution, or to secure, assert, or enforce legal claims. If data must be kept for legal reasons, it is blocked. The data is then no longer available for further use. Please pay attention however, that erasure of all your data may be technically impossible if such data is connected with your accounts in other services, in particular Social Network Services and mobile platform operators.

8. AGE LIMITS

To use our services you must confirm full legal capacity or, in case of restricted legal capacity, obtain the consent of your legal guardian. We do not knowingly collect or ask for personal information from children. In case you can’t confirm full legal capacity, please do not send us any data about yourself, including name, address or email address. If we learn that we have collected personal data of a child, we will delete these as soon as possible. If you think that we might have data from a child, please contact us at gdpr@scalac.io

9 YOUR RIGHTS AS A DATA SUBJECT

9.1 RIGHT TO INFORMATION
You are entitled at any time, upon request, to obtain information from us about your personal data within the scope of Article 15 GDPR. To request such information you may submit an application by mail or by email to the address given above.
9.2 RIGHT TO RECTIFICATION OF INACCURATE DATA
You have the right to demand that we correct forthwith any inaccurate personal data concerning you. For this purpose, please use the contact addresses listed above.
9.3 RIGHT TO DELETION
Under the conditions described in Article 17 GDPR, you have the right to demand the deletion of your personal data. In particular, you are entitled to demand deletion if the personal data is no longer needed for the purposes for which it was collected or otherwise processed, if it is no longer needed, if it was unlawfully processed, if an objection has been submitted or if deletion is mandatory under EU law or under the law of a Member State to which we are subject.
9.4 RIGHT TO RESTRICTION OF PROCESSING
You have the right to demand that we restrict processing in accordance with Article 18 GDPR. This right applies especially if we are not in agreement with the user concerning the accuracy of any personal data. The right persists for the time required to verify its accuracy. In addition such right applies in the following cases: if the user is entitled to demand deletion but instead demands restricted processing; if the data is no longer required for the purposes we are pursuing, but the user needs them in order to assert, exercise or defend legal claims; and if an objection has been raised but its successful exercise is still disputed between us and the user. To assert the aforesaid right, please use the contact addresses listed above.
9.5 RIGHT TO DATA PORTABILITY
You have the right to demand from us whatever personal information you may have given us. Pursuant to Article 20 GDPR, at your request we must provide you with such information in a structured, commonly used and machine-readable format. To assert the aforesaid right, please use the contact addresses listed above.
9.6 RIGHT TO OBJECT
Pursuant to Article 21 GDPR, you have the right at any time to object to the processing of your personal data on grounds related to your particular situation, including grounds under Article 6(1)(e) or (f) GDPR. We will cease processing your personal information unless we can demonstrate compelling and legitimate grounds for processing that outweigh your interests, rights, and freedoms, or unless the processing is done for the purpose of enforcing, pursuing, or defending legal claims.
9.7 RIGHT TO APPEAL
You also have the right to contact the competent supervisory authority if you have a complaint. Default authority for such a complaint is Inspector General for Personal Data Protection (Generalny Inspektor Ochrony Danych Osobowych) in Poland (soon to be replaced by a new authority - Prezes Urzędu Ochrony Danych Osobowych), however you may also lodge a complaint with any other personal data protection authority in an European Union member state.

10. CHANGES TO THIS PRIVACY POLICY

The current version of this Privacy Policy is always available at [LINK to Vixa Games subpage] Last updated: 20 December 2018

© 2018 Vixa Games