VIA Marketing s.r.o – Gaming Privacy Policy

Last updated Oct. 05, 2020
Effective Oct. 06, 2020
Our Privacy Commitment

VIA Marketing respects your privacy rights and recognizes the importance of protecting your personal information. We are also committed to providing additional protections for children who visit and/or use our Services. To learn about privacy protections for children, read VIA Marketing ‘Children’ Privacy Policy.

VIA Marketing’ Apps covered by this Privacy Policy include any mobile applications (“apps”) displaying or linking to this Privacy Policy.

This Privacy Policy applies only to information submitted and collected online through the apps and does not apply to information that may be collected by VIA Marketing offline.

VIA Marketing reserves the right, at any time and without notice, to add to, change, update or modify this Privacy Policy and our Terms of Use, simply by posting such change, update or modification on the apps. Any such change, update or modification will be effective immediately upon posting on the apps. Your continued use of any of our apps will signify your acceptance of these changes.

1. Scope

Our Privacy Policy applies to the collection and processing of personal information by The VIA Marketing Co., Ltd., and our subsidiaries and affiliated company’s action on our behalf (“VIA Marketing” or “we”, “us”, or “our”). This Privacy Policy applies only to personal information collected about you as a consumer through the VIA Marketing network of apps, features, services, events, and communications provided by VIA Marketing where this Private Policy is posted (“Services”). This policy does not apply to human resources data or the “VIA Marketing” website.

Our international affiliates and third-party websites or apps that our Services link to , or with whom we may have a presence, or with whom we may license use of our trademarks and copyrights, may collect and use personal information for their own purposes. Where they do so, their respective privacy policies apply. Please review the respective terms and privacy policies of these entities to learn how they process your personal information.

2. Information Collected

We only process data and analytics about the use of our services such as in-game play progress, levels, games played, session length, preferred settings, in-game adverts, in-game preferences, game preferences, the means to use the services, device types, the operating systems, and internet service providers, and general geographic location. However, all of this information is aggregated and therefore we cannot identify you from it. For example, we retrieve Daily Active Users (DAU) and device type from Google Analytics and Apple, so we can understand how many users playing our games daily and from what devices our games are being accessed. We do not know which users use our games.

We don’t store any of your personal information, as no personal information is required to use our Services. However, we may access or receive information about the ways you use and interact with our Services through third parties services, individuals, and the intermediaries as discussed above and below.

3. Use of Cookies, Flash Cookies, Web Beacons, and Similar Technologies

We don’t collect personal data and we don’t use cookies, flash cookies, web beacons, and similar technologies to collect your personal information.

4. Third Parties Services

We employ third party companies and affiliates to facilitate our Services, to provide the Services on our behalf, to perform service-related services or to assist us in analyzing how our service is used (such as Facebook, Apple, Google Analytics and Amazon). We may collect certain information when you use our Services through these third-party service providers and affiliates, for example, when you connect your account to third-party services or sign in using a third-party partner (like Google Play Game Services, or iOS Game Center). We are not responsible for, and have no control over, the privacy practices or content of third party companies, individuals and affiliates. Therefore, you are encouraged to carefully review and understand the privacy policies of any third-party service providers, individuals and affiliates services.

5. Who We Share Information With

Below is the list of some, but not all, business partners that we actively share users’ information and site usage data with (the list is subject to change without notice):

From time to time we may transfer personal data outside the EEA. Such transfer will be subject to appropriate safeguards in accordance with the Data Protection Laws and in accordance with this Privacy Policy. Further details may be obtained by emailing [email protected].

6. How Long Do We Keep Your Information

We will retain your personal data only for as long as necessary in relation to the reason that we hold it. The criteria used to determine our data retention periods include: (a) the length of time we have an ongoing relationship with you; (b) whether there is a legal obligation to which we are subject; and (c) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. Children

We encourage parents to instruct their children about this Privacy Policy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission.

We consider a user to be a child if they are under the age of 13, unless the data protection regulation of their country of residence specifies another age, for example, in some EU countries, users under the age of 16 are considered children.

No personal information should be submitted to VIA Marketing by users under the minimum legal age required in their country of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their country of residence.

8. The EU General Data Protection Regulation (GDPR)

The EU General Data Protection Regulation (GDPR) is a European Union regulation (2016/679). It came into force on the 25th of May 2018. The aim of GDPR is to protect and enhance all EU citizens’ data privacy rights. GDPR applies to anyone that holds or processes the data of an EU citizen, regardless of where the person/company processing that data is based.

To comply with GDPR, we have updated our terms and conditions and privacy policy by updating our processes to ensure your updated rights are protected for the GDPR, ensuring any third party companies, individuals and affiliates we use or act on our behalf are also GDPR compliant, and instructing our staffs on the requirements of GDPR and data privacy procedures.

9. Your Rights If You Are Located the EU

You have the right to request a copy of your personal data, to request a copy is sent to a third party, to ask that we correct or delete your data and to ask that we restrict or stop processing your personal data. These rights may be restricted in certain circumstances and pursuant to the law in your jurisdiction. If you have any questions on how we process your data or wish to exercise any of your rights please contact [email protected]. We would hope that we may resolve any issue that you might have, however you also always have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction if you are located in the EU.

10. Changes to our Privacy Policy

We may amend this Privacy Policy at any time in response to changing legal, technical or business developments. If we make a change to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it.

11. Legal disclaimer

This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. You should be aware that our website may from time to time contain links to third-party websites. VIA Marketing is not responsible for the privacy practices or the content of such sites. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site to which you link before you submit any personal information. By accessing any external sites, you agree to the privacy policies of those sites.

12. Contact Information

All questions, comments or enquiries should be directed to VIA Marketing at [email protected].