Free Zone Limited Liability Company «GEEKY HOUSE» (registration number 98707), is a company duly registered in the free zone Dubai Internet City, headquartered in Dubai, United Arab Emirates (hereinafter «GEEKY HOUSE»).
GEEKY HOUSE respects the confidentiality of information about users of its games and other software (hereinafter referred to as the «Users» or «User») and therefore provides this Personal data processing policy so that Users can understand the methods that GEEKY HOUSE uses in process of personal data processing, learn the processing purposes, find out their rights.
This Personal data processing policy (hereinafter referred to as the «Policy») is developed in order to ensure the protection of the rights and freedoms of a person when his or she personal data is being processed, including the protection of the rights to privacy, personal and family secrets.
In this Policy, the terms «GEEKY HOUSE» / «we» / «our» / «us» mean GEEKY HOUSE, and «You» / «Your» means you as a User of our products.
ACCESS TO THE GAME OR OTHER SOFTWARE (HEREINAFTER REFERRED TO AS THE «PRODUCT») AND / OR THEIR INSTALLATION AND / OR USE MEAN YOUR ACCEPTANCE WITH THIS POLICY, PURPOSES AND METHODS OF PERSONAL DATA PROCESSING.
IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCEPT THE PRODUCT, DO NOT INSTALL OR USE IT.
1. Basic concepts used in the Policy.
1.1. Personal data — any information relating directly or indirectly to a specific individual (subject of Personal data, User).
1.2. Operator of personal data (Operator) — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) being Processing of Personal data, as well as determining the purposes of Processing of Personal data, the composition of Personal data to be Processed, actions (operations) performed with Personal data.
1.3. Processing of Personal data — any action (operation) or a set of actions (operations) with Personal data performed with the use of automation tools or without them. The Processing of Personal data includes, among other things:
- clarification (update, change);
- transmission (distribution, provision, access);
1.4. Automated Processing of Personal data — Processing of Personal data using computer technology.
1.5. Dissemination of data — actions aimed at transferring Personal data to a certain circle of persons (transfer of Personal data) or to get acquainted with the Personal data of an unlimited number of persons, including the disclosure of personal data in the mass media, posting in the Internet or providing access to Personal data in any other way.
1.6. Provision of data — actions of the User aimed at transfer of Personal data to a certain person or a certain circle of persons.
1.7. Blocking of Personal data — temporary suspension of the Processing of Personal data.
1.8. Destruction of Personal data — actions as a result of which it becomes impossible to restore the content of Personal data in the information system of Personal data and (or) as a result of which material carriers of Personal data are destroyed.
1.9. Depersonalization of Personal data — actions, as a result of which it becomes impossible to determine the belonging of Personal data to a specific subject without using additional information.
1.10. Cross-border transfer of Personal data — transfer of Personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.
2.1. The Operator is GEEKY HOUSE. GEEKY HOUSE may engage third parties to Processing of Personal data, including those located on the territory of the Russian Federation, to that the User agrees by accepting access to the Product and / or installing it and / or using it.
2.2. By installing, using or otherwise gaining access to the Product, you agree to the collection, storage, processing and transfer of your Personal data in the manner prescribed in this Policy. We may use this data in different ways and in different countries, but we always do it legally in accordance with applicable law.
2.3. If you are concerned about the way your Personal data is processed in accordance with this Policy, please refrain from accepting access, installation and use of our Products.
2.4. Our Policy does not allow persons under the age of 16 to provide Personal data without the consent of a legal representative, and we do not knowingly collect or request Personal data from persons under the age of 16, nor do we knowingly allow such persons to use our Products without the consent of a legal representative. We believe it is important to protect children's privacy and encourage parents to regularly monitor their children's use of software. We believe that the persons who have accessed and / or installed and / or use our Product are over the age of 16 or have obtained the consent of a legal representative.
If you are the legal representative of a child and suppose that he or she under the age of 16 had access and / or installed and / or used the Product and thereby provided us with Personal data, please contact us at the address United Arab Emirates, Dubai, Dubai Internet City, 07-Co Work Building, 1st Floor, SD2-78 or at the mailing address specified in Section 14 of this Policy, and we will Destroy such data upon receipt of supporting documents.
If you are not the legal representative of the child and think that we may have any Personal data about a person under the proper age of 16, please contact us at United Arab Emirates, Dubai, Dubai Internet City, Building 07-Co Work, 1st floor, SD2-78, or at the mailing address provided in Section 14 of this Policy and we will verify your assumptions.
Also, if we find out on our own that we have collected Personal data about a person who has not reached the appropriate age, we will Destroy this data as soon as possible from the date of discovery and receipt of supporting documents.
2.5. It is forbidden to provide Personal data of third parties without permission from third parties for such Provision, or if such Personal data were not obtained by the User himself from publicly available sources of information.
3. Basic rights and obligations of the Operator.
3.1. The Operator has the right to:
3.1.1. Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the applicable law.
3.1.2. Entrust the Processing of Personal data to a third party with the consent of the subject of Personal data, in accordance with applicable law, on the basis of an agreement concluded with this person or entity. The person who Processes Personal data on behalf of the Operator is obliged to comply with the principles and rules for Processing of Personal data provided for by the applicable law.
3.1.3. Continue Processing of Personal data without the consent of the subject of Personal data in accordance with applicable law if the subject withdraws acceptance to the Processing of Personal data.
3.2. The Operator is obliged to:
3.2.1. Organize the Processing of Personal data in accordance with applicable law.
3.2.2. Respond to requests and inquiries from subjects of Personal data and their legal representatives in accordance with the requirements of applicable law.
4. Basic rights of the subject of Personal data.
4.1. The subject of Personal data decides on the provision of his Personal data and agrees to their Processing freely, of his own free will and in his interest.
4.2. The Personal data subject has the right to:
4.2.1. Receive information regarding the Processing of his Personal data in accordance with applicable law. The information is provided to the subject of Personal data by the Operator in an accessible form, and it should not contain Personal data relating to other subjects of Personal data, unless there are legal grounds for disclosing such Personal data. This procedure is determined by applicable law. If applicable law doesn't contain such rules the Operator uses provisions of General data protection regulation of European Union.
4.2.2. Require the Operator to clarify his Personal data, block or destruct them if the Personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights.
4.2.3. Appeal to the authorized body or in court the illegal actions or inaction of the Operator during Processing of Personal data, to protect in another way rights and legitimate interests, including demanding compensation for damages and (or) compensation for moral damage in court.
5. Personal data we Process.
5.1. We Process data provided during registration, installing, accessing and using the Product, as well as when contacting us, for example:
- email address, social media accounts;
- transaction details, payment amount, date and time of payment, information about purchases within the framework of an offer or other payment, or information related to subscription to Products, their purchase;
- account name (nickname), login, password, secret word, identifier assigned when using the Product, profile photo and other information specified by you on the Product platform;
- other data that you choose to provide when using and / or accessing and / or installing the Product, via email or web forms, including at our request, to the support service;
- the content of messages sent using our chats and messaging systems or other information that you send to a third party;
- last name, first name, patronymic, date and place of birth, series and number of an identity document, marital status, presence of children, registration address at the place of residence, contact information, individual taxpayer number, other personal data provided by Users.
5.2. The results of the surveys you have completed, the ratings given to the Product, your reviews, comments and etc.
5.3. Data about your device, such as its name, type, model, operating system, settings, its language, or other technical data such as screen size or processor, or a combination of these data, available from the device to the developer for checking the device's compatibility with a specific application; App IDs, Device ID, Advertising ID (unique device-related identifiers that advertisers use to identify ads of interest).
5.4. Data we collect using cookies or similar technologies.
5.5. General location data (such as the location of a country or city) based on your IP address, IP address itself, device identifiers (which may include: unique mobile device identifier (UDID), international mobile equipment identifier (IMEI), Android ID, Device MAC Address, Android Advertising ID, Advertising ID (IDFA) and Seller ID (IDFV) for iOS, and OPEN UDID and ODIN).
5.6. Analytics about the use of the Product (for example, game progress, levels, purchases made, advertising, data on gameplay, points, session duration, preferences, in-game links or game preferences, about which friends the User communicates with, etc.).
5.7. Information about how and when you play and / or use the functionality of the Product (including screen recording while using the Product, as well as the start or end time of using the Product, the frequency of using the Product, what in-game ads you view, searches, referrals, closing applications, games, in-game preferences) and logging errors when using the Product.
5.8. Data that we receive from the User's social media accounts if the User associates a third party's service with the Product.
5.9. Anti-fraud data (such as in-game payment abuse or click fraud in advertising).
5.10. Information about your orders (for example, products, date, amount, status, description, extended geographic location (for example, country or city)).
5.11. Data from third parties, services that have received your consent to the Processing of Personal data or have another legal right to share such information with us (including publishing partners, publishing platforms, advertising platforms and advertising partners, as well as data aggregators).
Whether we process any of the data listed above, or all of this data, often depends on the type of device used and its settings. These technologies enable us and third parties (including marketers and advertisers) to recognize your device when you use the Products.
5.12. We may from time to time ask you for your consent to the Processing of other Personal data. If we do this, we will definitely tell you what data we would like to process, why we need it and what we will use it for.
5.13. Please note that we do not guarantee the protection of any Personal data that you decide to share in your account, in the comments or otherwise make available to an indefinite circle of people, including but not limited to chats, forums, blogs where you can place your data. We are not responsible for how this data is used by others. Therefore, please be careful when distributing any data, including using the Product.
6. Purpose of Processing of Personal data.
6.1. The Processing of Personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of Personal data that is incompatible with the purposes of collecting Personal data is not allowed.
6.2. Only Personal data that meet the purposes of their Processing is subject to Processing.
6.3. We primarily use Personal data when Processing is necessary for the performance of a contract to which you are a party, or to take action at the request of the data subject prior to entering into a contract.
6.4. The Processing of Personal data is carried out for the following purposes:
6.4.1. Ensuring compliance with the applicable law.
6.4.2. Carrying out of its activities by the Operator in accordance with the internal documents of GEEKY HOUSE.
6.4.3. Implementation of civil law relations.
6.4.5. Providing you with the opportunity to use the Product.
6.4.6. Communication with you, whether it is serving Users or sending information about our Products.
6.4.7. Managing your account and improving the quality of your service when using our Products.
6.4.8. Researching, conducting surveys and interacting with you via email or other means.
6.4.9. Developing, improving and customizing the Product and servicing the Users.
6.4.10. Providing you with our offers in the Product, via email or otherwise.
6.4.11. Promotion of our Product.
6.4.12. Referral to your request for relevant information, safety warnings and support messages.
6.4.13. Moderating chats automatically or manually.
6.4.14. In order for you to be able to communicate with other players.
6.4.15. Providing personalized advertisements on the Product, via email or otherwise.
6.4.16. Tracking the content you access using the Products and your online activities.
6.4.17. Delivery, personalization and improvement of our advertising and Product.
6.4.18. Combating fraud, preventing crime or attempted deception, as well as ensuring the proper use of the Product and taking action against fraudulent or dishonest Users.
6.5. With your consent, we may process your data for additional purposes.
7. The procedure and conditions for the Processing of Personal data.
7.1. The Processing of Personal data is carried out by the Operator in accordance with the requirements of applicable law.
7.2. The Processing of Personal data is carried out with the consent of the subjects of Personal data to the Processing of their Personal data, as well as without it in the cases provided for by applicable law.
7.3. The Operator can carry out both automated and non-automated Processing of Personal data.
7.4. The Operator's employees, whose job responsibilities include the Processing of Personal data, and other persons involved by the Operator, are allowed to Process Personal data.
7.5. The Processing of Personal data is carried out by:
- receiving Personal data orally and in writing directly from the subjects of Personal data;
- obtaining Personal data from publicly available sources;
- entering Personal data into the logs, registers and information systems of the Operator;
- using other methods of Processing Personal data.
The Dissemination of Personal data without the consent of the subject of Personal data is not allowed, unless otherwise provided by applicable law. Consent to the Processing of Personal data that can be Disseminated on the basic of subject's of Personal data permission is drawn up separately from other consents of the subject of Personal data to the Processing of his Personal data.
7.7. The transfer of Personal data to the bodies of inquiry and investigation, authorized executive and legislative bodies is carried out in accordance with applicable law.
7.8. The Operator takes the necessary legal, organizational and technical measures to protect Personal data from unauthorized or accidental access to them, destruction, alteration, blocking, distribution and other unauthorized actions, including:
7.8.1. Identifies threats to the security of Personal data during their Processing.
7.8.2. Adopts documents regulating relations in the field of Processing and protecting Personal data.
7.8.3. Appoints persons responsible for ensuring the security of Personal data.
7.8.4. Creates the necessary conditions for working with Personal data.
7.8.5. Organizes the accounting of documents containing Personal data.
7.8.6. Organizes work with information systems in which Personal data is processed.
7.8.7. Stores Personal data in conditions under which their safety is ensured and unauthorized access to them is excluded.
7.8.8. Organizes training for the Operator's employees who process Personal data.
7.9. The Operator stores Personal data in a form that makes it possible to determine the subject of Personal data, no longer than the purpose of Processing of Personal data requires, if the storage period for Personal data is not established by applicable law or by an agreement.
7.10. We take the security of your Personal data very seriously. We provide technical and physical security measures to ensure the protection of your Personal data from accidental or illegal loss, destruction, alteration, unauthorized access or disclosure, or any other use or illegal Processing of Personal data that you have provided to us. Our Personal data security mechanisms are similar to those of other Product developers. But please keep in mind that the Internet is not 100% secure and we cannot guarantee that your Personal data provided by you will not be disclosed, changed or destroyed if security mechanisms are violated.
8. Providing Personal data to third parties, receiving Personal data from third parties.
8.1. We may provide your Personal data (i) to third parties, companies belonging to the Geeky House group of companies, suppliers and partners, regardless of their legal form, who provide us with data processing services and with whom we have signed agreements, or who otherwise Process Personal data for the purposes described in this Policy, or notify you when we collect your Personal data (for example, technical support providers, software providers, advertising and marketing partners, professional consultants (for example, lawyers, accountants, tax consultants, auditors and insurance brokers); (ii) government agencies, courts, government representatives or other third parties, if necessary in accordance with applicable law; (iii) third parties when a corporate restructuring or sale of GEEKY HOUSE assets occur, or changed as a result control over GEEKY HOUSE or its affiliates, or to prepare for any of these events. Any such third party has the right to continue to Process your Personal data in accordance with this Policy; or (iv) any other natural or legal person with your consent to disclose Personal data.
8.2. By accepting this Policy, without abandoning interest-based advertising (targeted), you thereby consent to us and our advertising partners to Process Personal data about you to improve advertising systems. So that we can show you the advertising you are interested in according to your preferences.
8.3. By accepting this Policy, you also authorize us at any time and at our sole discretion to provide third parties with anonymous and statistical data that does not contain Personal data.
8.4. If you use a third party social network or platform (third party) to access / install / use our Products, that third party, with your consent, may provide us with your Personal data. Please carefully read the terms of service and the Personal data Processing policy of third parties in order to understand exactly how they use your Personal data and what data may be transferred.
8.5. When you allow any interaction between our Products and any social network, platform or site owned by a third party, we may also share your Personal data with your contacts so that you can interact with other Users.
9. Updating, correcting, deleting and destroying Personal data, responding to requests from subjects of Personal data.
9.1. Confirmation of the fact of Personal data Processing by the Operator, legal grounds and purposes of Personal data Processing, as well as other information specified are provided by the Operator to the subject of Personal data or his representative upon contact or upon receipt of a request from the subject of Personal data or his representative.
The information provided does not include Personal data relating to other subjects of Personal data, unless there are legal grounds for disclosing such Personal data.
The request is sent in accordance with applicable law.
9.2. In case of revealing inaccurate Personal data when the subject of Personal data or his representative applies, or at their request or at the request of the authorized body, the Operator blocks Personal data related to this Personal data subject from the moment of such a request or receipt of the specified request for the verification period, if the blocking of Personal data does not violate the rights and legitimate interests of the subject of personal data or third parties and complies with applicable law
In case of confirmation of the fact of inaccuracy of Personal data, the Operator, on the basis of information provided by the subject of Personal data or his representative or authorized body, or other necessary documents, clarifies the Personal data within seven working days from the date of submission of such information and removes the blocking of Personal data.
9.3. In the event that unlawful Processing of Personal data is revealed when the subject of Personal data or his representative or authorized body applies (request), the Operator blocks the unlawfully Processed Personal data relating to this subject of Personal data from the moment of such a request or receipt of the request.
9.4. Upon achievement of the goals of Processing of Personal data, as well as in the event that the subject of Personal data withdraws consent to their Processing, Personal data are subject to destruction if:
9.4.1. Anything else is not provided for by the contract, to which the subject of Personal data is a party, beneficiary or guarantor.
9.4.2. The Operator is not entitled to carry out processing without the consent of the subject of personal data on the grounds provided for by applicable law.
9.4.3. Otherwise, it is not provided by another agreement between the Operator and the subject of Personal data.
10. Storage of Personal data.
10.1. Your Personal data will be processed and stored for as long as it is necessary to provide you with our Products or to complete any purposes for which they were originally intended. But please note that even after you close your account or stop using our Products, we may continue to store your data if it is necessary to comply with our legal obligations.
11. Links to third parties in our Products.
11.1. In our Products, we may insert links to third party websites, platforms, products, services of third parties. It should be understood that when you click on any of these links, you may be taken to a third party site, and therefore, all Personal data provided by you will not be protected in accordance with this Policy. Of course, we care about the selection of authoritative links, but please note that we do not control and are not responsible for the content, Personal data Processing policies or practices of third party sites or services.
12. Cross-border transfer of Personal data.
12.1. Our Products are global in nature, so your Personal data can be transferred anywhere in the world. Since different countries may have different data protection laws than the laws of your country, we take steps to provide adequate safeguards to protect your data as described in this Policy.
12.2. By accepting this Policy, the User agrees to the transfer of his Personal data to other countries.
12.3. The procedure for Processing of Personal data may differ depending on the legislation of the countries in which we operate.
13. Dispute Resolution.
13.1. Disputes between you and GEEKY HOUSE
Our goal is to resolve disputes fairly and quickly. In all disputes with us, you agree to first contact us and try to resolve the dispute informally by sending us a written notice of claim (the «Notice»). The Notice must be sent by registered mail with a description of the attachment to the address specified in section 14 of this Policy, or by email with confirmation of receipt. The Notice must (a) contain your email address or social media account associated with your account; (b) describe the type and reason for the claim; and © indicate the specific compensation claimed, if any. If we are unable to agree to resolve the dispute within 60 business days of receiving such notice, either party may initiate legal proceedings.
13.2. User disputes
You are solely responsible for your interactions with other Users of the Product. We reserve the right, but are not obligated to, to track disputes between you and other Users.
14. How to contact us.
14.1. If you have any questions regard to this Policy or would like to exercise the rights to the protection of Personal data described above, please contact us by email: email@example.com
or at: United Arab Emirates, Dubai, Dubai Internet City, building 07-Co Work, 1st Floor, SD2-78.
15. Changes to the Policy.
15.1. In the event that our Policy is changed or updated, any changes or updates will be posted so that you are aware of what Personal data we collect, how it is used, stored, and when we have the right to disclose it.
15.2. We reserve the right to make any necessary changes to this Policy at any time, so please review it often.