(Last Updated: November 2018 with effective date 01 December 2018)
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy explains, how we and affiliated companies (collectively, “Lemel Labs” or “we”, “us”, “our”) collect and process personal data, when end users (“you” or “your”) use games and other applications, as well as related services (together the “Services” or “apps”) provided and managed by Lemel Labs.
The data controller is Lemel Labs OÜ, with a registered address at Belarus.
WHAT INFORMATION DO WE COLLECT?
When you use the Services, we collect certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data. However, in certain cases we may process such data, if you provide them to us (for example, if you resort to our support team).
We process the following information:
Device Information – these data include the operating system of your device (device type), your mobile device identifiers (device ID, advertising ID), resolution, version of the application, language, time zone, as well as IP address.
Information about Your Use of the Services – these data include information about your activity within the Services, such as achievements within the Services, completed levels and actions taken within the Services, in-app purchases data (payment identification number, the type and amount of a product, its price in your local currency, date and time of the purchase), subscriptions, advertising that you click on.
Location Information – these data include information about your country, state and city of your location.
User Inquiries Information – these data includes all information you provide to us when addressing our support team or communicate with us in any other way.
When you register with us and use Lemel Labs, you generally provide your name and email address.
DO WE PROCESS YOU PAYMENT INFORMATION?
Our Services include in-app purchases, e.g. subscriptions. If you want to make an in-app purchase, you may do this with the help of in-app payment system provided by the Platform (either Google Play managed by Google or AppStore managed by Apple) and integrated in the Services. The in-app payment system is managed by the Platform administration or its authorized partner. Under no circumstances does Lemel Labs collect or process any information related to your payment instrument, such as bank card number, its validity term or your name as written on it.
DO WE PROVIDE THIRD PARTIES WITH PERSONAL DATA OR GET PERSONAL DATA FROM THIRD PARTIES?
Yes. For the purposes of analytics and advertising, we use services and solutions provided by third parties. Such parties process data on our behalf and the respective technical solutions represent a part of the Services. Any transfer of your Personal Data is based on a written agreement, and we make sure such a third party complies with the applicable data protection regulations. Such third parties process Personal Data in accordance with their own privacy policies. Please, check privacy policies of such third parties.
In certain cases we may transfer information about you to other third parties (for example, independent personal data controllers), if we are obliged or allowed to do so by applicable laws. If it is the case, we transfer such information while adhering to applicable personal data protection laws.
If Lemel Labs is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, we may transfer Personal Data, together with business assets, to another company. In this case the respective notification will be available on the web-page of the Privacy Policy.
We also may transfer your Personal Data to a third party in the following cases:
- if we need so to protect legal rights of Lemel Labs, our end users, business parties or other interested parties;
- if we need so to enforce our agreements with you;
- if we need so to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
We process Personal Data for the following purposes:
- to provide and maintain the Services, make the Services available to you if you switch devices or temporarily stop using the Services, as well as to manage everyday business activity related to the Services.
- to manage and protect the Services (e.g. to collect analytics, test, support end users, report illegal activity, etc.).
- to communicate with you with regard to your inquiries submitted to our help&support team.
- to analyze how you use the Services in order to plan further development of the Services, keep the Services updated and improve them.
- to advertise our Services.
FOR HOW LONG DO WE RETAIN PERSONAL DATA?
We retain all Personal Data for as long as you use the Services and 24 months after you stop using the Services. If you do not use the Services for 24 continuous months, we erase your Personal Data from our data base, as well as request the same erasure from any third party, whom your Personal Data may have been transferred to. We may erase your Personal Data earlier if we do not need to process such data anymore.
If it is legally required that we retain your Personal Data for longer period for whatever purpose as stated in the applicable law, we will retain your Personal Data for the period determined by the law. We will immediately erase your Personal Data after such period expires or if the legal duty to retain such Personal Data is repealed.
We may retain your Personal Data longer only in case such Personal Data have been duly anonymized. After anonymization the data are not considered Personal Data, as the end user (the data subject) is no longer identifiable.
Please, take into account that erasure of Personal Data is irretrievable. After your Personal Data have been erased, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
DO WE PROCESS ANY PERSONAL DATA OF CHILDREN?
The Services are intended to be used by end users older than 16 years old.
We do not use the Services to knowingly solicit data from or market to children under the age of 13.
If you believe that we process Personal Data of a child below 13 years old, please, contact us and we will make all reasonable efforts to stop processing such data and erase it as soon as possible.
WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?
Under the applicable data protection regulation, if you are a citizen of the EU and fall within the scope of a data subject, you are entitled to the following rights: right of access, right to rectification (correction), right to erasure (deletion), right to data portability, right to object, right to restriction of processing.
- right of access. You have the right to access your Personal Data, which we process;
- right of rectification (correction). You have the right to ask us to replace any inaccurate data about you with accurate data. If you think that the data we process are incomplete for the purpose of processing as stated in this Privacy Policy, you may ask us to complete your Personal Data accordingly;
- right to erasure (deletion). You have the right to ask us to completely delete your Personal Data;
- right to object. You have the right to object to processing of your Personal Data for the purpose of direct marketing;
- right to restriction of processing. Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679;
- right to data portability. You have the right to ask us to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
DO WE CONTROL THIRD-PARTY WEB-SITES?
This Privacy Policy may contain links to other web-sites that are not operated by us. If you click on such a link, you will be directed to that third party’s site. We strongly recommend you to review the privacy policy and terms of use of every web-site you visit. Under no circumstances do we control third parties’ web-sites or assume any responsibility for the content, privacy policy, terms of use or practices of any third-party web-sites or services.
HOW DO WE ADVERTISE IN THE SERVICES?
We show advertisements in the Services with the help of third-party advertising partners. We integrate their technologies into the Services, which are then used by our partners to select the advertisements that meet your interests in the best way.
If you do not want to receive targeted advertisements, please, adjust settings of your device as instructed below.
HOW CAN YOU ADJUST PRIVACY SETTINGS OF YOUR DEVICE?
If you want to adjust the privacy settings of your device, please, take the following steps:
- iOS operating system: enable Limit Ad Tracking on iOS by opening “Settings,” then tapping on “Privacy,” then “Advertising”, and sliding the Limit Ad Tracking switch to “On”.
- Android operating system: opt out of Ads Personalization on Android by opening “Settings”, then tapping “Google”, then “Ads”, then enable the switch next to “Opt out of Ads Personalization”.
HOW DO WE COLLECT AND PROCESS DATA FOR ANALYTICAL PURPOSES?
In order to analyze various aspects of the Services functioning, we need to collect and process certain information with regard to your interaction with the Services. Such information includes your location data, information about your device and advertising data. It may also comprise information about errors of the Services functioning. For this purpose we use technologies and solutions provided by third parties – our analytical partners. We integrate such technologies into the Services and our partners process the data on our behalf to provide us with analytics.
Processing data for analytical purposes is based on a legitimate interest of Lemel Labs – analyzing data about the Services for commercial purposes. Analytics helps us to provide better services to users, update and develop the Services. For example, we may use such information in order to fix errors of the Services, evaluate demographic composition of our users, determine what features to add to the Services or whether we need to translate the Game into another language.
CHANGES TO THIS PRIVACY POLICY
We may need to change the Privacy Policy from time to time, and we encourage you to review it at least once per month. If you continue to use the Services after changes have been introduced to the Privacy Policy, this will mean that you have accepted such changes to the Privacy Policy.
In some cases, we may notify you of changes to the Privacy Policy with a prominent notice on the Services (for example by way of a notification or pop-up), before the changes become effective and update the “effective date” at the top of this Privacy Policy.
CONTACT US
If you have any questions about this Privacy Policy, please contact us using the “Contact Us” form on our web-site http://lemellabs.com.
APPENDIX A – Advertising networks and their partners
(Last Updated: December 2020 with effective date 22 December 2020)
For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, content selection, delivery, reporting and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple’s ID for advertising (IDFA). For more information on how to opt-out go to Privacy Policy Opt-out of targeted advertising further above. In addition, the advertising networks listed below, with the exception of Fyber and PubNative who act as data processors upon our instructions, are independent data controllers in respect of your Personal Data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.
Adcolony
Adcolony is an advertising service provided by Jirbo, Inc (US)
Privacy Policy: https://www.adcolony.com/privacy-policy/
Amazon Developer
Amazon Developer is an advertising service provided by Amazon, Inc. (US).
Privacy Policy: https://aws.amazon.com/privacy/
You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs
AppLovin
AppLovin is an advertising service provided by AppLovin Corporation (US)
Privacy Policy: https://www.applovin.com/privacy
Facebook Audience Network
Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service, except for users who are based in California and exercise their right to opt-out.
Privacy Policy: https://www.facebook.com/about/privacy/
You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.
Fyber
Fyber is an advertising service provided by Fyber Group. (Israel)
Privacy Policy: https://www.fyber.com/services-privacy-statement/
Google AdMob and their partners
AdMob by Google is provided by Google Inc. (US)
For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/
For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903
You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
Google AdSense
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/
HyprMX
HyprMX is an advertising service provided by HyprMX Mobile LLC (US)
Privacy Policy: https://www.hyprmx.com/pp
Note: It is used only for users in the US.
InMobi
InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)
Privacy Policy: https://www.inmobi.com/privacy-policy/
Opt-out: https://www.inmobi.com/page/opt-out/
IronSource
IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.
Privacy Policy: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Maio
Maio is an advertising service provided by i-mobile Co., Ltd. (Japan)
Privacy Policy: https://adpf-info.i-mobile.co.jp/privacy_en/
MyTarget
MyTarget is an advertising service provided by My.Com B.V (Netherlands)
Privacy Policy: https://legal.my.com/us/games/privacy/
Nend
Nend is an advertising service provided by F@N Communications, Inc. (Japan)
Privacy Policy: https://www.fancs.com/en/privacy
Ogury
Ogury is an advertising service provided by Ogury Ltd (UK)
Privacy Policy: https://ogury.com/privacy-policy/
Pangle
Pangle is an advertising service provided by Bytedance Pte. Ltd. (Singapore)
Privacy Policy: https://www.pangleglobal.com/privacy
Rubicon Project
Rubicon Project is an advertising service provided by The Rubicon Project, Inc. (US)
Privacy Policy: https://rubiconproject.com/privacy/
Opt-out: https://rubiconproject.com/privacy/consumer-online-profile-and-opt-out/
Snapchat
Snapchat is an advertising service provided by Snap Inc. (US)
Privacy Policy: https://www.snap.com/en-US/privacy/privacy-policy/
Smaato and their vendors
Smaato is an advertising service provided by Smaato, Inc. (US)
Privacy Policy: https://www.smaato.com/privacy/ For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/
Unity Ads
Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Privacy Policy: https://unity3d.com/legal/privacy-policy
Verizon Media and their vendors
Verizon Media, previously known as Oath, provides advertising services under their AOL, Yahoo and other brands.
Privacy Policy: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/index.html
For more information on VerizonAOL (OATH) Vendors, please visit: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/topics/thirdparties/index.html
Vungle
Vungle is provided by Vungle, Inc. (US)
You can opt-out from Vungle service by following the instructions as described by Vungle on their Privacy Policy page: https://vungle.com/privacy/
Yandex
Yandex is an advertising service provided by Yandex LLC (Russia)
Privacy Policy: https://yandex.com/legal/confidential/
Note: It is used only for users in Russia.
APPENDIX B – Analytics and other service providers
We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.
Tenjin
Tenjin is analytics service provided by Tenjin LLC (US)
Privacy Policy: https://www.tenjin.com/privacy
Facebook Ads conversion
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on the Services.
Privacy Policy: https://www.facebook.com/about/privacy/
Facebook Analytics
Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.
Privacy Policy: https://www.facebook.com/about/privacy/
Firebase
Firebase is an analytics service provided by Google Inc. (US)
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://www.google.com/intl/en/policies/privacy/
Yandex App Metrica
Yandex Appmetrica is an analytics service provided by Yandex LLC. (RU) Policy: https://yandex.com/legal/confidential/index.html