Privacy Policy

 

PRIVACY POLICY FOR PROCESSING PERSONAL DATA

IN COMPLIANCE WITH FEDERAL LAW NO.152-FZ FROM JULY 27, 2006

"ON PERSONAL DATA "

 

  1. General Terms and Definitions under this Policy:

- User (owner of Personal Data) refers to private individual using Operator’s Online Services and communicating their questions and suggestions to Operator;

- Personal Data refers to any information that the User provides about themselves at their sole discretion upon registration (creating a user account) or during their use of the Services, including User’s personal information, such as name and last name, gender and age, photo(s), email address, etc.;

- Operator (of Personal Data) refers to CP Decision Limited that, at its sole discretion or jointly with other parties, organizes and/or undertakes Processing of Personal Data, as well as determines the purposes for Processing of Personal Data, contents of such Personal Data to be processed, and actions (operations) to be performed with such Personal Data;

- Operator’s Online Services refers to the website located at http://www.cpdecision.com/ and online games (games distributed via social networks and mobile application stores);

- Processing of Personal Data refers to any action (operation) or complex of actions (operations) with Personal Data performed by means of automation or not. Processing of Personal Data includes, without limitation, the following:

- Collection;

- Recording;

- Systemization;

- Accumulation;

- Storage;

- Verification (updating, editing);

- Exporting;

- Use;

- Delivery (distribution, provision, access);

- Anonymization;

- Blocking;

- Removal;

- Destruction.

- Automated Processing of Personal Data refers to processing Personal Data by employing computing devices;

- Distribution of Personal Data refers to actions aimed at disclosure of Personal Data to undefined persons;

- Transfer of Personal Data refers to any actions aimed at disclosing Personal Data to a given person or persons;

- Blocking of Personal Data refers to temporary suspension of processing such personal data (except for the cases when processing is required for Personal Data verification purposes);

- Destruction of Personal Data refers to any actions, as a result of which it becomes impossible to restore contents of Personal Data in the Personal Data Information System, and/or tangible Personal Data storage media are destroyed;

- Anonymization of Personal Data refers to any actions, as a result of which it becomes impossible to determine the attribution of given Personal Data to a specific owner of Personal Data without using some additional information or data;

- Personal Data Information System refers to the body of Personal Data contained in databases and information technologies and technical means that process such data;

- Trans-border Data Transfer refers to transferring Personal Data to the territory of a foreign state, to an authority of a foreign state, a foreign individual, or a foreign legal entity.

  1. General Provisions

 

CP Decision Limited (hereinafter Operator) recognizes and respects the right to private life of any person(s) that use Operator’s Online Services. This Document (hereinafter Policy) determines Operator’s policy towards processing Users’ personal data and outlines insights into implemented security requirements regarding users’ Personal Data.

This Policy may use terms and definitions as set out in the User Agreement, which this Policy and Game Rules (Appendix 1 to the User Agreement) constitute an inherent part of. The User Agreement and its Appendices together with this Policy are public documents and are available to any Internet user.

This Policy has been designed in compliance with personal data protection laws and regulations, and it governs the terms of Processing of Personal Data received by Operator from the Users as a result of their use of Operator’s Online Services.

This Policy applies exclusively to Operator’s Online Services and does not regulate websites that belong to other companies and organizations that Operator’s Online Services may reference and/or provide links to.

By choosing to register with a social network (Facebook, VK.com, OK.com, MyMail.ru, Fotostrana and other networks that provide access to the Game) and proceeding to log in to the Game by clicking on “Run Game”, “Play”, “Play Now” or similar buttons, or installing the Game on a mobile device via Google Play or App Store Mobile Platforms, User expresses full and unreserved agreement with the terms of Processing of Personal Data as set out by this Privacy Policy.

Operator does not control or accept any responsibility for third-party websites that the User may proceed to by following external links available from Operator’s website, including, without limitation, appropriate search results.

Operator reserves the right to collect and process information associated with User behavior during their use of Operator’s Online Services, as well as gaming data, such as achievements, ratings, etc., in order to adjust its Services with regards to User interests and to improve the overall quality of Services.

Operator accepts no responsibility for Personal User Data that have been entered by such User on the website, in the game, and/or in the social networks in a commonly available manner (e.g. on forum pages, in social network user comments, etc.).

Operator reserves the right to process anonymous User data associated with visits and website and social network use for statistical purposes.

 

  1. Rationale Behind Collecting Personal Data

Operator collects and stores only Personal Data of the type that is integral to using the Game and providing User with its services.

Operator reserves the right to use Personal User Data as required for the following purposes:

- User identification;

- Keeping in touch with the User, including provision of technical support;

- Determining whether User’s age is appropriate to carry out purchases in and/or use services;

- Providing services;

- Improving quality of services and the ergonomics and simplicity of their use;

- Development of new services and features;

- Undertaking statistical and other research based on anonymous data;

- Registration of entries for competitions and/or events;

- Informing Users of new services and features provided by Operator;

- Informing Users of updates and upgrades to services and features;

- Target advertising.

Operator employs cookies technology (where cookies are files carrying technical service information, sent by the web server to the User’s computer and subsequently stored in the User’s web browser; this technology is used to store data that is specific to a particular user). Cookies carry no confidential information and are not forwarded to any third parties.

 

Operator uses cookies to:

- Identify User and their device, e.g. by matching their IP address with previous records;

- Enable Operator’s services to interact with third-party services (e.g., social networks or mobile platforms);

- Allow Operator’s payment systems and/or applications to process User’s payments;

- Provide User with targeted personalized services, e.g. specific languages;

- Obtain data that will help Operator determine how Users use Services provided by Operator in order to improve those appropriately.

 

  1. Legal Basis for Processing of Personal Data

The legal basis for Processing of Personal Data is provided by Federal Law No.149-FZ from July 27, 2006 titled “On Information, Information Technologies and Information Protection”; Federal Law No.152-FZ from July 27, 2006 titled “On Personal Data”; CP Decision Limited’s company charter from January 26, 2017; the User Agreement (available to view and/or download at http://cpdecision.com/user-agreement; this Policy; and User’s Consent to Processing their Personal Data.

  1. Size and Categories of Processed Personal Data

 

Under this Policy, Operator may organize collection and processing of the following data:

- Personal information that the User provides at their sole discretion upon registration (i.e. creating a user account) or in the process of using the Services, including User’s personal details, such as name and last ame, gender and age, photo(s), email address, etc.;

- Data that are forwarded to Operator automatically during the process of using the Game or Game Services, including the IP address, cookies, information on User’s browser (or any other program that helps access the Services), time of access and address(es) of requested page(s).

  1. Order and Terms of Processing of Personal Data and Personal Data Protection

6.1. Confidentiality of Personal User Data is observed in all cases, except for when the User enters information about themselves with public availability to unlimited persons/parties at their sole discretion.

6.2. Operator reserves the right to forward Personal User Data to third parties, including those located abroad (trans-border data transfer) in the following cases:

6.2.1. Such third party is acting on the basis of a contract with Operator, seeking to execute their obligations towards the User;

6.2.2. User has expressed their consent for the specified action(s);

6.2.3. Information must be shared as part of use of a specific Service by the User, and/or to provide a Service to the User;

6.2.3.1.Collecting and processing user requests submitted to Operator’s game and user support is performed via the specially designed helpshift.com service (Helpshift, Inc., TIN 27-4516627).

6.2.4. Forwarding the information is determined by laws of Russian Federation or any other applicable legislation, as a set procedure, including, without limitation, cases when the business is partially or fully sold or in any other way consigned to another party; in this case, the party to acquire Operator’s assets is assigned all the obligations to the Users set out in this Policy and associated with any Personal Data they come into possession of;

6.2.5. In order to legally protect the rights and legitimate interests of Operator or any third party in cases when User breaches the User Agreement;

6.2.6. In accordance with rational and applicable requirements by law, such as enquiries by investigation agencies or other authorized bodies, as long as current law of the Russian Federation provides for the grounds for their enquiry.

6.3. Operator obtains information on User’s IP address (a unique ID assigned to a specific device connected to the Internet) in order to provide security to all of its users. This information is never used to establish user’s identity.

Platforms

 

Operator’s Online Services are offered to Users via a range of platforms, such as social networks (including, without limitation, Facebook, VK.com, OK.com, MyMail.ru, Fotostrana, Kanobu Games and others, that provide access to the Game); mobile platforms (App Store and Google Play); and other platforms for applications and software.

Any platform of this type may collect and use Personal User Data. When the User connects with the platform, it registers their Personal Data for future use.

Users can find more detailed information on each specific platform by studying that platform’s privacy policy.

 

Protecting Minors’ Personal Data

Operator recognizes children’s personal right to confidentiality. If a user is below 18 years of age, they are highly recommended not to forward any of their personal information to the Operator. Before forwarding their personal information to the Company, minors must always seek permission from their parents or their legal representatives or guardians to do so. User agrees to fully comply with this section of this Policy in case they are a minor (that is, under 18 years of age); otherwise, they must immediately cease to use any of the Operator’s Online Services.

 

Measures Taken to Protect Personal User Data

 

Operator takes all the necessary and sufficient measures, organizational and technical, to protect Personal User Data from unlawful and/or accidental access, destruction, amendment, blocking, copying, distribution, and any other unlawful actions by any third party.

- Operator has enacted documents that determine Operator’s policy regarding the Processing of Personal Data and local regulations for issues associated with processing such data; a person has been designated to be in charge of organizing the Processing of Personal Data;

- Lawful, organizational and technical measures are taken to limit access to Personal Data;

- Access to Personal Data is technically limited in the manner that implies that only specially authorized personnel may obtain such access by using special encrypted communication channels.

 

Personal User Data collected by Operator are stored on the premises/in archives/on various media, access to which is unavailable to unauthorized persons (that is, including physically locked premises). In order to avoid unauthorized access to Personal User Data over the Internet, Operator uses servers protected by firewalls and cryptographic technology. Operator also demands full compliance with security and protection measures associated with Personal User Data from any third party or person(s) that come in contact with such information as part of their work duties.

Period of Storage of Personal Data; Data Updates, Amendments and Destruction

 

User reserves the right to amend (update, extend) their Personal Data provided originally, in full or in part, as well as its confidentiality parameters.

In the event that it is confirmed that Personal Data was inaccurate, or that processing such data was unlawful, Operator must bring such data up to date, ceasing to process such data until this is done.

 

User reserves the right to delete personal information originally provided for a specific user account, in full or in part, by using an appropriate tool or function.

 

User reserves the right to request the following from Operator: to clarify their Personal Data; to block and destroy Personal Data, should they be incomplete, obsolete, inaccurate, illegally obtained and/or not integral to the processing purposes as given; to take measures provided for by law to protect User’s rights.

The request to clarify, block or destroy Personal Data must contain the following:

- User’s identification document number, information of its date and place/body of issue;

- Information confirming User’s relations with Operator, or information in any other way confirming that the User’s Personal Data has indeed been processed by Operator;

- Signature of the owner of Personal Data (or that of their representative).

The request may be forwarded as an electronic document signed with an electronic signature.

 

The request may be forwarded in the following manner:

- By email at support@cpdecision.com

- By post at E11 1BS, 12 Chelmsford Road, London, United Kingdom, N14 5PT, CP Decision Limited

 

User has a right to revoke their consent on processing their Personal Data; however, Operator reserves the right to continue the Processing of Personal Data in cases where it may help resolve a conflict or is part of executing services to the User and/or standing agreements, as well as to provide security in cases when User’s consent to process their Personal Data is not required.

 

Processing of Personal Data may be terminated in case when the purpose of such processing has been fulfilled, when the User’s consent has expired, or when the owner of such Personal Data revokes such User consent, as well as when unlawful Processing of Personal Data has been discovered.

 

To store Personal Data, Operator shall use databases located on the territory of the Russian Federation, in compliance with Part 5 of Article 18 of the Federal Law titled “On Personal Data”, as well as use data storage systems by helpshift.com (see Clause 6.2.3.1 of this Agreement).