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Privacy policy

Last updated: June 22nd, 2022

  1. WHO WE ARE

1.1. https://advgo42.com/ (the “Website”) and Services (as defined below) are provided by ADVGO42
LTD, located at Irodi Attikou, 8A Lakatamia, 2332, Nicosia, Cyprus (“Company”, “we”, “our” or “us”) and
our subsidiaries.

1.2. This Privacy Policy shall be read alongside, and in addition to, our End User Licence Agreement
accessible online at https://advgo42.com/doc/eula.pdf (the “EULA”) and our Cookie Policy accessible
online at https://advgo42.com/doc/cookie.pdf (the “Cookie Policy”).

1.3. This Privacy Policy sets out how we collect and use your personal information when you (i) use the
services offered by the Company and its subsidiaries by visiting our website; (ii) use games and the
Website as defined in the Terms; and (iii) registering an account, if any, (an “Account”) and use the mobile,
online, and downloadable products, including, games and services (the “Services”) offered by the
Company and its subsidiaries on the Website and the choices available to you in connection with our use
of your personal information (the “Privacy Policy”).

1.4. It is reminded that information collected via the Services offered by the Company and its subsidiaries
is used by the Company, responsible for its processing.

1.5. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

1.6. Please note that if you use other products and services that the Company suggests on the Website, or
such products and services are provided by or together with third parties, you may be required to register
“extra” accounts, and in that case additional privacy policies shall be applied and accepted by you.

  1. THIS PRIVACY POLICY

2.1. By making the Services available, we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register an Account, and use the Services;
(b) provide true information about yourself to the extent necessary for the use of the Services;
(c) understand that, by posting your personal information, if there is such a technical possibility in the
Services, and where it is accessible by other users of the Services, you have manifestly made this
information public, and this information may become available to other Website users and Internet users,
be copied, and be disseminated by them;
(d) understand that some types of information transferred by you to other Service users cannot be
deleted by you or by us;
(e) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such a check is necessary in
order for us to fulfill our obligations to you.

  1. INFORMATION WE COLLECT ABOUT YOU

3.1. In order to implement the agreement between you and us, and provide you with access to the use of
the Services, we will improve, develop, and implement new features of our Services, and enhance the
functionality of the available Services. To achieve these objectives, and in compliance with applicable
laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data
(hereinafter “processing”). We will also receive and pass this data, and our automatically processed
analyses of this data, to our affiliates and partners as set out in the table below and in section 4 of this
Privacy Policy.

3.2. We set out in more detail the information we collect when you use our games, why we collect and
process it, and the legal basis below.

3.3. General clauses, which shall apply to your use of the Website and the Services related to the
Company:

Cookie Information CollectedPurposeLegal Basis
1Data you provide for registering in
the Services, including your e-mail
and/or other identifiers available
We use this information in order to
manage and administer the Services
provided to you.
We use this data to enable us to
fulfill our obligations to you as part
of the Services (e.g. in cases where
you request restoration of your
Account).
See section 8.3 of this Privacy Policy
for more information.
We also use this information in
order to provide you with updates
and information on our and selected
third parties’ products and services
we think you may be interested in.
Legitimate
interests
Performance of
our contract
with you
Consent
2Additional data you provide when
you create or edit your Account or
other related pages, including your
first name and surname, nickname,
gender, date of birth, avatar
picture, and language preferences.
We use this information in order to
provide our Services to you, to
manage and administer Services,
and as additional information to
verify your Account to prevent
abuse and infringement of your or
other persons’ rights.
We also use this information in
order to provide you with updates
and information on our and selected
third parties’ products and services
we think you may be interested in.
We use this information in order to
tailor and improve the
advertisements that may be
presented on the Website and in
our other products and services that
you may choose to use, and to
measure the effectiveness of these
advertisements.
Legitimate
interests
Performance of
our contract
with you
Consent
3Additional data received when you
access the Services, including
information regarding technical
devices, technical interaction with the Service such as your IP-address,
mac-address, time of registration in
the Service, device IDs, country and
language settings, device brand and
model and operating system used,
its version, whether it is rooted or
jailbroken or not, system
information and memory and disk
usage data, screen resolution,
screen orientation, RAM size,
Facebook ID (linked to the
application), Google Play ID (linked
to the application), Game Center id
(linked to the application), push
token, game region, timezone,
apple IDFA (if available).
We use your data for internal review
in order to constantly improve the
content of our Services and web
pages, to optimize your user experience, to understand any
errors you may encounter when
using the Services, to notify you of
changes to the Services, and to
personalise the use of our Services.
We use this information in order to
tailor and improve the
advertisements that may be
presented on the Website and in
our other products and services that
you may choose to use, and to
measure the effectiveness of these
advertisements.
Legitimate
interests Performance of
our contract
with you
4Information that is automatically
received at the time of access to
the Services with the use of
cookies.
Please see our cookies policy which
sets out the types of cookies we use
and what we use these cookies for.
We use this information in order to
tailor and improve the
advertisements that may be
presented on the Website and in
our other products and services that
you may choose to use, and to
measure the effectiveness of these
advertisements.
Consent
5Information that is created by you
while using the Services (if there is
such a technical possibility in the
Services), including information
that you post in any in-game chats.
Depending on the Services and
place of posting, this information
can be available to some or all
other users of our Services.
We use this information in order to
manage and administer the
Services, including providing our
services to you.
Legitimate
interests,
which, inter
alia, include
the processing
of data
manifestly
made public by
you, where it is
accessible by
other users of
the Services
Performance of
our contract
with you
6Information obtained as a result of
your behavioural actions when
using Services, information
obtained as a result of your use of
the payment features of Services,
information about payments (date amount, payment type, payment
status), information about goods
and services purchased (name,
amount), information about the
activation status of goods and
services purchased, including
information obtained by the
“Main” Account from your “extra”
Accounts in order to match this
data to your user Account, etc.
We use this information in order to
manage and administer the
Services, including providing our
services to you.
We use this information in order to
tailor and improve the advertisements that may be
presented on the Website and in
our other products and services that
you may choose to use, and to
measure the effectiveness of these
advertisements.
Legitimate
interests,
which, inter
alia, include
the processing
of data manifestly
made public by
you, where it is
accessible by
other users of
the Services
Performance of
our contract
with you
7Information that is created, posted,
sent or otherwise made available
by you while placing requests to
our Service Support.
We use this information in order to
verify your identity and to fulfil your
support request.
We may also use this data in order
to investigate any complaints on
your behalf and to provide you with
a more efficient service.
Legitimate
interests
Performance of
our contract
with you
8Data collected via third parties,
including your social network IDs,
application store IDs, nickname,
e-mail and friends list, when you
register in our Services via your
social or application store accounts
and/or connect your social account
to our Services (e.g. Facebook,
Twitter).
We use this information in order to
manage and administer the Services
provided to you.
We use this information for certain
social functions of our Services, such
as to show you your friends who
play the same game as you.
We also use this information in
order to provide you with updates
and information on our and selected
third parties’ products and services
we think you may be interested in.
Legitimate
interests
Performance of
our contract
with you
9Information that is received as the
result of your behavioural actions
when using the Services (including
your game actions and
achievements, badges). This
information may be available to
other users of our Services (e.g. on
leaderboards).
We use this information in order to
manage and administer the
Services, including providing our
Services to you.
We may also use this data in order
to tailor and improve the
advertisements that are presented
to you and to measure the
effectiveness of these
advertisements.
Legitimate
interest
10Information that is received about
you as the result of other users’
actions on the Services (in
particular, information posted
through in-game chats by other
users).
We use this information in order to
manage and administer the
Services, including providing our
Services to you.
We use this information in order to
verify your identity, manage, and
administer the Services, including
providing our Services to fulfil your
support request.
We may also use this data in order to investigate any complaints on
your behalf and to provide you with
a more efficient service.
Legitimate
interests
Performance of
our contract
with you
11Data obtained via third parties,
including your social network IDs,
application store IDs, social
network nickname, e-mail and
friends list, when you connect your
social account (e.g. Facebook,
Google, VK, or Apple Game Center)
to our Services.
We import this information into
your profile. We use this
information in order to manage and
administer the Services provided to
you.
We use this information for certain
social functions of our Services, such
as to show you your friends who
play the same game as you, or to
provide you with the ability to post
your achievements into your social
account.
We also use this information to
retain the data about your usage of
our Services (such as game progress
and achievements) across your
different mobile devices, which are
connected to the same social
account.
Legitimate
interests
Performance of
our contract
with you
12Information that is received as the
result of your use of the payment
functionality of the Services.
We use this information in order to
manage and administer the
Services, including providing our
Services to you.
We may also use this data in order
to investigate any complaints on
your behalf and to provide you with
a more efficient service.
Legitimate
interests
Performance of
our contract
with you

3.4. We may also undertake certain actions to prevent fraudulent activity in our Services, improve our
Services and provide you with better user experience, such as automatic collection and processing of
screenshots of your screen during the time when the game is launched and the game’s window is not
minimized to ensure users’ compliance with the Terms of Use of the relevant Service. Please be aware
that such collection and processing of the screenshots complies at any time with this Privacy Policy and no decisions are based solely on automated processing.

3.5. Our legitimate interests include (1) maintaining and administering the Services; (2) providing the
Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that
was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your
Account is adequately protected; and (6) complying with any contractual, legal, or regulatory obligations
under any applicable law.

3.6. As part of maintaining and administering the Services, we use the information to analyse user activity
and to ensure that the rules and Terms of Use of the Services are not violated.

3.7. Your personal information may also be processed if it is required by a law enforcement or regulatory
authority, body, or agency, or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required
and/or permissible under applicable/relevant law.
3.8. In case you provided us with a consent to the sending of marketing information, you may withdraw
your consent to the sending of marketing information to you by amending your privacy settings in your
Account. An option to unsubscribe will also be included in every SMS or e-mail sent to you by us or our
selected third party partners.

3.9. Please note, that if you do not want us to process sensitive and special categories of data about you
(including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical
beliefs, sex life, and/or your sexual orientation), you have to take care not to post this information or
share this data on the Website and/or Services. Once you have provided this data, it will be accessible by
other Website users and it becomes difficult for us to remove this data.

3.10. Please note, that if you withdraw your consent to data processing or you do not provide the data
that we require in order to maintain and administer the Services, you may not be able to access the
Services or register with the web pages of the Website.

3.11. If we intend to further process your data for any other purpose besides those set out in this Privacy
Policy, we shall provide you with details of these purposes before we commence data processing.

  1. DATA SHARING

4.1. Publicly available data. Your username and other information that you provide or post while using the
Services can be available to all users of the Services. We take technical and organisational measures to
ensure that your data is safe. Please note, that by posting your personal information in publicly accessible
areas (resources accessible by other users of the Services), you have manifestly made this information
public, and it may become available to other users of the Services and Internet users and be copied and/
or disseminated by such users. Please keep in mind that once other users have gained access to or copied
your data, neither you nor we are able to delete or remove such data from possession of those other
users.

4.2. Sharing with third parties. We may share your personal information with third parties only in the
ways that are described in this Privacy Policy. Sometimes we may need to provide your data to affiliated
entities, as well as our partners, in order to provide you with the Services offered by the Company and its
subsidiaries, to administer the Services, for example, if you choose to share your data across other social
media platforms, to administer the billing services or to personalize, adjust and improve our Services or in
other cases described in this Privacy Policy and only subject to the purposes described in this Privacy
Policy. We do not sell your personal information to third parties.
The transmissions of personal data with the recipients (whatever their legal status, subcontractor,
processing manager or just recipient) are carried out in a secure manner and in application of an
agreement between us and each recipient as may be necessary under applicable law. We undertake to
ensure that each recipient knows the directive principles of personal data protection and submit to them
in application of the law and/or of a particular contract.

4.3. Confidentiality obligations. In case we share your data with selected third parties, including our third
party contractors and application developers, we always ensure that these third parties undertake
confidentiality obligations regarding your personal data collected while you use the services or
applications they offer. The developers use the information provided to them in order to provide you with
additional services, including technical support, if applicable. We will not share your personal data outside
the scope of purposes specified in this Privacy Policy without your prior consent.

4.4. Advertising disclaimer. Our ad management and recommendation system is designed so that your
information will not be shared directly with our third party advertisers. An advertiser or maker of a
recommendation can only choose to target advertisements to groups of users falling within criteria such
as age, gender, location (country, city), or other, or to target communities according to their types. If you
fall within one of the target groups, you will receive an advertisement or recommendation of such third
party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of
your information in case you interact in any way with the ads provided by such advertisers.
4.5. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list
of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser
or maker of recommendations) can check for user matches. They will see the number of matches but not
the matches themselves.

4.6. Sharing in the general conduct of business. We may also share your data with our affiliates and keep
some of your personal information in our business records for the accounting and compliance purposes.
As such, we may also disclose your personal information to a third party if we decide to transfer a
business to that third party, so you can continue to receive service and information in connection with
that business with as little disruption as possible. Similarly, in the event of a merger, acquisition,
reorganization, bankruptcy, or other similar event, your personal information may be transferred to our
successor or assignee.

4.7. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax
authorities in case it is necessary because of your participation in public tournaments. We may also
publish your data as part of the tournament score tables on our and third party websites.

4.8. Disclosure required by law. We reserve the right to disclose your personal information as required by
law, by court order or in special cases when we have reason to believe that disclosing such information is
necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other
terms of services provided by us or our affiliates or any applicable law, for the purpose of defense of our
rights and interests. We also reserve the right to disclose your personal information if we have a good
faith belief that it is necessary to prevent fraud or other illegal activities.

  1. PRIVACY SETTINGS

5.1. The Services may contain links to Websites operated by third parties. We are not responsible for your
data privacy when you access these links or engage with third party services, and you shall ensure that
you review the relevant third party’s privacy statement, which will govern your data privacy rights.

5.2. We bear no liability for the actions of third parties, which, as the result of your use of the Internet or
the Services, obtain access to your information in accordance with the confidentiality level selected by
you.

5.3. We bear no liability for the consequences of the use of the information that, due to the nature of the
Services, is available to any Internet user. We ask you to take a responsible approach to the scope of the
information posted on the Website.

  1. INTERNATIONAL TRANSFERS

6.1. We may transfer and maintain some of your personal information on our servers or databases
outside the European Economic Area (EEA).

6.2. The countries to which we transfer your data may not have the same data protection laws as your
jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual
Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately
protected.

  1. RETENTION PERIODS. DATA DELETION

7.1. We will retain your personal information for as long as required to perform the purposes for which
the data was collected, depending on the legal basis for which that data was obtained and/or whether
additional legal/regulatory obligations mandate that we retain your personal information during the term
that is required and/or permissible under applicable/relevant law.

7.2. You are entitled to withdraw your consent to process your personal data under this Privacy Policy at
any time by removing the data from your Account or alternatively by deleting your Account through your
Account settings and following the instructions provided by the Company after your sending such a
deletion request.

7.3. You may request to remove your Account and data on our Services by contacting the Service Support
(see section 11 for details). Please note that such withdrawal does not have any impact on the validity of
the consent before withdrawal, and we reserve the right to process your personal data on another lawful
basis if permitted by applicable law.

Please also note that uninstalling our game (or any application related to our Services) from your device
does not automatically result in consent withdrawal or any deleting your personal data from our servers.

7.4. We may remove your Account or the information you post, as provided by the Terms.

  1. YOUR RIGHTS

8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block, or delete your
personal data, if the data is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for
the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased if:

  • it is no longer required in relation to the purposes for which it was gathered or processed in another
    way;
  • you withdraw your consent concerning processing subject to consent;
  • you are justifiably opposed to the processing;
  • it has been subject to illicit processing; or
  • it is imposed by law.
    (e) Right to object to processing of your personal information.
    (f) Right to data portability (in certain specific circumstances).
    (g) Right not to be subject to an automated decision.
    (h) Right to lodge a complaint with a supervisory authority.
    (i) For processing based upon your consent, the right to withdraw that consent at any time.
    (j) You may have other rights under your legislation of your country of residence, including the right to
    define the instructions relative to the outcome of your personal data after your death.

8.2. You also have the right to independently remove personal information on your Account and make
changes and corrections to your information, provided that such changes and corrections contain
up-to-date and true information. You can also view an overview of the information we hold about you.

8.3. If you would like to exercise these rights, please contact us via mail or e-mail. We will aim to respond
to you within 30 days from the date of receipt of your request, unless another, shorter term, is prescribed
by applicable laws. We will need to verify your identity before we are able to disclose any personal data to
you.

  1. SECURITY MEASURES

9.1. We take technical, organisational, and legal measures, including, where suitable, encryption, to
ensure that your personal data is protected from unauthorised or accidental access, deletion,
modification, blocking, copying, and dissemination.

9.2. Access to the Services is authorised using your login and password. You are responsible for keeping
this information confidential. You shall not share your credentials with third parties and we recommend
you take measures to ensure this information is kept confidential.
9.3. If you forget your login details, you can request us to send you verification information as agreed by
the Terms.

9.4. To reduce the probability of third parties gaining unauthorized access, if you login to your Account
from an unusual place or after several failed attempts to provide valid login details, we may block entry to
your Account. You will then need to contact Service Support and provide certain additional information to
verify your credentials and gain access to your Account.

  1. CHANGES TO THIS POLICY

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in
any way, we will post an updated version on this page. We will store the previous versions of this Privacy
Policy in our documentation archive. We recommend you regularly review this page to ensure that you
are always aware of our information practices and any changes to them.

  1. CONTACT US

11.1. If you have any questions, please send your inquiries to Service Support at support@advgo42.com
or through Account settings/functionality provided via Services and/or send your request to us in writing
to Irodi Attikou, 8A Lakatamia, 2332, Nicosia, Cyprus. Please quote this Privacy Policy so we can deal with
your enquiry efficiently. We will aim to respond to you within 30 days from receipt of your request, unless
another, shorter term, is prescribed by applicable laws.

11.2. All correspondence received by us from you (written or electronic enquiries) is classified as
restricted-access information and may not be disclosed without your written consent. The personal data
and other information about you may not be used without your consent for any purpose other than for
responding to the enquiry, except as expressly provided by law.

11.3. The e-mail address of our DPO is legal@advgo42.com