PRIVACY POLICY

1. INTRODUCTION

The terms of this Privacy Policy govern the relationship between you and Kindzasoft LLC (hereinafter "Developer", “we", "us", “our”) - the “Data Controller”, publisher and developer of the mobile applications as described in Terms of Service.

This Privacy Policy applies whenever you use our “Services”, which means playing our mobile games or using our websites hosted on “pyramids-pool.com” domain. It describes how we collect, use and process your personal data.

Do not use our Services and do not play our games if you don’t want us to process your personal data as described below.

2. WHAT DATA WE COLLECT AND WHAT IT IS USED FOR

Technical information - We collect different technical information including IP address, Mac address, device hardware ID, date and time of access, device name, application version, OS language, device resolution - we collect this data whenever you connect to our game servers. Our games cannot operate without this data. We need it to provide you with the Service, create your game account, authorize you later and make your game experience more comfortable. Also we need it to prevent possible fraud.

Social network ID, social network access tokens - if you want to link your game account to one of your social network accounts you can choose this option. It will prevent you from losing control over your game account. In this case you provide us with your social network account ID and access token so we can verify that you are eligible to login via this social network account. We assume that you provide the consent when you click the “Link account” button in the game menu and then login to the chosen social network.

Currently available social networks: Google Play Games (for Android), GameCenter (for iOS), Facebook, Vkontakte,

After we link your game account with your social network account we anonymize this personal data and only then store it in our database for further authentication.

Nickname, Avatar - if you want you can customize your game profile with a custom nickname or with custom avatar image. We assume that you give us consent to process and collect this data when you enter this information in your game profile menu.

This information is publicly available for everyone. You can modify it or delete it the same way you entered it.

Please note that this information is subject to moderation and it can be deleted, modified or rejected at our discretion.

We can process this data to third-party services for moderation purposes.

We also can keep this data in certain situations to fulfill our legal obligations or protect possible fraud.

Game chat, club chat - this is the messages that you send to other players when you play the game. We assume that you give us consent to process and collect this data when you enter and send messages via game interface.

This information is publicly available for everyone.

Please note that this information is subject to moderation and it can be deleted, modified or rejected at our discretion.

We can process this data to third-party services for moderation purposes.

We also can keep this data in certain situations to fulfill our legal obligations or protect possible fraud.

Club name, club description - you can create your own club in game and give it custom name and description. We assume that you give us consent to process and collect this data when you enter this information in game.

This information is publicly available for everyone.

Please note that this information is subject to moderation and it can be deleted, modified or rejected at our discretion.

We can process this data to third-party services for moderation purposes.

We also can keep this data in certain situations to meet our legal obligations.

Purchase history, purchase receipts - we collect this information when you make a purchase in game. We need it to provide the Service and prevent possible fraud.

Push notification token - we need it to send you push notifications. You will be asked for it and we will collect this data only if you give us your consent. You always can withdraw consent via operating system settings.

Advertising identifiers - this identifier may be provided by default by the operating system or we may ask you for it clearly. It is used to show you personalized ads. Anyway, it will not be somehow used until you give us your consent to use it. In case when we want to use it you will see the consent window. Also you can always withdraw your consent via game settings menu or reset this identifier via operating system. We don’t use this identifier by ourselves but we provide it to third parties. This process is described in details in this document below.

Logging of all in-game actions and events - we log events that naturally occur during the game process. This may also include in-game actions, played games records, crash reports, performance issues. We need it to improve your game experience, provide you with the support in case when you need it and to prevent possible fraud.

3. LEGAL BASES FOR PROCESSING YOUR DATA

There are several legal bases for processing your data:

1. Performance of the contract with you - there’re many cases when we need the data to provide you the Service. These cases include (but not limited to) creating of the game account, keeping your game account safe, providing you with better game experience, providing communication and interaction with other players, providing the support, managing purchases, etc.

2. Your consent - we can process certain data only if you have provided your consent for a specific purpose. For example we can ask you to provide your consent to use an advertising id to show you personalized ads. Or we can ask you if you want to receive push notifications. You always can withdraw your consent in all of these cases.

3. Compliance with legal obligations to which we are subject - in some cases we process certain data to comply with legal obligations.

4. Legitimate interests - in some cases we process your data for our legitimate interests. For example, to analyze and improve the Service provided to you.

4. PERSONAL DATA WE COLLECT FROM THIRD PARTIES

Social networks and login methods - if you choose to link your game account to your social account via third-party social networks (Google Play Game, GameCenter, Facebook, Vkontakte) then we’ll receive data from these services necessary to authenticate you. Usually it includes some kind of account id or login token. Please note that we anonymize this data before we store it on our servers.

Payment data - when you make an in-app purchase, the transaction will be processed by a third-party payment provider and it will be subject to third-party payment providers privacy policy. In this case we receive only general data about payment status, payment data/time and necessary data to make sure that payment is valid. We don’t receive any specific financial information like credit/debit card information, your credentials or payment method.

5. EXTERNAL ADVERTISING COMPANIES

We show ads from many advertising companies. They will show you personalized ads only if we have a consent from you for that purpose. You will be asked for it clearly in that case. You always can withdraw your consent in the game settings menu or in your operating system setting. Below you can find the list of advertising companies whose ads we show in our games and links on their privacy policies. You have to contact these companies directly If you want to exercise your rights in relation to personal data you provide to them.

AdMob (Google)

https://policies.google.com/technologies/partner-sites

Appodeal

https://appodeal.com/privacy-policy/

Unity Ads

https://unity3d.com/legal/privacy-policy

TapJoy

https://www.tapjoy.com/legal/#privacy-policy

Applovin

https://www.applovin.com/privacy/

MyTarget

https://legal.my.com/us/mytarget/privacy/

6. ANALYTICS

We use Firebase Analytics and Flurry analytics in our games. Only anonymized data is processed to them. You can find their privacy policies below.

Firebase

https://policies.google.com/privacy

Flurry

https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/index.html

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA

We can share your personal data with third-party services when it is necessary to provide you with the Service. These cases include (but not limited to) services of hosting providers, content delivery providers, support services, moderation services, etc. In all those cases your data is processed in compliance with applicable data protection laws.

We can disclose information to public authorities, law enforcement agencies or other judicial entities if we are legally required to do so or if it is reasonably necessary  to comply with our legal obligations.

We may also disclose your personal data in case of any reorganization, merger, join venture, sale, transfer or other disposition of our business (fully or partially).

8. LOCATION AND SECURITY OF YOUR DATA

We store all your personal data on our servers and we use appropriate security measures to keep your data safe. All data transfers are protected by appropriate safeguards. Only authorized persons have access to our servers. We constantly monitor our system condition to prevent any loss, misuse or unauthorized alteration of the data.

9. HOW LONG WE KEEP YOUR DATA

Most of the data is stored as long as you use our Service. We assume that you have stopped using our Service if you have not used it for 180  consecutive days. Then we may delete your personal data (including Game Account) except for those that we need to comply with our legal obligations and meet our legitimate interests. Please note that in this case you can lose access to your Game Account.

Any public information you have shared with others (such as chat messages and other User Generated Content) will remain publicly available in the system.

10. YOUR RIGHTS

You have following rights in relation to your personal data:

• Request access to your personal data
• Request correction of your personal data
• Request the deletion of your personal data
• Withdraw your consent if your personal data is processed with your consent

You can exercise your rights by sending a request to support@kindzasoft.com. We will process and answer your request without undue delay and usually it won’t take more than one month unless a longer period is required due to the complexity of the request. We may ask you to provide additional information so we can determine which data is yours and to prevent disclosure of your personal data to others. If you request us to delete or correct your personal data, we may retain part of it to comply with legal obligations.

11. CHILDREN

We do not knowingly collect personal data from anyone under the age of 18. Parents or guardians who suspect that we hold information about their children who are under the age of 18 may contact us at support@kindzasoft.com.

12. HOW OFTEN DO WE UPDATE PRIVACY POLICY

This Privacy Policy is subject to change and we may make any changes to it when we need it - it will be published in our Services. If you continue to use our Service then it means that you agree with the changes.

12. CONTACT US

If you have any questions or complaints you always can contact us at:

Armenia, 0051, Yerevan, Hrachya Kochar 44/53

Or by email:

support@kindzasoft.com

Effective Date: April 17, 2022