Privacy and Cookies Policy
Effective Date: March 17, 2021
- Introduction and Applicability of This Policy
- organizing it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be implemented by us and
- defining and capitalizing a few terms that are used more than once, for the sake of simplicity and brevity.
2. Data Controller Details
2.1. Throughout this document, “Company”, “we”, “us”, “our” and “ours” refer to
Reaction Games Ltd. (“Data Controller”)
Address: PO Box No. 16, Kosmonavtov highway 110, Perm, 614087, Russia
3. Table of Contents
- Introduction and Applicability of This Policy
- Data Controller Details
- Table of Contents
- Data We Collect and Receive
- How We Use Data
- Who We Share Your Data With
- International Data Transfers
- Data Retention
- Security Safeguards
- Age Limits
- How To Exercise Your Personal Data Rights
- Contact US
4. Data We Collect and Receive
4.1. Usage Data
The browser may transfer certain information about the details of visits to the Site, including
- information about traffic, log-files, user activity on the Site;
- IP-address and mobile device identifiers (such as your device ID, advertising ID, MAC address, Android ID, IMEI);
- general location data;
- browser and device information, operating system.
4.2. Cookie Files and Similar Technologies
Cookies or similar technologies stored on your computer or device through which you use the Site have amongst others but without limitation, the following functions:
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
We may use third-party analytics providers software to allow us to better understand the functionality of our Site including but not limited to, Google Analytics, Yandex.Metrica (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Site. The information about your use of our Site, may be transmitted to and stored by Third-Party Analytics Providers’ servers, which may also be located outside of the European Economic Area.
This website uses Yandex.Metrica web analytics provided by YANDEX LLC, 16, Leo Tolstoy St., Moscow, 119021, Russia (hereinafter referred to as the “Yandex”).
Yandex.Metrica uses “cookies,” small text files placed on users’ computers to analyze user activity.
You can opt out of using cookie files by choosing the corresponding settings in your browser. You can also use the tool https://yandex.com/support/metrika/general/opt-out.html. However, it can affect some website functions. By using this website, you agree that Yandex can process your data in the above manner and for the above purposes.
You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.
4.3. Anonymous data
We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
4.4. Sensitive Information
We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.
4.5. Other Data
We may request any information required to organize and conduct events in the Game when you register to participate in such events initiated by us.
5. How We Use Your Data
5.1. We use your Data
- to provide the Services to You;
- to improve our Site and Services and to make them more comfortable to You
- to understand, improve, and research products, features, and services, including to create logs and record when you access our Site from different devices;
- to comply with the legal requirements.
5.2. With Your Consent
5.4.1. With your consent, we may process your data for additional specific purposes, for example to notify You and provide you with information including via email about features on our Services, new product releases and service developments, and to advertise our products and services.
5.4.2. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time (to find out what to do in this case, please refer to section 11.9.), but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean that you will no longer be eligible to use the Services.
6. Who We Share Your Data With
6.1. We share information we collect about you in the ways discussed below and only when necessary for compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties.
6.1.1. Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Services.
6.1.2. Customer Support Services: we engage third-parties to help us provide customer support for some territories and products. Such companies may have access to your personal data, including personal data that you may provide in your customer support requests.
6.1.5. Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you and that cannot reasonably be used to identify any individual user, for instance to show trends about use of the Services. We may also allow our third party advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve or modify their operations.
7. International Data Transfers
7.1. Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
8. Data Retention
8.1. We retain your data for as long as your account is active, or as long as is needed to provide you with the Service. We regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Security Safeguards
9.1. In order to help ensure a secure and safe usage of our Services, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
10. Age Limits
10.1. We do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under the age of 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
11. How To Exercise Your Personal Data Rights
11.1. You have certain choices available to you when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
11.2. You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.
11.3. Your requests and choices may be limited in certain cases, such as when fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
11.4. Access Your Data (Right of Access): Upon your request, we will provide you with a copy of your personal data in a structured, electronic format.
11.5. Change or Correct Your Data (Right to Rectification): You can edit some of your personal data (such as your email address) through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
11.6. Delete Your Data (Right to Erasure): In certain territories (including the European Union) you can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you).
11.7. Request That We Stop Using Your Data (Right to Object): In certain territories (including the European Union) where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims.
Opt-Out of Direct Marketing:
You can opt-out of receiving any direct marketing communications that we may send you by using the unsubscribe mechanism in those marketing emails.
You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
11.8. For European Union users only. Data Portability: Data portability is the ability to obtain some of your personal data in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
11.9. You may withdraw consent where processing of your personal data is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
11.10. We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.
12. Contact US
12.1. If you have any questions about how your personal data is collected, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at:
Reaction Games Ltd.
Address: PO Box No. 16, Kosmonavtov highway 110, Perm, 614087, Russia