Effective Date: 8 June 2020
At Libertime LLC (“Libertime” “we” or “us”), are committed to respecting your privacy and the integrity and security of your personal data.
Libertime is data controller with legal address at prospekt Pobediteley 23/1, office 500b, Minsk, 220004 Belarus.
1. What Data We Collect
The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from our partners.
Data you provide to us
- Contact information (such as name and email address)
- Your messages to the Services (such as chat logs and player support tickets)
- Limited and tokenized payment information may be collected when making a purchase
- Other data you choose to give us
Data we collect automatically
- Data about your game progress
- Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services
Data we collect from our partners
- Data we receive if you link a third party tool with the Services (such as Facebook, or Google)
- Demographic data (such as to determine the coarse location of your IP address)
- Data to fight fraud (such as refund abuse in games or click fraud in advertising)
- Data from platforms that the games run on (such as to verify payment)
- Data for advertising and analytics purposes, so we can provide you a better Services
- Your mobile device identifiers (such as your device ID, advertising ID)
- Data about your device, such as device name and operating system, browser type and language
- General location data
2. Why Do We Collect Your Data
To make the Services work
To perform the contract, we process data necessary to:
- Allow you to use our Services
- Operate the Services
- Verify and confirm payments
- Provide and deliver products and services you request
- Send you Services-related communications
To make the Services more suitable for our players
To provide a great Services to our players, we have a legitimate interest to collect and process necessary data to:
- Develop and improve the Services and player experience
- Manage our relationship with you
- Provide social features as part of the Services
- Customize your Services experience
- Respond to your comments and questions and provide player support
- Provide you our offers in the Services
- Send you related information, such as updates, security alerts, and support messages
- Enable you to communicate with other players
To show personalized advertisements
To show you personalized advertisements in the Services 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
- For information on how to opt-out from personalized advertisements, see section “Your rights and options” below.
To keep the Services safe and fair
In order to keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:
- Analyze, monitor and moderate use of the Services and its social features
- Take action against fraudulent or misbehaving players
To keep the Services safe and fair
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
3. Who Can See Your Data
Apart from Libertime, your data can be accessed by others in the following situations:
Other players and users.
Social features are a core component of our Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Other companies and public authorities.
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
Our Service Providers and Partners.
We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.
4. International Data Transfers
Our Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
5. Your Rights and Options
Opt-out of targeted advertising.
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.
Access the personal data we hold about you.
If you request, we will provide you a copy of your personal data in an electronic format.
Opt-out of marketing emails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Your other rights.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.
We will respond to all requests within a reasonable timeframe. You may also contact your local data protection authority within the EEA for unresolved complaints.
6. Cookies and Similar Technologies
7. How Do We Protect Your Data
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
8. Age Limits
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 16 and over. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.
9. Contact us
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact us at firstname.lastname@example.org.