PRIVACY POLICY FOR ELEMENT LTD (ELEMENT) PROJECTS AND SERVICES
ELEMENT follows generally accepted industry standards to protect the information you submit. Please note
that
information that you voluntarily make public or disclose by posting will be publicly available and
viewable
by
others. ELEMENT bears no liability for any information that you voluntarily choose to make public
through
such
and/or other explicit actions, but ELEMENT is nevertheless committed to protecting and respecting your
privacy.
This Privacy Policy (“Privacy Policy”) describes how ELEMENT treats information that you provide or that
ELEMENT
collects about you.
“Personal Data” refers to data that relates to you as an identified or identifiable natural person. The
term
“Personal Data” may apply to information such as, but not limited to, your name, address, telephone
number,
email address, age, gender, and game preferences. Anonymous information that ELEMENT is not in a
position to
relate to you does not qualify as Personal Data.
By accepting this Privacy Policy, users of the Games and Website (these terms are defined below)
expressly
agree
to the provision, processing and storage of Personal Data within the scope and on the terms specified in
the
Privacy Policy. By submitting Personal Data to ELEMENT, users of the Games and Website consent to its
storage,
processing, and transfer (including cross-border transfer if required by the Services [the term is
defined
below]). If users of the Games and Website have any questions or suggestions regarding this Privacy
Policy
they
may email ELEMENT at email set in section 1 below.
1. DATA CONTROLLER
The “Controller” of data falling under the aegis of the General Data Protection Regulation (GDPR) and other
data
protection or data privacy laws of the Member States of the European Union and other guidelines that apply
to
data protection on the part of the website
elementgames.ru (“Website”) and
games for
mobile and other devices
(“Games”),
which are distributed through online stores such as the Apple Store, Google Play, etc., is:
ELEMENT LTD Address:
Entuziastov street, 2, office 212
Chelyabinsk 454080, Russia
The term “Services” refers to providing users of the Games and Website with the opportunity to use the Games
and
Website and any other ELEMENT products and services (including support services and forums) related to the
Games
and Website.
2. DATA PROTECTION OFFICER’S CONTACT INFORMATION
ELEMENT LTD Address:
Entuziastov street, 2, office 212
Chelyabinsk 454080, Russia
email: info@elementgames.ru
3. FUNDAMENTALS OF THIS PRIVACY POLICY
a. The processing of the personal data of users of the Games and Website is performed solely for the purpose
of
fulfilling ELEMENT’s obligations to users of the Games and Website as follows:
- provide and operate Services;
- improve our Services and keep them secure;
- personalize Services;
- promotional activities, including marketing and advertising;
- comply with ELEMENT’s legal obligations;
- prevent and/or detect fraud or fraudulent behavior.
b. The collection and processing of Personal Data are prerequisites for the possibility of providing users
with
access to the Games and Website. When processing Personal Data, ELEMENT adheres to the legal rights and
interests of the users of the Games and Website and.
ñ. ELEMENT complies with international standards of Personal Data protection and protects users’ personal
data.
4. LIMITATIONS OF THIS PRIVACY POLICY
This Privacy Policy applies to the Games and Website only. ELEMENT does not control and is not responsible
for
third-party resources to which users of the Games and Website can go through the Games and Website.
5. ENSURING INFORMATION SECURITY
ELEMENT understands the importance of privacy for users of the Games and Website. ELEMENT maintains
reasonable
and appropriate security procedures to protect the personal information of users of the Games and Website
against loss, misuse, unauthorized access, disclosure, alteration, and destruction, while taking into
account
risks involved in the processing of and the nature of the Personal Data.
6. DATA RETENTION AND DATA DELETION
ELEMENT, in the process of processing Personal Data, stores some of the Personal Data of users of the Games
and
Website for as long as users of the Games and Website continue to use the Games and Website. ELEMENT will
delete
the Personal Data of a user of the Games and Website if there is no ongoing legitimate business need to
process
data or after receiving the corresponding request from a user of the Games and Website via the email address
specified in Section 2 of this Privacy Policy within a reasonable time.
7. PROCESSING OF PERSONAL DATA OF MINORS
ELEMENT believes that the Games and Website are used by persons who have reached the age of majority or have
consented while in the presence of a legal guardian. If ELEMENT discovers that the Games and Website are
being
used by a minor under the age of 13, the Personal Data of such person will be immediately destroyed by
ELEMENT
and removed from all ELEMENT databases in full. ELEMENT recommends that minors aged 13-17 seek a consent
from
parents or legal guardians before accessing and/or using Games and Website and providing any private
information.
8. TARGETED AND PERSONALIZED ADVERTISING
8.1. To show you personalized advertisements in the Services as well as in other websites and services
(including email) we have a legitimate interest to process necessary data to track the content you access in
connection with the Services and your online behavior deliver, target and improve our advertising and the
Services.
8.2. You can opt-out of interest-based advertising on mobile applications by checking the privacy settings
of
your Android or iOS device and selecting:
"limit ad tracking" - (Apple iOS), or
"opt-out of interest-based ads" - (Android).
For personalized in-game offers opt-out, you can use the options provided in the game settings.
9. PROVIDING INFORMATION TO THIRD PARTIES
9.1. ELEMENT has the right to provide the Personal Data of users of the Games and Website to its affiliates,
subsidiaries, vendors, or agents working on its behalf for the purposes described in this Privacy Policy.
Vendors or agents of ELEMENT adhere to data privacy and security requirements and are not allowed to use the
Personal Data they receive from ELEMENT for any other purpose.
Your personal information may be transferred to, and processed in, countries other than the country of which
you
are a resident. These countries may have data protection laws that are different from the laws of your
country.
This means that in order to facilitate the use of the Games and Website, ELEMENT may transfer Personal Data
to
suppliers or agents working on ELEMENT’s behalf and transferred to and processed it in any of these
countries.
However, ELEMENT ensure appropriate safeguards are in place so that your personal information will remain
protected in accordance with this Privacy Notice. This includes complying with the European Commission’s
Standard Contractual Clauses for transfers of personal information among ELEMENT and third-party service
providers and partners, which require all members to protect the personal information they process from the
EEA
in accordance with European Union data protection law. It also includes the transfer of personal information
to
third-party service providers and partners that are certified under the EU-US Privacy Shield.
9.2. Since the list of ELEMENT’s partners can change over time, users of the Games and Website can always
request an up-to-date list of partners to which data is provided. Users of the Games and Website may request
this information via email at
info@elementgames.ru. By giving
ELEMENT Personal Data, users of the Games and
Website agree to such transfer, storage, or processing. ELEMENT will take all reasonable steps necessary to
ensure the security of the Personal Data of users of the Games and Website in accordance with this Privacy
Policy.
10. LIST OF PROCESSED PERSONAL DATA
ELEMENT processes only information received directly from users of the Games and Website in accordance with
Article 6 (1) (f) of the GDPR Regulation, as well as any information that is automatically handled by
technical
methods when using the Games and Website. ELEMENT collects Personal Data and other information that users of
the
Games and Website voluntarily provide, namely:
- Information provided by users of the Games and Website when requesting information or support from
ELEMENT;
- Information that users of the Games and Website have posted on various gaming forums and websites
concerning
the Games;
- Access time in the Games and Website;
- IP address;
- Tracking data and cookies (specified in Section 12 of this Privacy Policy);
- Information sent through in-game data transfer in the Games and Website, including when participating in
competitions, contests, and tournaments and responding to surveys;
- Information relating to profiles of users of the Games and Website on social networking websites for the
purpose of ensuring integration with such social networking websites; and
- Other information, including information indirectly received through users of the Games and Website when
interacting with the Games and Website and resources on the internet used when using the Games and Website.
This
information may include, but is not limited to, browser and device information, data collected through
automated
electronic interactions, application usage data, demographic information, geographical and geo-location
information, and statistical and aggregated information. Statistical or aggregated information does not
directly
identify a specific person, but it may be derived from Personal Data. When combining such information with
Personal Data, ELEMENT will treat the combined information as Personal Data.
11. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
a. To access, correct, update or request deletion of your Personal Data;
b. To object to the processing of your personal information (which is processed on the grounds of legitimate
interests);
c. To opt out of marketing communications;
d. You can withdraw your consent to the processing of Personal Data at any time. Withdrawing your consent
will
not affect the lawfulness of any processing ELEMENT conducted prior to your withdrawal, nor will it affect
the
processing of your personal information conducted pursuant to lawful processing grounds other than consent;
e. You have the right to file a complaint with a data protection authority about our collection and use of
your
personal information;
f. Other rights provided for in this Privacy Policy and applicable law.
12. TRACKING DATA AND COOKIES
ELEMENT and ELEMENT’s partners such as marketing and analytics partners may use “Cookies,” which are text
files
placed on the computers of users of the Games and Website to help ELEMENT analyze how users use the Games
and
Website, and similar technologies (e.g. web beacons, pixels, ad tags, and device identifiers) to recognize
the
use of the Games and Website across different devices and ELEMENT services, as well as to improve ELEMENT
services and marketing, analytics, or Website functionality. The use of Cookies is standard on the internet.
Although most web browsers automatically accept cookies, the decision to accept them rests with users of the
Games and Website. Users of the Games and Website may adjust their browser settings to prevent the reception
of
cookies or to provide notification whenever a cookie is sent to users of the Games and Website.
Website traffic volume and information pertaining to the Games such as the number of visitors to a given
Game or
Website on a daily basis is typically referred to as “Tracking Data.” This type of indirectly-collected
information is gathered through various means such as an IP address, which is a number that is automatically
assigned to the computers of users of the Games and Website whenever users of the Games and Website use
online
resources. Web servers, the computers that “serve up” web pages, automatically identify computers by their
IP
addresses. When users of the Games and Website visit any website or server, ELEMENT logs the computer’s IP
address.
All information is collected when users of the Games and Website provide Personal Data within the framework
of
the Games and Website and is collected only on an anonymous basis.
ELEMENT reserves the right to modify this Privacy Policy statement at any time, so please review it
frequently.
DATED: April 22th, 2019
UPDATED: March 22th, 2022