PRIVACY POLICY

1. General Provisions

These Privacy Policy is a legally binding document, which constitutes an integral part of the Terms of Use of Our App, Site or Game, and aimed to regulate relationships between Owners and Users of Our App, Site or Game and contains the scope of confidential information, the methods for its collection, storage, processing, disclosure, analysis, ensuring security during the use of Our App, Site or Game. It is strongly recommended for Users to read carefully the following conditions before they start usage of mobile application, as well as its content, or other related products. By using the mentioned products, you acknowledge your consent to use mobile application in accordance with these terms. If Users do not accept fully or partially the terms of present Privacy Policy, they should terminate or not to start the usage of mobile application.

2. The scope and types of confidential information

The confidential information that is collected, stored or processed while using Our App, Site or Game includes the following types of information:
- Contact Information: This includes, in particular: mobile phone numbers, name and surname of User, email address, i.e. information by means of which User can identify himself as authorized User of Our App, Site or Game, as well as authorisation data/information in order to access social networks, third party mobile applications, services and other software - in case of connection to/exploitation of its functionality.
- User Information: This includes, in particular: any information in any format that is generated and uploaded directly by User, shared, received, distributed in any form by User while using Our App, Site or Game, as well as information about the User himself.
- Third party Materials: This includes, in particular: data/information, products, content, intellectual property created, published or otherwise accumulated from third parties, other than User and / or Owner.
- User Account Information: This includes, in particular: information which is received / collected, in particular - about IP addresses, device types, which are used for running Our App, Site or Game, time and frequency of installations, visits, geo-location of Users and devices, metadata, comments, ratings, feedback posted by Users, received from other users / content of third parties.

3. Purposes for the collection of confidential information

Collection of information is necessary in order to enable the following:
- Registration and authorization;
- Performance of User's tasks;
- Detecting, investigating, and combating fraud, non-permitted access or any other kind of illegal activity in relation to the Our App, Site or Game;
- Ensuring technical support for Users of Our App, Site or Game;
- Administration of mobile applications;
- Ensuring compliance with the Terms of Use of Our App, Site or Game;
- Analytics of accumulated, deconfidentialized and anonymized information in order to improve and optimize the quality of service, which results will be used to optimize Our App, Site or Game functionality and improve the service provided.
- With respect to above mentioned Owner agrees to obtain a full and explicit User consent for the collection and processing of mentioned data/information/information.
- By registering with Our App, Site or Game, as well as actual using of Our App, Site or Game and setting tasks via Our App, Site or Game, including tasks for data/information sharing, User expresses his full and explicit consent for the collection and processing of mentioned confidential data/information.
- By accepting this Privacy Policy, User acknowledges and agrees that the data/information listed above will be collected, processed and stored on the Owner's servers. The collection, storage, processing, or any use of the information for purposes other than the purposes specified in this Agreement, is strictly prohibited. No one may distribute, publish or otherwise exploit User information in any way, which violates or potentially violates the rights of third parties, or other Users.

4. The moment of data/information collection

The owner of the application collects information when:
- User registers within Our App, Site or Game;
- User directly uses mobile application interfaces;
- Users create, upload and share data/information between each other or otherwise communicate;
- User communicates with Owner through Our App, Site or Game and related systems.

5. Disclosure of confidential data/information

Owners reserve the right to disclose User confidential data/information to following persons:
- Third parties who are partners of the Owner and shall, therefore, assist in the provision of service (maintaining services, support, hosting, data/information base management, etc.). In this case, the information is disclosed exclusively for the purposes of service provision, and person to whom it is available, undertakes not to disclose or use information outside the scope of this Privacy Policy;
- Representatives of public authorities - in order to respond to legally reasonable requests in connection with official procedures, investigations, if the obligation to disclose is required by the current legislation;
- Professional advisors (lawyers, auditors, etc.) for the purposes of an independent audit, corporate governance and compliance procedures.

6. User consent

Disclosure, transfer, exchange of confidential information is possible only based on full, expressed and explicit User consent. User has an opportunity at any time to prevent, to stop the transfer, or sharing of confidential information.

7. Storage and data/information Security

Owner undertakes all the necessary and reasonable measures to protect User information from leakage, loss, illegal and unauthorized use. However, User should be aware that Our App, Site or Game is open, can be accessed online, and therefore can potentially be subject to cyber-attacks, viruses, and other similar negative activities. Online access a priori does not guarantee the absolute safety of the App; Our App, Site or Game Users use application at their own risk and Owners do not bear any responsibility for damage / loss raised from the threats to information and cyber security. The user is also aware that the applicable information security and data/information protection tools cannot guarantee the absolute security of any data/information shared. Owners are not responsible for the actions of third parties, to whom User opens, discloses or otherwise transmits information. Since Our App, Site or Game enables communications globally, User acknowledges and agrees that confidential information may be transferred to the devices that are located in any other country of the world, and with different levels of data/information protection. Using the mobile app, the User acknowledges and agrees to such data/information traffic.

8. Confidential data/information Change

Users have the right at any time to change, update, correct or delete confidential information via Our App, Site or Game. User agrees that after removal of his registration data/information / content - a copy of the data/information can continue to be stored on the server because of the data/information backups for some time. However, the Owner is not obliged to store such data/information after termination of the present Agreement and User is aware and agrees that after termination of the registration his data/information and content will not be saved.

9. Cookies

Cookies-files may be used to monitor the use of Our App, Site or Game and web traffic in order to optimize and improve the service. User is aware and agrees that cookies may collect his certain confidential information, including information about IP-addresses, information on the types of devices and used operating systems, time and frequency of visits. User can at any time to change the settings of his browser by blocking the ability for automatic use of cookies. The information gathered may be used solely for the purposes of analytics, based on deconfidentialized and anonymized data/information, the results of which will be used in order to optimize the functionality of Our App, Site or Game and to improve the service provided. Blocking of cookies, however, may affect the ability to access to certain functionality of Our App, Site or Game.

10. The procedure for making amendments and additions to the Terms

Owners reserve the right at any time to revoke the terms and conditions of this Agreement, to make changes, additions, without prior User consent or other prior notices. In case if certain provisions of the present Agreement turn to be invalid or ineffective under the jurisdiction of particular countries, the mentioned does not affect the legal force of the entire Agreement, as well as the validity of some of its provisions in specific jurisdictions. Since consequent changes to the terms of the present Agreement are made, they shall be published on the Platform, where Our App, Site or Game is located, with the appropriate notification on the updating date at the top of the text.

11. Details to Privacy policy (for VOODOO partnership)

NETSOFTWARE (including all partners) is an international entertainment company specialized in the publishing of mobile games and applications.

The purpose of this policy is to provide you with all the important information and explanations about how and why some of your data may be collected and processed by NETSOFTWARE (including all partners) when you use one of our applications or browse on our website. This privacy policy governs and details the main principles that NETSOFTWARE (including all partners) applies to the data we collect and process to:
- develop, publish and monetize mobile games and applications (“NETSOFTWARE (including all partners) Apps and Games”), and
- run our corporate website NETSOFTWARE (including all partners). This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them. Should you have any questions related to this policy or our practices around privacy and data protection in general, please don’t hesitate to contact NETSOFTWARE (including all partners) Data Protection Officer as indicated in the contact section of this policy.

NETSOFTWARE (including all partners) apps and games

Why does NETSOFTWARE (including all partners) collect data from its apps and games? When you install and use NETSOFTWARE (including all partners) mobile applications, we can collect and process some of your data for different legitimate purposes. You will find below explanations regarding the reasons why NETSOFTWARE (including all partners) may collect data and the legal bases NETSOFTWARE (including all partners) relies on in each case. NETSOFTWARE (including all partners) collects data:
- To provide you with the services you asked for (e.g., knowing that you completed the first level to allow access to the second one)
- Legal basis – such data processing is strictly necessary for the service(s) asked
- To run analytics and understand how users interact with our product and services in order to continuously improve it either directly or through third party partners (e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)
- Legal basis for third party analytics - Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, NETSOFTWARE (including all partners) only shares personal data collected through NETSOFTWARE (including all partners) apps with third party partners that provide NETSOFTWARE (including all partners) with analytics services once you express your consent through the pop-up notice included in our apps.
- Legal basis for first party analytics – Legitimate interest. NETSOFTWARE (including all partners) collects user data for the purpose of its own internal analytics tools. Data is used for the sole purpose of NETSOFTWARE (including all partners) analytics tool and is not shared with any third parties. This data processing is based on the legitimate interest of NETSOFTWARE (including all partners).
- To serve advertising tailored to the preference and interests of our users and allow NETSOFTWARE (including all partners) to continue to provide free services and products
- Legal basis – Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, NETSOFTWARE (including all partners) only processes or shares personal data collected through NETSOFTWARE (including all partners) apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps. For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page in our various applications. Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

What data does NETSOFTWARE (including all partners) collect from its apps and games?

For all the purposes listed above the data that NETSOFTWARE (including all partners) collect is limited to:
- The apps you are using
- Your IP address
- Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
- Technical information about the device you use and your connection (user agent, type of connection, timestamp)
- 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 advertising served in our applications (for instance, number of ads served, potential clicks)

With who may your data be shared & why?

NETSOFTWARE (including all partners) does not share your personal data with third parties without your prior consent in the countries where collecting users’ consent may be required by applicable laws and regulations. When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:
- Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.
- Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter.
- Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:
- Authorities: only to the extent we are obliged to by applicable laws and regulations.

NETSOFTWARE (including all partners) website

Why does NETSOFTWARE (including all partners) collect data from its website? Like on most websites, when you browse on NETSOFTWARE (including all partners).io certain information about your connection and device(s) are automatically collected for the website to operate properly. NETSOFTWARE (including all partners) and its partners also use cookies and similar technologies to analyze how our users interact with our services and administer the website. Cookies are small text files stored on your browser that allow the collection of non-personally identifiable information related to your navigation on a website. You can control the use of cookies in your browser settings but if you choose to disable cookies it may affect certain websites’ functionalities. What data does NETSOFTWARE (including all partners) collect from its website? For the purposes listed above the data that NETSOFTWARE (including all partners) and its partners collect is limited to:
- Browsing events and interactions with the website’s contents and services
- Anonymized IP address and technical information related to your browser and/or device (user agent)
- Information you provide us with voluntarily when you contact NETSOFTWARE (including all partners)

Analytics and third party cookies

NETSOFTWARE (including all partners) uses Google Analytics to collect information related to the web traffic on our website. This service allows us to measure the performance and proper functioning of our website and to provide you with a better experience. NETSOFTWARE (including all partners) made sure to configure this tool in such a way that the information collected for this purpose is anonymized in a way that does not allow to identify any end users of our website. For more information on the data protection and privacy aspects of these analytics services, you can refer to Google specific policy accessible here: https://policies.google.com/privacy and opt-out from Google Analytics data collection here: https://tools.google.com/dlpage/gaoptout

Social networks and other communication tools

Our website also offers communication tools allowing users to share content on social networks. When you interact with such social media widgets or “share buttons”, these social network companies may collect information about you and/or your device and connection. your interactions with these services are governed by the respective privacy policies of the companies providing these services. For more information on the data protection and privacy practices of these companies, you can refer to their specific policies listed below:
- Facebook: https://www.facebook.com/about/privacy/
- Linkedin: https://www.linkedin.com/legal/privacy-policy

Security and other important information

How long does NETSOFTWARE (including all partners) keep your data? Personal data collected, received and processed for the purposes described in this policy is not kept longer than necessary by NETSOFTWARE (including all partners). NETSOFTWARE (including all partners) does not retain user level data for more than 13 months except for the data collected for the purpose of its first-party analytics tool which can be stored up to 25 months based on the guidelines of our Supervisory Data Protection Authority.

Children data

NETSOFTWARE (including all partners) never knowingly or willingly collect any personal data concerning children under 16 years of age.

International transfers

Some of the partners and processors referred to in this policy are located outside of the European Union and Ukraine and US. In such case, we ensure that:
- the personal data is transferred to countries recognized as offering an equivalent level of protection or,
- for personal data transferred outside of countries recognized by the Ukraine and European Commission and Ukraine as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and notably the adoption of the standard contractual clauses of the European Commission and Ukraine.

What rights do you have?

Consent withdrawal and opt-out of sale of information

You can change your consent status at any time from the Privacy Settings available in NETSOFTWARE (including all partners) mobile games and applications. Please note that if NETSOFTWARE (including all partners) does not sell the personal information of its users, we may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services. Adjusting your consent settings within NETSOFTWARE (including all partners) apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

Access right

Upon request, NETSOFTWARE (including all partners) will provide you with information about whether we hold any of your personal information. You may access or request deletion of your personal information directly in NETSOFTWARE (including all partners) mobile apps or by contacting NETSOFTWARE (including all partners) Data Protection Officer as indicated in the “Contact” section below. We will respond to your request within a reasonable timeframe.

Rectification and erasure

You may request NETSOFTWARE (including all partners) the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request NETSOFTWARE (including all partners) to erase without undue delay your personal data when it is no longer necessary for NETSOFTWARE (including all partners) to retain such data. In order for your data to be erased or rendered inaccessible you can either:
- reset your mobile advertising identifier (IDFA on iOS, GAAID on Androïd) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
- contact NETSOFTWARE (including all partners) Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by NETSOFTWARE (including all partners) on you and/or your device permanently erased or anonymized

Portability

Upon request, NETSOFTWARE (including all partners) will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract.

12. The contact details

Site: https://netsoftware.com.ua
Email: support@netsoftware.com.ua


Last updated on April 25, 2022