Privacy Policy

This personal information privacy policy (hereinafter – Policy) applies to all information that “IVERIN GAMES” and/or its affiliates may obtain from and about the user through his/her use of any of “IVERIN GAMES”’s Applications.

Terms “IVERIN GAMES”, “we”, “us”, “our” or “ours” used in this Privacy Policy refer to Company “IVERIN GAMES”.

This Privacy Policy sets out how we collect, use, disclose, transfer, and store information about you and/or information about your computing device received through your use of the Applications.

In addition, this Privacy Policy defines the rules for the use of third-party services in all the applications published under the brand name “IVERIN GAMES” (hereinafter – Application or Applications) that may run on a computing device of any type (including a mobile device), and your use of the Application.

By using our Applications, you explicitly consent to the collection, use, and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may obtain and/or request your information (including personal information) at any time when you are in contact with us or use our Applications. We may share this information (including personal information) with our affiliates or partners (as defined below) and use it in accordance with this Policy, as described in greater detail below. In addition, we may use your information (including personal data), together with other information, to provide and improve services, products, content, and advertising.

If you have any questions regarding this Privacy Policy, you can contact us at admin@iverin.ru.

Interest-based Advertising

We advertise our Applications and services in our own applications and in the applications of other publishers. We similarly help our partners to advertise their products and services in our Applications. We may share the information we obtain from you with our advertising partners who may use this information to display targeted advertisements. We and our advertising partners display targeted advertisements or advertisements of interest (hereinafter – advertisements) that do not violate the COPPA Rule for Applications published in family and “Applications for kids” categories in Google Play and Apple Store. By using our Applications and by not refusing to watch advertisements, you consent to the transfer of your data as specified below.

We may transfer the data obtained from you, including technical information, information about advertising and the use of applications, as well as information regarding age and gender to our advertising partners who may use these data to display targeted advertising. We authorize our partners to display targeted third-party advertisements and other content. Our partners may combine the information collected through our Applications with the information collected through other applications, websites, and services. This information may be used to create user profiles and transferred to other providers. Advertisers may target the audience according to the following criteria: location, demographics, previous likes, keywords, age and gender, interests, behavior, connections, and other information that is obtained or inferred in relation to the user. We collaborate with several advertising aggregation companies, as follows:

Information We Collect

1. Technical information and data
We collect technical data that your device requires to use our Applications. We also collect additional technical data necessary to maintain and analyze the Application’s functionality, personalize the Application content, and to display contextual advertising.

We obtain some information about your device automatically. This information includes:

  • IP address and country code;
  • IDFA and IDFV numbers and other advertising identifiers;
  • language and locale (a specific location where this language is used);
  • time zone, session start and end time;
  • connection status (Wi-Fi, etc.), browser extension types and versions;
  • user agent string (UA), platform, SDK version, and time stamp;
  • all installed applications;
  • technical information about the device (for example, device make and model, operating system name and version, information about the CPU, disk space available, display resolution, firmware, software, mobile service provider, Internet service provider, application API key, International Mobile Equipment Identity (IMEI) for Android, Android ID, Android serial number);
  • push notifications token;
  • player identification string (we extract the identification strings only after the user logs in to Google Play Games or Apple Game Center).
    In addition, we create unique user identifiers for users with Android devices and we use IDFV to track users’ activities within our Applications on iOS devices.


2. Advertising And Application Usage Information And Data

When you use our Applications, we may collect additional information with the help of identifiers able to identify your device. This information is used for advertising and analytics purposes and includes:

  • information about the advertisements displayed;
  • the length of time that an advertisement is in view and its size;
  • advertisement response (if any), including clicks on the advertisement;
  • angle of view;
  • Application usage information (Application usage frequency and session length, activities within the Application, location in the Application, in-app purchases and their cost, general usage data, performance data, customer lifetime value, etc.).

3. Personal Information

Our Applications do not collect your personal information, except for the persistent identifiers (such as IDFA, IDFV, Advertising ID, or IP address). The persistent identifiers are able to uniquely identify your device, but they do not identify you personally. In some jurisdictions (for example, in the USA), the device identifying information is considered personal information.

When you initiate a direct contact with us, we may collect your personally identifying information you provide us with, for example, your first and last names and email address. We use such contact information only for the purposes you provide us with it for. We do not share such information with third parties.

How We Use The Information Obtained

General provisions

We use information about you and about your computing device to deliver services to you and to operate our business. Such uses by us and by our Partners may include, but are not limited to:

  • Delivery of our services: development, delivery and improvement of our products, services and content, adaptation of our products and services, updates and support availability, analysis and understanding of Application usage trends, Application management and customer service.
  • Advertising: we may display third-party advertisements in our Applications or we may display our Applications advertisements in the applications of other publishers.
  • Joint promotion of our Applications and services: we may display an advertisement of one of our Applications while you are using another one.
  • Research and analysis: to analyze and understand the Application usage trends, we may collect demographic information about our users and information about the location where the Application was downloaded. In addition, we may generate and analyze reports for the purpose of research and business analytics, for example to keep track of potential problems or trends in our Applications and services, as well as to test new game features and content. The data obtained from third-party social networks are used exclusively for internal analytics.

Push Notifications

We use push notifications to remind you about your activities in the Application. You will receive push notifications only if you subscribe to them in the Application. To disable push notifications, follow the instructions below:

  • For iOS: after downloading the Application, you will have to allow or deny push notifications. If you choose “deny”, you will not receive push notifications. If you choose “allow”, you will be able to block them later if your device has such an option in the settings. You can manage the push notifications on your mobile device by following these steps: Open the settings, tap “Notifications”. Find “Applications”. Tap the Application icon. Enable or disable the notifications by moving the switch to the “on” or “off” position.
  • For Android, after downloading the Application, you will automatically receive push notifications. To manage push notifications, you will have to open the information screen on the main page of the Application and choose “Settings”. You can disable the push notifications by ticking them off inside the Application.

We collect push notification tokens to determine if you have subscribed to push notifications. When you decide to unsubscribe from push notifications, the push notification tokens will be deleted from our database.

Information Disclosure to Third Parties

We do not have enough resources to deliver all the services necessary for the successful functioning of the Applications by ourselves. For this reason, we are forced to share the information we collect with third parties, including advertising providers, analytics and tracking services, or any other third-party services that ensure proper functioning of the Applications (hereinafter – Partners). We may share information that may be used for personal identification of your computing device (for example, with the help of such persistent identifiers as IDFA, IDFV, advertising ID, and IP address) in order to provide services, display advertisements, conduct analysis and research, as well as to measure the effectiveness of our and our Partners’ advertising campaigns. We may share such information with the following persons and entities:

  • Our analytics providers: in some Applications, we use third-party analytics tools, such as:

Their use is necessary to provide our services and to conduct research and analysis. To find out in detail how your data are collected and processed, you can visit the web page of any of these services.

In addition, we have integrated Google Play Developer Console data, such as impressions, downloads, and traffic sources into our Google Analytics account to see how many times people viewed or downloaded our Applications from Google Play. The data that we share with such providers are encrypted. A provider may assign a random number to each record in such data set, by which it is impossible to identify you. Third-party analytics providers have the right to process data in accordance with their privacy policies (https://policies.google.com/privacy?hl=en#nosharing ). Such data may be published in aggregate form to demonstrate their services usage trends, as well as for marketing and advertising purposes. We may aggregate data for benchmarking purposes.

  • Third-party Advertising Partners:  we have contracted with certain third-party advertising networks that help us to display advertisements to our Applications users. This allows us to provide our users with free or available for a small price Applications.
  • Third-party tracking service providers of our advertising partners: in some Applications, we allow our advertising partners to track the number of impressions, clicks on advertisements, downloads, and other indicators that measure the effectiveness of the advertising campaign by using tracking services delivered by their partners.
  • Other third-party service providers: some of the Applications were developed with the help of Unity software. Detailed information on how Unity processes data is available in the privacy policy at https://unity3d.com/legal/privacy-policy.

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications.

We reserve the right to disclose your information (including personally identifiable information) within the framework of the law, legal action, and/or upon request of public authorities within or outside your country of residence. We may also disclose your information if we consider that it is necessary for national security, law enforcement, or for other socially important purposes. We may also disclose your information if we consider that it is necessary to comply with our service terms, to protect our business or our users, or to ensure service delivery to our users. In addition, in the event of a reorganization, merger, or sale we may transfer any or all personal information we collect (including personally identifiable information) to the relevant third party.

Advertising

When you use our Applications, we may display contextual advertising to you. In order to ensure advertising, we allow our partners to collect electronic identifiers (such as Advertising ID on Android and IDFA on iOS), which in some jurisdictions may be considered personal information. Our partners are obliged to use such data solely for the purpose of contextual advertising. For all other purposes, they must use anonymous and aggregate data.

In some locations, we may use (or transfer to our advertising partners) technical information and the information about advertising and the use of Applications that we obtain from you, so that our partners could display, target, and optimize third-party advertisements in our Applications. This is necessary to ensure that the advertisements you see are based on your application and device usage, online behavior and interests. In addition, we may use such information and transfer it to our advertising partners for the purposes of targeting and optimization of our advertisements and special offers in our Applications and in the applications of other publishers.

Tracking

When you use our Applications, we and third-party advertising providers may use the information collected from your device using cookie files, “Web beacons”, and other technologies to display relevant advertisements within the Application and to count unique and duplicate advertisement impressions.

We use tracking and data collection tools of our service providers in order to measure the effectiveness of our advertisements and to optimize our advertising campaigns. We also conduct analysis to improve our services and to prevent fraudulent activities. Such tools may use cookie files, API, and SDK in our Applications to collect and analyze information and data related to the user and device. This information may include: number of advertisement impressions, number of clicks on advertisements, downloads, and other indicators of advertising campaign effectiveness, as well as the actions performed within the application after downloading.

Additionally, our Partners may use their own technologies (including, but not limited to, cookie files, “Web beacons”, HTTP cache, LSO files, and other technologies) to track the number of impressions, clicks on advertisements, downloads, and other indicators of advertising campaign effectiveness in order to assess the effectiveness of third-party advertising campaigns.

Third-party Social Networks

Some of our Applications use third-party services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, or Vkontakte (hereinafter – Third-party social networks). Such applications allow our users to log in to a third-party social network account to establish a connection with our Application by using the “Log in with” or “Connect to” option of our Application. Users can also share the content created within the Application with Third-party social network users. By logging in to a Third-party social network to connect to our Application or by using our Application to share content in a Third-party social network, you authorize us to collect, store, and use any information (in accordance with this Privacy Policy) that, with your consent, Third-party social networks can share with us through the Application Programming Interface (API). You accept these conditions when you “permit” or “allow” (or perform a similar action) one of our Applications to connect to such a Third-party social network. The available to us information differs from Application to Application and depends on the privacy settings of your and your friends’ accounts in the Third-party social networks. You can learn more about and manage your privacy settings in the corresponding Third-party social network. Note that the use of Third-party social networks is defined by their own privacy policies, terms of use, and end-user agreements. We are not responsible for and have no control over their data-sharing policy and practice.

Third-party Service Terms

Note that the access to and use of the Application may fall under the scope of the terms of service and privacy policies of third-party services, including app stores, mobile program platforms, online games platforms, social networks, statistics and payment services. By using our Applications, you confirm that you understand and accept that “IVERIN GAMES” is not responsible for such third-party terms of service and for how they handle your personal information.

Children’s Privacy

We believe that our company policy is focused on the entire family, but we have voluntarily decided to adhere to an elevated standard of children protection. Although our products and services are not directed at children under the age of 13, we deliberately do not collect their personal information, with the only exception being made for the above mentioned persistent identifiers. If we find out that we have collected personal information, with the exception of the persistent identifiers, from a child under the age of 13, we will take all reasonable measures to promptly erase such information from our records. If you find out that your child has provided us with his/her personal data without your consent, please, contact us at  admin@iverin.ru.

To preserve the reputation of Family Applications, we have introduced an age restriction for certain features in our Applications, so that children under the age of 13 could not use them. To protect our younger users and to ensure their confidentiality, the age restriction is activated for individual countries and in some of our Applications after downloading. The functions that have the potential to collect and share user’s personal data (with the exception of the persistent identifiers) will be disabled for the device IDs of the users who do not meet the age restriction. To ensure our users’ safety, it is impossible to change later the age indicated in the user profile at the moment of registration. If a user is under the age of 13, we do not store information about their actual age in our Applications, we only record that the user does not meet the age restriction.

The only personal data necessary for the delivery of our services we collect from the users who indicated to be under the age of 13 are the persistent identifiers (such as the device ID, IDFA, IDFV, advertising ID, and IP address). Such persistent identifiers are used and disclosed to third parties solely for the purpose of maintaining internal operations necessary for contextual advertising (including frequency capping), user authentication, or Applications content personalization (for example, push notifications). Other purposes may include: to maintain the Applications and analyze their functionality, to establish network communications in order to protect the security and integrity of user data, as well as to meet safety standards or regulations.

Using persistent identifiers does not imply contacting users under the age of 13, displaying to them behavioral advertising, or using their data for tracking and profiling. We strive that all of our advertising partners adhere to the same standards for the collection, usage, and disclosure of children’s personal information as we do, but we cannot be responsible if they breach the commitments they gave to us regarding the collection of information. By using our Applications, you accept that our liability for such breaches is limited to the amount we are able to receive as indemnification from our Partners. You can find detailed information on how your data are disclosed to third parties in the Information Disclosure to Third Parties section of this Policy.

We will send push notifications only to those users who have authorized us to do so, in order to motivate them to restart using the Application. You can unsubscribe from the push notifications following the instructions in the Push notifications section of this Policy. We strive to make the notifications content relevant for the whole family. Push notifications are context sensitive and depend on the language. They are sent only within the Application and not from a server or with other user information.

In-app Purchases

In our Applications, there is an in-app purchase option. We do not process payments for purchases inside the application and do not have access to your payment details. The in-app purchases are made through your account in the app store. All post-purchase actions fall under the responsibility of the app store and are regulated by its Terms and Conditions.

Other Confidentiality Provisions

In some of our Applications, you can fully interact with your friends on Facebook after you log in to your Facebook account. By connecting to Facebook, you authorize the Application to access your public profile and your friends list. If you do not want to share the list of your friends with the Application, you should tick off the corresponding option when logging in to Facebook through the Application. If you log in to the Application through your Facebook account, the Application will display your public profile to your Facebook friends.

Some of our Applications have Single player and Multiplayer options. In the Multiplayer mode, you can participate in matches with random players or with your Facebook friends. If you log in to the Application through your Facebook account, in the Multiplayer mode with a Facebook friend or with a random player, the Application will display your public profile.

Questions About The Privacy Policy

If you have any questions or suggestions regarding this Privacy Policy or information processing, please, contact us at  admin@iverin.ru.

Version dated April 6, 2021.