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    PRIVACY POLICY: 25.05.2018

    LAST UPDATE: 09.12.2024

    DIGITAL MELODY PRIVACY POLICY

    This privacy policy is a document that describes how Digital Melody collects, processes, shares, stores, transmits and discloses both personal data and data generated in applications and games.

    Digital Melody, including its affiliates and subsidiaries, is the controller of the data it collects and processes for the purpose of creating and developing games, applications, websites and services. All mechanisms, practices and data management principles are governed by this document and are in compliance with it.

    By using any of Digital Melody services, games, applications, websites and other services, you hereby consent to this Privacy Policy created on 25.05.2018 and modified on 23.05.2022.

    If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please see the “Contact” section at the end of this document.

    1. Information we collect

    Information you provide us:

    • Your name and email address 
    • Your age
    • All the information you provide contacting us via all support tools (e-mail, forms, support tickets etc.)
    • Other information you provide us (via sending us emails, inquiries, requests by any of provided by Digital Melody tools)

    Information collected automatically :

    Whether by our partners or directly by google services as well as in game scripts, these are the main data that may be processed by Digital Melody:

    • General geolocation information (for example country, country region or continent).
    • Game related progress and activity, your interactions with other players, Digital Melody player ID
    • Data we collect by using cookies and similar technologies (stated in cookies policy)

    Information collected from our partners:

    • Information that we receive if you decide to connect to a third-party social network (such as Facebook or Game Center)
    • Information from billing partners (if you subscribe to some games or make an in-game purchase)
    • Information for advertising and analytics purposes, so we can provide you with better Services
    • NET address, device identifiers, browser preferences (such as IP, your device ID, advertising ID, MAC address, IMEI, device name and operating system, browser type and the language you prefer) if needed for the case.

    Digital Melody collects only adequate and relevant information limited to the purposes defined in this document.

    Informations collected by our partners:

    All informations collected by our partners are stated in their privacy policies:

    2. When we collect your information

    Digital Melody collect information when you:

    • play our games and consent to use our services
    • watch advertisements within our services
    • make a purchase by our partner services
    • sign up for a newsletter
    • contact Digital Melody customer service 
    • share or contribute to our social-media channels and other community websites
    • apply for: participation in any project, partnership, subcontracting and for a job

     We collect personal information when:

    • when we have your consent to do so
    • when they are needed to fulfill contract with you (to identify sides of contract)
    • when they are needed to fulfill all legal obligations according to the law and to prevent crime and fraud
    • when we have a legal obligation to collect personal information from you

    3. How do we use your information

    • We use the information to provide you with a better gaming experience and to properly operate our business with reference to the law where the service is provided. That means we use this information:
    • to match the Services to your age according to the applicable laws of your country of residence
    • enhance game experience based on your behavior in game and feedback you provide
    • deliver ads and offers to you for a services that you may like
    • to offer you the opportunity to take part alfa and beta testing of our services
    • to fix bugs and service errors and use of exploits and cheats in games and services
    • to prevent and protect against crime or fraud and other security manners
    • to make valid analytics, statistics and optimization in games and services
    • to comply with all regulatory and legal requirements, and answer any requests from Data Protection Authorities or any law-enforcement agency
    • to provide support and communication and to respond to any requests or questions you have submitted through our customer support
    • handle your subscription to, and opting-out of, our policies and newsletters
    • to promote our services
    • provide advertising that may match your interests in comply with age and general localization
    • to measure our efforts and effectiveness of advertising and offers and to optimize them
    • to conduct push notification if we have your consent
    • to use and perform analytics that enhance business operation that leads to optimize services

    4. How long do we retain your data?

    As long as you are playing our games and use our services, adding the period needed to fulfill all the purposes stated in this document, in compliance with the applicable laws of your country of residence. In addition, your data can be retained to solve any future disputes, police requests and to fulfill legal obligations until those disputes, requests and obligations are closed.

    5. How we share your information

    Internally:

    In order to operate the Services, your personal information may be transferred to other Digital Melody studios or entities, subsidiaries, processors, partners or third parties operating on behalf of Digital Melody.

    With authorities

    We are obligated to report to law enforcement agencies any activity that we believe in good faith is illegal. In case of suspicion, we will investigate and take action to counter any kind of possible abuse in order to protect property or the safety of others. Your data may be disclosed to the authorities on the basis of legal provisions or a court order, if the suspicions turn out to be justified, especially if they threaten harmful behavior. The scale of the data we share is always adequate to factual needs and comply with the local law.

    Social networks:

    If you decide, while using our Services, to use social sharing features such as “Share” or “Like” on Facebook or other third-party social network sites, this may allow for personal and non-personal data collection by third-party social networks you share data to. Digital Melody may have access to this data due to your consent to contracts provided by those entities. You should visit the policies of such third parties for more information about their information-collection practices.

    In case of sale of our company

    In connection with any sale of our company or any line of business (including the assets) customer information generally is one of the transferred business assets. In the event of any such sale or disposition of any or all of our business, your information may be transferred to the acquirer.

    6. International operations and transfers of your information

    If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland based on the standard contractual clauses authorized by the European Commission or other appropriate safeguards defined in Article 46, General Data Protection Regulation (GDPR) (EU) 2016/679.

    7. Security and confidentiality of your personal information

    The security measures that we have implemented and that we have at our disposal have been introduced to protect data and prevent unauthorized access.

    However, please note that no data transmission over the Internet or any wireless network is 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of your information and accept no responsibility for any unauthorized use of or access to your information under our control.

    Each time in the event of a breach of the security of your data, you will be informed by us.

    If you believe that your personal data is being misused by us or any third party, please notify us immediately by email at [email protected].

    8. Children

    We encourage parents and legal guardians to educate their children about the dangers of sharing their own, any family member and friends personal data over the Internet. No child should disclose any personal data and other sensitive data, especially any payment data, wherever they belong to.

    The user is considered a child if he or she is less than 13 years old and lives outside the European Union. If a user lives in the EU, and has less than 16 years, he or she is considered as a child, unless the data protection laws applicable to his or her place of residence provides otherwise.

    If any of our age-appropriate services are or may be used by an age-inappropriate user, we reserve the right to block such service for that user.

    We apply the above and following limitations to personal information collection for a user that is not of the minimum legal age required in their country of residence.

    If you do not have proper age, you cannot:

    • subscribe to newsletters
    • display your real name or any information in the games
    • access the chats, leaderboards, forums, SNS (Facebook, Game Center, etc.)
    • use any other feature where users could appear under their real names

    With respect to such a user, we will prevent the collection and use of his/her precise geolocation data and display to him/her contextual advertising only (excluding any behavioral advertising).

    If a user has consent of their legal guardians or parents to use services not suitable for his age, parents and legal guardians have to exercise their privacy rights for their children, if law of the country of residence allows it. Digital Melody due to its strong recommendations and statements will oppose such actions but will always comply with the law. You can use this e-mail to submit your case: [email protected]

    9. Job applicants, partnership, subcontracting

    If you apply for a participation in any project, partnership, subcontracting and for a job, your personal data can be collected for the recruitment process and retained only for recruitment purposes for a period when the recruitment process is finished. Depending on the result, your information data can be stored for a time of cooperation and any legal requirements arising due to it or deleted shortly after denial, if we do not have your consent to do otherwise.

    10. Your rights as an Adult and Parent / Legal Guardian

    Adults

    We encourage the data provided to Digital Melody to be kept up-to-date and accurate. By using our services, you ensure that the data provided by you belongs exclusively to you and not to third parties.

    You can ask Digital Melody to access, correct, add or delete data at any time. If you are a European user, you can also request limitations to the processing of your personal information, object to the processing of your information, or exercise your right to data portability.

    If you subscribed to the newsletter or agreed to cookie-based tracking, you can opt out at any time by unsubscribing from the newsletter or deleting cookies on your web browser or smartphone.

    If you do not agree to some cookies, you can withdraw your consent in their settings (if allowed by the website or application) or not use our services if the permission level is inadequate for you.

    Please note that your actions may affect the functionality and availability of services and games. Withdrawal of certain consents may limit or prevent entertainment altogether. Removing consents or limiting them can cause game or application reset and / or their functionality may be limited. In extreme cases, games and applications may remain inaccessible to you if the consent conditions their work and make them fully functional. In addition, when withdrawing consent, communication with us may be difficult, especially if the contact details have been blocked.

    If you withdraw your consent or request the deletion of your data, we will no longer use or process your data, but will keep it in order to respond to requests from regulatory authorities or the police.

    We also reserve the right to archive such information for a commercially reasonable period to ensure that its deletion does not affect the integrity of our data; in addition, we reserve the right to keep an anonymous version of such information.

    Children

    If you are the parent of a child under the age of 13 (or any other age under the laws of your country) and you believe your child may have provided information to us, you can complete the form so that we can check and delete the information from our system.

    In order to correctly identify you as a parent or legal guardian and to enable access to data, we will need to identify you. Therefore, we need you to provide us with a copy of an official document proving your identity and the fact that you are the child's parent or legal guardian. This copy will be safely destroyed within two months of receiving and closing the request.

    Your request will be processed within one month, unless it requires further investigation. You will be informed about this fact.

    European users are reminded that they have the right to lodge a complaint with the European Data Protection Supervisor.

    11. Third-party services

    Some of our services may contain links to third party services that provide us with the modules, software and services that we use for our games and applications.

    These links may lead to websites and services beyond our control and influence.

    This Privacy Policy covers only how we handle personal and non-personal information that we collect as part of our Services. By accessing any external sites, you agree to the privacy policies of those sites and services, which may have different policies regarding the collection, use and disclosure of personal information.

    As noted, being out of control, we are not responsible for the privacy practices, actions, omissions and policies of such third parties and their services. We encourage you to read the privacy policy of the websites and services you are accessing.

    12. Changes to our Privacy Policy

    We reserve the right to change our privacy policy at any time. This change will be updated both on our website: www.digitalmelody.eu/privacy and in the applications and games that use it. Therefore, please read this document from time to time to be aware of the current Digital Melody Privacy Policy.

    The policy update date will always be at the top of the document.

    By continuing to use the services you accept the changes.  If you do not accept the changes, you may choose not to use Digital Melody services. You can also send us a consent withdrawal notice via this e-mail: [email protected]

    13. Legal disclaimer

    Our Services operate AS IS, and we do not represent or warrant that our Services will be available at all times. We also cannot guarantee that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for anything beyond our control. This Privacy Policy is governed by the laws of your country of residence. Any disputes arising from the use of the Services will be brought to the appropriate courts in your country of residence.

    14. Contact

    In case of questions, requests, doubts or applications, you can always contact us by e-mail: [email protected]

    Digital Melody S.A.
    Ul. 3 Maja 9
    05-827 Grodzisk Mazowiecki
    Polska