Заботливый en privacy policy. ИБ: Зачем нужна Privacy Policy и что в ней меняет GDPR. Как долго мы храним ваши данные

PRIVACY POLICY

Last updated: 23/05/2018

1. Who we are

1.1 We are Pixonic Games Ltd located at 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus.

1.2 This Privacy Policy sets out how we collect and use your personal information when you use our website сайт, including contact form ("Services"), offered by Pixonic Games Ltd and the choices available to you in connection with our use of your personal information (the Privacy Policy).

This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (at https://сайт) (Terms).

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

1.3 For the purposes of relevant data protection legislation, Pixonic Games Ltd, is the data controller of the information you provide in submitting your resume or employment application.

2. This Privacy Policy

2.1 By making available the Services we, acting reasonably and in good faith, believe that you:

(a) provide true information about yourself to the extent necessary for use of the Services;

(b) are aware of and accept this Privacy Policy.

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

3. Information we collect about you

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

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

Information collected: Your e-mail address
Purpose: We use this information in order to manage and administer the Services provided to you. We use this information in order to communicate with you.
Information collected: Information that you submit to us via contact form when send us an email, including those which contain your employment application (certain information about you including your name, address, date of birth, education and qualifications, training, previous employment, references and other related details you provide or provided about you in the course of your employment application).
Purpose: We use the information we collect from you for the purposes of:
Evaluating and progressing your employment application;
Creating your employee personnel file, if hired;
Maintaining our own internal records of employment applications; and
Protecting the rights and interests of Pixonic Games Ltd and others.
Legal basis: Legitimate interests

3.3 We process your data for the purposes identified above, as necessary, (1) for the legitimate interests of us and other third parties, including maintaining and administrating the Services; (2) to comply with our legal obligations; and (3) to perform our obligations under your employment contract, should your application be successful. We also process your data where you have otherwise provided consent.

3.4 Please pay your attention, we do not collect and process information that usual automatically collected through a User’s interaction with services through cookies and other technologies.

3.5 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.

3.6 We do not require you to submit any special categories of personal data, such as personal data relating to your health or religion, as part of your employment application. Please note, 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 your sexual orientation) you should take care not to send this information to us.

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

4. Data sharing

4.1 We may share your personal information with companies, organisations and individuals inside and outside of the Pixonic Games Ltd where one of the following circumstances applies:

To other companies in our group, for administrative and management, subject to us taking reasonable measures to ensure that your information is kept secure at all times;

To trusted third parties businesses, or persons who perform services and process your personal information for us for the purposes listed above, based on our instructions, subject to us taking reasonable measures to ensure that your information is kept secure at all times; and

To companies, organisations or individuals outside of the Pixonic Games Ltd if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:

o meet any applicable law, regulation, legal process or enforceable governmental request;
o detect, prevent or otherwise address fraud, security or technical issues; or
o protect against harm to the rights, property or safety of the Mail.Ru Group, our customers or the public, as required or permitted by law.

4.2 Pixonic Games Ltd, My.com B.V., other companies in the Mail.ru Group or our selected third party partners with our permission, using their own ad servers, can show advertisements to you.

5. International Transfers

5.1 We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in USA, Japan, Russia.

5.2 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.

6. Retention Periods

6.1 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. Where you are unsuccessful in your application, but potentially your application might be suitable for future vacancies within Pixonic Games Ltd, we will keep your information during three (3) years, otherwise will delete immediately. If you are successful, this will be for the duration of your employment with Mail.ru Group plus a period following your employment.

6.2 You may request to remove your data on our Services by contacting the Service support (see Section 10 for details).

7. Your Rights

7.1 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.

(d) Right to request that your personal information is erased.

(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.

7.2 If you would like to exercise these rights, please contact Support Service at legal@сайт or send your request to us, in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

8. Security Measures

8.1 We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9. Changes to this Policy

9.1 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 achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

10. Contact Us

10.1 If you have any questions, please send your inquiries to Service support at legal@сайт or send your request to us, in writing to 243, 28th Oktovriou Street, 7th Floor, Apartment 702/802, at Christiana Sea View Court, 3035 Limassol, Cyprus. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

10.2 All correspondence received by us from you (written or electronic inquiries) 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 response to the inquiry, except as expressly provided by law.

10.3 The e-mail address of our DPO is [email protected].

At Apalon, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security and others to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

1. INTRODUCTION

Welcome to Apalon"s Privacy Policy. Thank you for taking time to read it!

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

If you live in the European Economic Area ("EEA"), the company that is responsible for your information under this Privacy Policy (the "data controller") is:

IAC Search and Media Europe Limited
10 Earlsfort Terrace
Dublin 2
Ireland

If you live outside the EEA, the company responsible for your information is:

Ask Applications, Inc.
29 Wells Avenue, Suite 300
Yonkers, NY 10701
ATTN: Privacy Officer/Legal Dept.

2. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps and other services operated by Apalon. For simplicity, we refer to all of these as our "services" or "apps" in this Privacy Policy. To make it extra clear, we"ve added links to this Privacy Policy on all applicable services.

3. INFORMATION WE COLLECT

It goes without saying, we can"t help you have an awesome user experience without some information about you, such as your email address and password in some of our services. We also collect information generated as you use our services, as well as information from third parties, like when you access our services through your Facebook account in Weather Live. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it.

Information you give us

You choose to give us certain information when using our services. This includes:

When you create an account in some of our services, you provide us with your login credentials, such as email address, name and password.
To use certain features in our services, you may allow us to access your camera or the microphone. Depending on your device, Apple and Android system will ask for your permission before allowing us to access these features. The Warmlight – Picture Editor App does not have access or collect any facial data.
Features that allow you to share content about your use of our services with your connections or through your social network. We may also collect your information when you use our app such as when you post or share material, upload data, request further services or make selections using our app, if such functionality is available in the app.
In our Paloma app, please note that anything you input into the app (such as your menstruation) is stored on your device and not accessible by Apalon. However, in order to understand if our Paloma users are enjoying the app, we do receive anonymised statistics from our analytics partners about what features users like and don"t like. Should you wish to sync data held in your Apple "Health" app with Paloma (and vice versa), we will ask you for your explicit permission to do this. If you permit Paloma to access your Apple "Health" app data, then this data will only be stored on your device and will not be transmitted to Apalon or any other third party. You can "unsync" Paloma from your Apple "Health" app or vice versa at any time – however, please note that all previously synced data will remain. You can manually remove your data from your Apple "Health" app or Paloma at any time.
In our Sleepzy app, we ask for your explicit permission to access your heart rate data, which is stored on your device through Apple "Health" app. If you permit Sleepzy to access this data, then this data will be displayed in the Sleepzy app to help you gain a better understanding of your sleep habits and sleep quality alongside your health metrics. We will not store or access any of your health data that is accessed from Apple "Health" app and will not transmit this data to external servers or any other third party; all data from Apple "Health" app shall remain on your device. For additional clarity, we will not use your health data for advertising, promotion, cross-selling or any similar service.
If you contact our support team, we collect the information you give us when you report a problem, contact or communicate with us. In our VPN App, we do not connect this information to your internet browsing activities through our VPN.
From time to time, we may request your opinions, suggestions, or modification and improvement ideas ("Feedback") through surveys, or other similar requests. Any responses you provide are voluntary, however you agree that any Feedback you provide shall be owned Apalon and may be used by Apalon in our sole discretion.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Information collected when you use our services

When you use our services, we collect information about which features you"ve used, how you"ve used them and the devices you use to access our services. See below for more details:

Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, time spent in the app, features you"ve been using, advertising that you click on).
Movement Data : If you opt-in, some services (e.g. Apalon"s sleep tracker app, Sleepzy) may collect movement data from your device.
Device information

We collect information from and about the device(s) you use to access our services, including:

geolocation data (in some of our apps), which is any information which indicates the geographical position of your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some apps may collect this data when the app is not open or actively in use. This may help us or third parties to customize information, content, or offers to you, for instance.
information on your wireless and mobile network connection, like your service provider and signal strength.
hardware and software information such as IP address, device type, app crashes, app version, advertising IDs (such as Google"s AdvertisingID and Apple"s IDFA, both of which are randomly generated numbers that you can reset by going into your device"s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

Information we collect when you use our #VPN app:

Our #VPN app is intended to provide for secure and private internet browsing to be used in accordance with all applicable laws.

In our #VPN app, we collect information from and about the device(s) you use to access our VPN app, including:

From when you open the #VPN App:
. Our servers automatically record information about how a person uses the app, including things like app install source, IP address, app version, operating system, device model and device language.
. From time to time, we might show you subscription offers - but at no time will you see an advertisement in our #VPN app.
. At no time will we ask you for access to your precise device location data in our #VPN app.
From moment you turn on #VPN software:
. Your browsing activity (including your IP address) becomes encrypted, meaning it becomes invisible to ISPs, third party snoopers and even us.
. We have a strict no-logs policy when it comes to seeing user activity online. Your IP address is deleted after you disconnect from the VPN.

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

As described in Sections 3 and 5 of this Privacy Policy, we sometimes work with third parties to deliver ads or offers. Sometimes we or these third parties do so through a mobile "SDK." The SDK is a bit of computer code that app developers can include in their apps to enable data to be collected and ads to be shown. We may use this and similar technology to deliver certain advertising through mobile applications and browsers based on data associated with your mobile device, and we may work with third parties who likewise embed their SDKs into our services, for third party advertising. If you"d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions below or in the app (as applicable).

If you wish to opt out of interest-based tracking through your mobile device, you can do so through your device "settings", as follows (but please note that the below is for informational purposes only and Apple, Google, or other device platforms may change the manner in which their "opt out" settings work at any time): Please note that if you opt out through these settings, you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. For instance, that advertising may be based on your real-time or "contextual" application usage or general location inferred from IP address.

Opting Out on iOS Devices Such as iPhones, iPads or iPods
If you have an Apple device, you can opt out of interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to "ON". On an iPhone 6 for example, you can do this by clicking on Settings -> General -> Privacy -> Advertising and toggling "Limit Ad Tracking" to "ON". Our systems are designed to respect your choice and not use your personal information to provide interest-based advertising when this setting is ON.

Opting Out on Android Devices
If you have an Android device and would like to opt out of interest-based advertising, you may do this as follows:

Open the Settings app on your device
Go to "Google"
Select Ads
Opt out of interest-based ads

More information on our use of cookies on our websites can be found in our .

5. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we may use your information to help keep you safe and to communicate with you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

In our #VPN App specifically

When you connect to the VPN, we collect your IP address, immediately encrypt it and store it only for the duration of your VPN session. Your IP address is deleted after you disconnect from the VPN. We do not associate your IP address with your online activities and we do not store or log your IP address after you disconnect from the VPN.

We do not keep logs of your online activities and never associate any domains, or applications that you access while the VPN is connected with you or your device.

We DO NOT use your non-personal information (meaning information that, by itself, does not identify who you are such as device information) for targeted online marketing through tools like Facebook Custom Audience to contact interested parties.
We DO NOT use or share VPN IP or usage data (i.e. network activity).

To administer your account and provide our services to you

Deliver our services to you and ensure their optimal functionality and operation.
Identify, establish and manage your account and our relationship with you.
Provide you with customer support and respond to your requests.
Should you provide us with this information, we may use your email address, name, country and language for customized marketing purposes.
When we collect your precise geolocation data (subject to your consent) (which may be via the device"s cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties" apps) that may be related to your location over time.
Some of our apps may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the app you are using, and on the social media provider concerned, but may often include your name, e-mail address, mobile phone number and friends list. If you login using your Facebook account, your e-mail or your phone number then we may receive a unique ID in connection with this login. This is solely used for confirmation purposes and is kept separate from all other online identifiers. We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you in the app you are using. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you see their privacy policy to understand how they collect, use and share your information, and how you can set your privacy preferences on their sites and apps.
If you have registered with an app using your social media account details, we may use the information we receive from your social media provider to identify which of your friends are also using our services so that you can connect with them in our app.

In some services, to ensure a consistent experience across your devices

Link the various apps and devices you use, so that you can enjoy a consistent experience of our services on all of them. This will allow us to form a single view of your use of our services, so you can easily access your content on multiple devices. For this purpose and better user experience generally, we may use and combine your personal information which we collect across different services used by you.

To improve our services and develop new ones

Develop new features and services (for example, we may decide to build a new feature further to requests or feedback received from users).
Apalon uses the Google Analytics tool Firebase in order to carry out analysis on information which is gathered by our apps. Device information and other information which we gather are provided to Google in order to enable them to carry out data analysis. Any information which is provided to Google will become subject to Google"s privacy policy which is located here: www.google.com/privacy.html . For further information on how Google"s Firebase analytics tool uses data, please see the site "How Google uses data when you use our partners" sites or apps", (located at www.google.com/policies/privacy/partners/).
Conduct research and analysis of your behaviour about your use of, or interest in, our products, services, or content to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users" behaviour). This software may record information such as how often you use the services, what happens within the services, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from.

To communicate with you

To serve you relevant offers and ads

To prevent, detect and fight fraud or other illegal or unauthorized activities

Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our

To process your information as described above, we rely on the following legal bases:

Provide our service to you : Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to maintain your account and provide our cool features to you.
Legitimate interests : We may use your information where we have legitimate interests to do so. For instance, we analyze users" behavior on our services to continuously improve our offerings and we process information for administrative, fraud detection and other legal purposes.
Consent : From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time where indicated in the services or by contacting us at the address provided at the end of this Privacy Policy.

6. HOW WE SHARE YOUR INFORMATION

Since our goal is to provide the best services we can to you, the main sharing of users" information is with service providers and partners who assist us in operating the services, with other IAC Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

With our service providers and partners

We follow a strict vetting process prior to engaging any service provider or working with any partner. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, marketing, advertising and security operations. These service providers may have limited access to your information, which is needed to perform their functions, but are not permitted to share or use such information for any other purposes. For example, we use your non-personal information (meaning information that, by itself, does not identify who you are such as device information) for targeted online marketing through tools like Facebook Custom Audience to contact interested parties.
In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note that such aggregated information will not include any information which allows third parties to identity you.
With our #VPN service providers
Our VPN service providers may have limited access to your information, which is needed to perform their functions, but are not permitted to share or use such information for any other purposes. We do not log, and prohibit our VPN service providers from logging, your internet browsing activities when you use our VPN.
With other IAC Group companies
Apalon is part of the IAC Group family of businesses.
We share your information with other parts of IAC to:
Assist us in technical processing operations, such as data hosting and maintenance, finance, legal, HR and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
. for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; or (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties and/or to comply with applicable law; (iii) to enforce our agreements or policies with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

7. HOW WE PROTECT YOUR INFORMATION

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at

8. INFORMATION RELATING TO CHILDREN

Our services are intended for general audiences over the age of 13 years old (or over the age of 16 if you are resident in the EEA). We do not knowingly collect information from children under the age of 13 years old, or 16 years old in the EEA. If you are not over 13 years old (or 16 years old in the EEA) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 13 years old (or over the age of 16 if you are resident in the EEA), please contact us at and we will promptly delete that personal information

9. YOUR RIGHTS

We want you to be in control of your information and be aware of your privacy rights, so here are a few key points to remember:

Depending on your location you may have some or all of the following rights in relation to how we use your personal information:
. Access: you may request access to your personal information and receive copies of it;
. Correction: you may have inaccurate/incomplete personal information corrected and updated;
. Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it.
. Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honour such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it.
. Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider)
. Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.
If you wish to exercise any of these rights, or wish to object to our use of your information, please write to us at the address listed below and we will consider your request in accordance with applicable laws.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
For your protection, we may ask you to provide proof of identity before we can answer the above requests.

10. CROSS-BORDER DATA TRANSFERS

Sharing of information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. The United States, European Economic Area ("EEA") Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live.

The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of the EEA. We use these Model Clauses or other suitable safeguards (such as EU-US Privacy Shield to send personal information to some of our third party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program) to permit data transfers from the EEA to other countries.

11. HOW LONG WE STORE YOUR INFORMATION

We retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active or as needed to provide the services to you. We will also retain and use your information to the extent necessary:

to comply with applicable law;
to evidence our compliance with applicable law;
if there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
if the information must be kept for our legitimate business interests, such as enforcing our terms or fraud prevention. For example, information may need to be kept to prevent a user who was banned for security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12. PRIVACY POLICY CHANGES

Because we"re always looking for new and innovative ways to help you enjoy our services, this policy may change over time. We will notify you of any material changes so that you have time to review the changes.

13. DATA PROTECTION OFFICER

For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached by contacting

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, here"s how you can reach us:

By post:
IAC Search and Media Europe Limited
10 Earlsfort Terrace
Dublin 2
Ireland

If you live in the EEA, you may also file a complaint with your local data protection regulator.

We have recently updated our policies and we are in the process of translating it into several languages. If you do not have an appropriate language option and you have any questions, please contact us.

END OF DOCUMENT.

Welcome to сайт ("PacoGames"). PacoGames allows users to access thousands of games and its related services (the "Service").

This section of the website explains how PacoGames and its affiliates collect, use, share and protect user"s information related to the use of the Service.
PacoGames collects and uses data in accordance with applicable laws in the US, the EU, or eventually with superior territorial decisions.
This policy applies to all visitors, users and other people using the Service

PacoGames measures, tracks, and records general behavior of users on the website and in the games in order to detect bugs and improve their products.

1. INFORMATION WE COLLECT

Based on permission, Pacogames collects the following types of information.

1.1 Information collected within a legitimate interest

1.1.1 Analytic Tools

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

1.1.2 Browser Storages

To improve the user"s experience, PacoGames uses browser storage in the form of cookies and local storages. An example of the saved data can be the list of games played in the given browser, or recorded scores in the played games. This data is stored only on the client side and does not serve to identify a particular user.
We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

1.2. Information collected based on user"s consent

By consensus, the user agrees with extension of the authorization to collect and process data with the following additions. The validity period of the consent is 3 years, if the user does not withdraw his consent earlier. Consent also expires by deleting the user"s account.

1.2.1 Analytic Tools 1.2.3 Device Identifiers

A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

1.3. Information collected during communications between a visitor and Awagon.

Communication made over contact form, bug report, email, telephone, post or different offline supported way is storred for a time necessary for its execution. (maximum of 3 weeks, unless otherwise provided by the law). Using the bug report form, the user automatically sends his browser and operating system signature. These data help us to identify possible problems more quickly and accurately.

2. HOW WE USE YOUR INFORMATION

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:

sign in option. Remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
diagnose or fix technology problems
provide personalized content and information to you and others, which could include online ads or other forms of marketing
develop and test new products and features
monitor metrics such as total number of visitors, traffic, and demographic patterns

3. SHARING OF YOUR INFORMATION

We will not rent or sell your information to third parties outside Awagon Entertainment s.r.o. (operator and owner of PacoGames) (or the group of companies of which PacoGames is a part) without your consent, except as noted in this Privacy Policy.

Parties with whom we may share your information:

We may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

4. Information storage and processing

Confidential data provided to Pacogames are stored in an encrypted form.
In order to keep the information collected via the Service safe, we are taking appropriate measures for the relevant business purpose, and before we give you access to your account, we will take reasonable steps to verify your identity (such as requiring a unique password)
Awagon Entertainment s.r.o., its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

How long we keep your User Content:

Following termination or deactivation of your account, Awagon Entertainment s.r.o., its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes.

5.CHILDREN"S PRIVACY

Awagon Entertainment s.r.o. does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

6. OTHER WEBSITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services.
Our websites or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.

7. Network Advertising initiative (NAI)

8. CHANGES TO OUR PRIVACY POLICY

Awagon Entertainment s.r.o. may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of PacoGames or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

Intro to the Fyber Site

Welcome to Fyber Site! This is a marketing site aimed to provide information and content about Fyber and Fyber’s Service.

The Fyber Site is a marketing website aimed to provide information and content, created by Fyber, about Fyber and its Services. You can visit the Fyber Site without any registration.

When visiting the Site, Fyber will receive information that you voluntarily provide, such as when you fill out a “contact us” form request, when you apply to join one or more of the Fyber Services or when you subscribe to the Fyber newsletter and will collect ‘traffic/session’ information from your device.

Such information will include Personal Information such as your name, email address, telephone number or any other information you provide to Fyber. Please note that you are not required by law to provide us Personal Information. Fyber’s Site is not directed to children under 16 years of age and Fyber does not intentionally or knowingly collect Personal Information on such users.

1. The Personal Information that You Provide Voluntarily Through the Site

We receive Personal Information that you provide and submit through our Site.

When you contact Fyber, by filling a form on the Site, contacting Fyber’s customer support team for technical issues or contacting Fyber’s legal team with any questions or inquiries or when Fyber contacts you regarding any of the above, Fyber will process any Personal Information that you provide Fyber such as your name, your company’s name and email address.

If you submit Personal Information in a comment on a blog post or on any applicable social media websites, others can read, collect and use the Personal Information that you submit including to send you unsolicited messages and contact you for other purposes.

Fyber is not responsible for the Personal Information that you choose to submit in these blogs.

2. The Personal Information that Fyber collects Through the Site

Fyber automatically logs ‘traffic/session’ data and collect additional activity information.

When you access the Site, Fyber’s servers log ‘traffic/session’ information from your device, such as your user agent and the Internet Protocol (IP) address.

When you use the Site, Fyber will collect information about your activity, for example, your log-in and log-out time, the duration of sessions, web-pages that you have viewed or specific content on web-pages, activity measures and geo-location of your device.

3. The Site Includes Third Party’s Services

The Site includes Third-party services that are governed by their own privacy policies.

We incorporate to the Site third party’s services, such as Marketo (a marketing automation platform), which are governed by their respective privacy policy. For example, Marketo’s privacy policy can be found at: https://www.marketo.com/ . You can find a full overview of all Services used on the Site at: . You should read the privacy policy of these services to understand their practices.

Fyber Site includes links to third-party social media websites, such as Youtube ® Facebook ® , Twitter ® , LinkedIn ® , Google+ ® and Vimeo ® , and associated social media features and scripts, such as the Facebook® “like” button and widgets. These features and scripts collect details such as your IP address, which page you are visiting on the Site, and set a cookie to enable the feature to function properly. Please read the cookie section under this policy to learn more about cookies.

The third party social media website or our own Site host the Social media features and widgets. The social media websites have their own privacy policies. When you use their platforms, features, widgets and other services, you should read their privacy policies to understand their practices.

4. What does Fyber do with Personal Information it Receives Through the Site?

Fyber maintains the Site, improves and continues developing it, and protects the Site from misuse and law violations.

Fyber uses Personal Information that you provide through the Site for its business’ purposes, such as responding to your inquiries or support requests, for marketing, recruiting and hiring, and to contact you in the course of offering you with any of Fyber’s services and the Fyber newsletter.

Fyber uses the information, including Personal Information that Fyber and its service providers collect through the Site to understand users’ interests and behavior on a pseudonymous, no-name basis in order to be able to deliver content tailored to the users’ preferences.

As applicable laws require, Fyber will use Personal Information to enforce Fyber’s terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

сайтmits to process Personal Information solely for the purposes described in this policy.

5. Sharing Personal Information with Others

We use service providers, for example, to send email messages. We share Personal Information with our affiliated companies. We transfer information as needed if we change our corporate structure, and we may share the information with our affiliate entities.

Fyber shares Personal Information related to you with service providers and other third parties, if necessary to fulfill the purposes for collecting the Personal Information, on condition that any such third party will commit to protect your privacy as applicable laws and this policy require.

Share Personal Information with Fyber’s corporate affiliates in order to operate the Site.

Share Personal Information with law enforcement and/or government agencies, courts, and/or other organizations: (a) as the law requires, such as to comply with a subpoena, or similar legal process; and/or (b) when Fyber believes in good faith that disclosure/sharing is necessary to protect Fyber’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

Share or transfer Personal Information if Fyber is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. Fyber will provide a prominent notice on the Site of any change in ownership or uses of this information if applicable.

The entity which will assume the ownership of the Site will continue to protect Personal Information related to you under this Policy;

Share it in any other circumstances where Fyber receives your written consent;

6. Aggregated and Analytical Information

Fyber also collects non-identifiable information through Google Analytics. Analytics data include for example, the type of browser, browser language, type of operating system, domain name of Internet service provider, device IP address web pages visited, times and dates of visits and the content you access on and/or through the Site.

The privacy practices of these tools are subject to their own privacy policies. Fyber therefore encourages you to read Google’s policy regarding its analytics services at: http://www.google.com/analytics/learn/privacy.html .

Fyber uses anonymous, statistical or aggregated information and shares them with Fyber’s partners for legitimate business purposes. This has no effect on your privacy because there is no reasonable way to extract data from the aggregated information that can be associated with you.

7. Cookies

Yes. We use cookies. Read more about it.

Cookies are small packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

Fyber uses Session Cookies for legitimate purposes, such as facilitation of the use of the Site and its features and tools. Your device removes session cookies when you close your browser session.

We also allow third parties, such as Google analytics and social media websites to place cookies on your device. These are persistent cookies. A persistent cookie has an expiry date. It remains on your device until it is expired or removed.

If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you can delete cookies, block them or control when they can be placed.

8. User Choice

At any time, you may opt out from our mailing list and change your cookies preferences.

At any time, you can unsubscribe from Fyber’s newsletters list, by sending Fyber an opt-out request to: marketing fyber com or clicking the “unsubscribe” link available thereto.

You can manage your cookies preferences through the setting of your browser.

9. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of Personal Information relating to third parties to which Fyber has disclosed Personal Information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact Fyber at: privacy fyber com

10. Accessing Personal Information Related to you

You can request access to Personal Information related to you.

GDPR fyber com and request to access the Personal Information that Fyber keeps on you. Fyber will need to ask you to provide credentials to make sure that you are who you claim to be. If you find that the details on your account are not accurate, complete or updated, then please provide Fyber the necessary information to correct it.

At any time, you can contact Fyber at: GDPR fyber com to receive a copy of the Personal Information that Fyber keeps about you, and to verify the accuracy of the data.

If you’d like Fyber to delete data that you provided through the Site, please contact Fyber at Marketing fyber com and Fyber will respond in a reasonable time.

Fyber retains and uses Personal Information related to you as necessary to comply with its legal obligations, resolve disputes and enforce Fyber’s agreements.

In addition, after Fyber deletes Personal Information related to you, residual copies will take a period of time before they are deleted from Fyber’s active servers and remain in its backup systems.

This deletion will not change or delete Personal Information which Fyber has already shared with third parties, as this Policy permits in this Policy or any other agreement between you and Fyber.

11. Your EU Data Subject Rights

In operating the Site, Fyber processes Personal Information as a data controller (as this term is defined in the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR)). As a data controller, Fyber is committed to fulfill data subjects’ (i.e. users) GDPR rights. This section applies to GDPR-covered processing of Personal Information.

We base our processing of Personal Information as a data controller on the following lawful grounds:

- All processing of Personal Information related to you which are not based on the lawful grounds indicated below, are based on your consent.
- We process your account and payment details to perform the contract with you.
- We will process Personal Information related to you to comply with a legal obligation and to protect your and others’ vital interests.
- We will rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
- Communications with you, including direct marketing where you are our client or a user of our client, or where you make contact with us through our Site and other digital assets;
  - Cyber security;
  - Support, customer relations, service operations;
  - Enhancements and improvements to yours and other users’ experience with our services
  - Fraud detection and misuse of the Service.

Access the data that Fyber keeps about you. Fyber will need to ask you to provide us credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you can provide us with the necessary information to rectify it.
CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL INFORMATION RELATED TO YOU. EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
Request to delete or restrict access to Personal Information related to you. Fyber will postpone or deny your request if Personal Information related to you is in current use for providing the Services or due to other legitimate purposes, such as compliance with regulatory requirements associated with Fyber.

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold Personal Information related to you, in accordance with this Policy, will act accordingly.

You can ask to transfer Personal Information related to you in accordance with your right to data portability.
You can object to the processing of Personal Information related to you for direct marketing purposes.
You have the right not to be subject to a decision based solely on automated processing , including profiling, which produces legal effects concerning you or similarly significantly affecting you.
You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en .

Fyber does periodical assessments of its data processing and privacy practices, to make sure that сайтplies with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.

If you have any concerns about the way Fyber processes Personal Information related to you, you are welcome to contact Fyber’s data protection officer at: GDPR fyber com , or write to Fyber to: Fyber GmbH, Wallstraße 9-13, 10179 Berlin, Germany.

Fyber will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you remain unhappy with the response you received, you can also refer the matter to the data protection authorities in Germany .

12. Data Retention

Fyber stores and retains Personal Information related to you for as long as you use the Site and/or remain subscribed to the Fyber newsletter or blog. Notwithstanding the foregoing, Fyber stores and retains Personal Information related to you for a reasonable time of up to 90 days after you stopped using the Site and/or unsubscribed to the Fyber newsletter or blog for internal reporting and analytics and improving the Site and/or any product or services provided thereto.

Fyber retains the information collected through the Site for so long as you use the relevant Fyber service or until you choose to unsubscribe from the Fyber mailing list (we include a link to cancel your subscription in every email that we send you), or until Fyber deletes Personal Information related to you following your request.

Fyber retains various types of Personal Information for longer periods pursuant to legal requirements under the applicable law.

Fyber will make efforts to guarantee that Personal Information is kept for no longer than is necessary for the purposes for which the Personal Information is processed.

In any case, as long as Fyber uses Personal Information related to you to provide the Services, Fyber will retain the Personal Information about you, unless a law requires Fyber to delete it, or if Fyber accepts your request to delete the Personal Information, pursuant to applicable laws, or if Fyber decides to remove it at its discretion.

13. Transfer of Data Outside your Territory

Fyber stores and processes Personal Information in various sites throughout the globe, including in sites operated and maintained by cloud based service providers. Fyber lists its sub-processors .

If you are a resident in a jurisdiction where transfer of Personal Information related to you to another jurisdiction requires your consent, then you hereby provide Fyber your express and unambiguous consent to such transfer or by using the Site you hereby provide your express consent to such transfer (as applicable).

If you are a resident of the European Economic Area (EEA), Amazon Web Services (AWS) Cloud processes and stores Personal Information related to you in the US on Fyber’s behalf in accordance with the highest degree of security of AWS.

To the extent necessary under EU privacy laws and regulations, Fyber will implement data onward transfer instruments, such as the Controller to Processor EU-US Standard Contractual Clauses, the Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles.

14. Information Security

Fyber is concerned about safeguarding the confidentiality of Personal Information related to you. Fyber and its hosting services implement systems, applications and procedures to secure Personal Information related to you, to minimize the risks of theft, damage, loss of Personal Information, or unauthorized access or use of Personal Information.

For example, Fyber limits access to Personal Information to authorized personnel who need to know that information in order to operate, develop or improve the Site.

These measures provide sound industry standard security. However, although Fyber makes efforts to protect your privacy, Fyber cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

15. Changes to this Privacy Policy

From time to time, Fyber will update this policy. If the updates have minor if any consequences, they will take effect 7 days after Fyber posts a notice on the Site. Substantial changes will be effective 30 days after Fyber has initially posted the notice.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Site. Continuing to use the Site after the new policy takes effect means that you agree to the new policy.

16. Contact Fyber

Please contact Fyber’s Data Protection Officer at: GDPR fyber com for further information.

Last Updated: June 11, 2018

II. The Fyber Services Privacy Policy

Fyber develops and operates several services in the ad-tech environment, such as a digital automated (“Programmatic”) ad exchange, mediation platform, Programmatic mediation platform, incentivized offer walls, direct sales service and other online advertising-related services, all of which include advertising management services, such as optimization, ad serving, campaign management and the compilation of relevant statistical data (collectively, the “Services ”).

This Policy explains Fyber’s privacy practices for processing Personal Information through the Services and it applies whenever you access or use a Property of a Supply Partner that is connected to and/or uses the Services.

The Services are not directed to children under 16 years of age and Fyber does not intentionally or knowingly collect Personal Information on such users.

1. The Services

We provide automated web-based advertising services.

Fyber provides advertisers, advertising agencies, Demand-Side Platforms and advertising networks (collectively, “Demand Partners ”) and website and/or mobile application/website developers and/or owners publishers (collectively, “Supply Partners ”); Supply Partners and Demand Partners are also referred to as “Customers ”) with the following Services:

Ad Exchange service , that enables Supply Partners to make their ad inventory available for purchase by Demand Partners for their ad campaigns through a Programmatic auction and for the winning ad of such auction to be served on Supply Partner;
Mediation service , that enables Supply Partners to optimize placement of ads by third-party Demand Partners on their website, mobile application or mobile website (collectively, “Property ”) and for Demand Partners to buy ad inventory and serve ads directly on such property;
Programmatic Mediation service , that enables Supply Partners and Demand Partners to use Programmatic auction for the sale and purchase of advertising space inventory on the Property;
Offer Wall service , that enables Supply Partners and Demand Partners to use an opt-in scrollable offers which includes individual Ads to integrate into Property.
Direct Sales service , that enables Supply Partners and Demand Partners to run ad campaigns on Properties.
From time to time, Fyber will offer ancillary services to the services described above and additional services.
Fyber has no direct engagement or interaction with the individuals that visit Customers’ services (users), except for the Fyber Offer Wall service where Fyber provides technical support to users of the Offer Wall on behalf of Supply Partner. When you contact Fyber’s customer support team for technical issues related to the Offer Wall, Fyber will process any Personal Information that you provide within the support request form, such as your name and email address to respond to your support request.
Fyber requires Customers to provide a privacy policy of their own, as required by the applicable legislation and, if required by applicable legislation, to also provide an adequate notice to Users about this Policy.

2. The Personal Information that Fyber Collects and Receives

We collect Personal Information from devices, Properties and partners.

Fyber collects Personal Information in order to provide the Services and for other specific purposes, as described in this Privacy Policy. Please note that you are not required by law to provide Fyber with any Personal Information.

Fyber only collects Personal Information that the Supply Partner had instructed Fyber to collect, in writing, prior to such collection, and subject to your permissions inside the Property and/or your mobile device.

As an example, if you use a Property with a Fyber’s Software Development Kit (“SDK ”) embedded in it, the SDK will only collect information that Supply Partner enabled Fyber to collect for the provision of the Services and in any case, the SDK will not collect your location data unless you affirmatively allowed/enabled the Property to collect it. Fyber also receives Personal Information through an application programming interface (“API “) integration between Fyber’s server and trusted third-party’s servers, and additional Personal Information by embedding tags on websites that you visit.

From time to time, Fyber may use additional or alternative tools to collect information. If Fyber’s use of a new tool impacts Fyber’s privacy practices, it will amend this Privacy Policy accordingly.

When interacting with the Property, Fyber may collect/receive the following information, which includes Personal Information:

Information about your device , such as device type and model, network provider, browser type, language.
Information about the Property , such as package name, key words, version.
Information about your operation system , such as Android, iOS.
Information about your mobile advertising identifiers , such as your Advertising ID (Apple IDFA or Google AAID).
Information that your device provides , such as device IP address, network connection type and device GPS location (only if you provide permission).
Information Fyber receives from Supply Partners , such as your age, gender, zip code, GPS location.
Information Fyber receives from Third Parties about you from sources other than the Property, such as non-precise device location based on IP address, device specifications and User’s interests.

3. What does Fyber do with Personal Information?

We provide, maintain and improve our services and for other lawful purposes.

Fyber uses the Personal Information that it collects and receives –

- to provide the Services;
- to enable and optimize the Services’ tools and features;
- to study and analyze the functionality of the Services, Customers’ and Users’ activities;
- to provide support;
- to measure the Services’ activity for pricing purposes;
- to maintain the Services;
- to improve the Services and to continue developing the Services.

Fyber uses the Personal Information to evaluate Users’ interests and behavior on a pseudonymous, no-name basis in order to be able to deliver tailored content If necessary.

Fyber uses Personal Information to enforce its terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

сайтmits to process Personal Information solely for the purposes that this policy describes. To the extent relevant and within Fyber’s technological and operational ability, Fyber will make efforts to maintain accurate information that is complete and up-to-date.

4. Sharing Personal Information with others

We share Personal Information with Demand and Supply Partners, with data enrichment sources, with our affiliates, with law enforcement and on a merger or an acquisition.

Fyber shares Personal Information for the following purposes:

Share it with its Trusted Demand Partners :

For the purpose of serving you with contextual ads, based on the content that you view or use on the Property, or targeted ads which are based on your preferences and online behavior, and that we believe can interest you.
For ad reporting purposes and for Demand Partners to have information about the performance of their ad campaigns and improve their ads performance over time.

Share it with Supply Partners:

To help them understand how Users are engaging with ads, the kind of Users are most engaging with types of ads on their Property, and what kind of ads are published on their Property;

Share it with Third Parties :

To receive additional data on you from sources other than the Property in order to help analyze and enrich the Personal Information that we collect about you, and serve you with more relevant ads on the Property and on additional online properties.
To receive Third Party’s services, such as fraud protection, bot detection, rating, analytics, viewability, geo location services, ad security and verification services.

Share it with Fyber’s corporate affiliates in order to provide the Services.

Share it with law enforcement and/or government agencies, courts, and/or other organizations : (a) as required by law, such as to comply with a subpoena, or similar legal process; and/or (b) when Fyber believes in good faith that disclosure/sharing is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

Share or transfer it if Fyber is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. Fyber will provide a prominent notice on the Site of any change in ownership or uses of this Personal Information if applicable. In any event, the entity which will assume the ownership of the Site will continue to protect Personal Information related to you under this Policy;

Share it in any other circumstances where Fyber receives your written consent ;

5. Aggregated and Analytical Information

Aggregated data is not identifiable. We use it for legitimate business purposes and may use standard analytical tools.

Fyber uses standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they use their own cookies to provide their service (for further information about cookies, please see the ‘Cookies’ section in this policy).

Fyber uses the standard analytics tools of Google Analytics and Fyber will use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html .

Fyber uses anonymous, statistical or aggregated information and shares it with its partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.

Fyber will share Personal Information related to you only subject to the terms of this policy, or subject to your prior consent.

6. Cookies

Yes. We use cookies.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

Fyber uses session cookies for legitimate purposes, such as facilitation of the use of the Property you use and its features and tools. Fyber’s cookies do not collect any Personal Information about you. Your device removes session cookies when you close your browser session.

When you visit a website, the cookie can recognize your device based on internal identifier of Fyber’s systems and in the future, if you return to that website, it can read that cookie to remember you from your last visit. By keeping track of you over time, cookies will be used by Fyber and its Demand Partners Advertisers to deliver ads targeted to you and track your engagement with these ads.

7. User Choice

You can disable your account, opt-out from location-based advertising, limit the use of tracking data for ad targeting, opt-out of our Demand Partners and delete cookies.

If you have an account in the Services, at any time, you can disable your account through your account page. Thereafter, Fyber will stop collecting any Personal Information from you.

However, Fyber stores and continue using or making available Personal Information that relates to you. For further information, please read the Data Retention section in this policy.

If you wish to opt-out from collection and use of precise location data for advertising, you can turn location services off through your device settings. The latest versions of iOS and Android allow you to limit which particular applications can access your location information.

You also can limit the use of identifiers for ad targeting on your devices. If you turn on this setting, apps are not permitted to use the advertising identifier to serve consumers targeted ads.

As an example, for iOS, the controls are available through Settings > Privacy > Advertising > Limit Ad Tracking. For Android, Google Settings > Ads > Opt Out of Interest-Based Ads.

Although this tool will limit the use of tracking data for targeting ads, companies will still be able to monitor your app usage for other purposes, such as research, measurement, and fraud prevention.

You can reset the identifiers on your mobile device in the device settings. iOS users can do this by following Settings > Privacy > Advertising > Reset Advertising Identifier. For Android, the path is Google settings > Ads > Reset advertising ID.

Following such restart, the device is harder to associate with past activity, but tracking can start anew using the new advertising identifier.

If you’d like to opt-out from Demand Partners’ use of Personal Information about you to serve targeted advertising to your mobile application, you can download the Digital Advertising Alliance’s mobile application for each of your devices and set your preferences in the mobile application.

If you reset the mobile advertising identifiers, you will also need to reset your preferences in the AppChoices applications.

If you delete all cookies, you’ll also delete the cookies that indicate your preference to opt out of targeted ads. Please note that even if you opt out of targeted advertising, a company will still use cookies for other purposes, such as to limit the number of times you’re shown a particular ad.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on the Services or through cross-site user tracking. The Services do not respond to DNT signals.

8. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of Personal Information relating third parties to which Fyber has disclosed Personal Information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact us at: privacy fyber com .

9. Accessing Personal Information Related to you

You can request access to Personal Information related to you .

At any time, you can contact us at: GDPR fyber com and request to access the Personal Information that Fyber keeps about you. Fyber will need to ask you to provide it with credentials to make sure that you are who you claim you are.

If you find that the details on your account are not accurate, complete or updated, then please provide us the necessary information to correct it.

At any time, you can contact Fyber at: GDPR fyber com and request to access the Personal Information that Fyber keeps about you, and to verify the accuracy of the data.

If you’d like us to delete data that you have provided through the Property, please contact Fyber at: GDPR fyber com and Fyber will respond within a reasonable time after receiving your email.

Fyber will retain and use Personal Information related to you as necessary to comply with its legal obligations, resolve disputes and enforce Fyber’s agreements.

In addition, after Fyber deletes Personal Information related to you, residual copies will take a period of time before they are deleted from Fyber’s active servers and will remain in Fyber’s backup systems.

This deletion will not change or delete Personal Information which Fyber has already shared with third parties, as permitted in this Privacy Policy or any other agreement between you and Fyber.

Fyber will make efforts to redact from the data which it will make available to you, any Personal Information related to others.

10. Your EU Data Subject Rights

Fyber is committed to fulfill data subjects’ rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

сайтmits to assist its controllers as to data subjects’ rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).

Under the GDPR, Fyber processes personal data as part of its Services as a data processor and the Supply partners are the data controllers. As a data processor, Fyber is committed to assist its data controllers to fulfill data subjects’ GDPR rights.

Therefore, if you wish to exercise your rights under the GDPR or have any questions in this matter, please contact the relevant Fyber’s controller directly.

11. Data Retention

We retain Personal Information as needed for legitimate and lawful purposes.

As a general practice, Fyber stores Personal Information related to you for as long as you use the Property and for a 30 days thereafter., Fyber uses Personal Information related to you in these cases for internal reporting, analysis and to provide the Services. Fyber saves and uses Personal Information related to you, for longer period of up to 90 days after you discontinue using the Property, and if Fyber needs Personal Information related to you for invoicing, reporting and discrepancy investigation reasons.

Fyber also uses and store Personal Information related to you to prevent fraud. Where Fyber suspects that the Property that you have used becomes vulnerable to fraudulent activities, Fyber will store and use Personal Information related to you, if needed, up to a year after you discontinue using the Property for fraud detection purpose.

Fyber is required to retain information, including Personal Information, by law. Aggregated data will be retained by Fyber for longer periods and through a third-party analytics platform.

Fyber will process Personal Information for no longer than necessary for the purposes for which the Personal Information was provided.

In any case, as long as Fyber uses Personal Information related to you to provide the Service, Fyber will keep the Personal Information about you, unless laws require Fyber to delete it, or if Fyber accepts your request to delete the Personal Information, pursuant to applicable laws, or if Fyber decides to remove it at its discretion.

As a Customer, as long as you use the Services, Fyber will keep Personal Information about you, unless the law requires to delete it, or if Fyber decides to remove it at its discretion.

12. Transfer of Data Outside your Territory

We store and process Personal Information in the US, in sites operated and maintained by cloud-based service providers.

Fyber stores and processes Personal Information in various sites throughout the globe, including in sites operated and maintained by cloud-based service providers.

If you are a resident in a jurisdiction where transfer of Personal Information related to you to another jurisdiction requires your consent, then you provide Fyber your express and unambiguous consent to such transfer.

If you are a resident of the European Economic Area (EEA), Fyber keeps your Personal Data on Amazon Web Services (AWS) Cloud in the US on Fyber’s behalf in accordance with the highest degree of security of AWS.

To the extent necessary under EU privacy laws and regulations, Fyber will implement data onward transfer instruments, such as the Controller to Processor SCCs, the EU-U.S. and Swiss-U.S. Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles.

Fyber implements other or additional onward transfer mechanisms, as available from time to time.

13. Information Security

Fyber implements systems, applications and procedures to secure Personal Information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

сайтmits to safeguarding the confidentiality of Personal Information related to you. Fyber and its hosting services implement systems, applications and procedures to secure Personal Information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

As an example, Fyber limits access to Personal Information to authorized personnel on a need to know basis in order to operate, develop or improve the Services.

While all measures provided reflect the current industry standard of security, Fyber cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

14. Changes to this Privacy Policy

Fyber will update its Policy from time to time after giving proper notice.

From time to time, Fyber will update this Policy. If the updates have minor if any consequences, they will take effect 7 days after Fyber posts a notice on the Services’ website. Substantial changes will be effective 30 days after Fyber’s notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Services. Continuing using the Services after the new policy takes effect means that you agree to the new policy.

Note that if Fyber needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

15. Contact Us

Please contact Fyber’s Data Protection Officer at: GDPR fyber com for further information.

Last updated: June 24, 2019

Наши службы можно использовать разными способами – искать и распространять информацию, общаться с людьми, а также создавать новую информацию. Когда вы предоставляете нам данные, например регистрируя аккаунт Google , мы используем их для того, чтобы усовершенствовать свои службы. Благодаря этим данным мы показываем более релевантные результаты поиска и рекламу, способствуем вашему общению и обеспечиваем возможность легко и быстро делиться информацией . В то же время мы хотим, чтобы вы четко представляли себе, как используются ваши данные и каким образом вы можете защитить их конфиденциальность.

Политика конфиденциальности объясняет:

какие данные мы собираем и зачем;
как мы используем собранные данные;
какие существуют варианты доступа к данным и их обновления.

Мы постарались изложить все как можно проще, но если вы не знаете, что такое файл cookie, IP-адрес, пиксельный тег или браузер, изучите сначала список основных терминов . Google серьезно относится к конфиденциальности ваших данных, поэтому независимо от того, новичок вы или опытный пользователь, обязательно ознакомьтесь с нашими правилами и при необходимости задайте вопросы .

Какую информацию мы собираем

Google собирает информацию, которая помогает улучшать наши сервисы, начиная с языковых настроек и заканчивая более сложными функциями. Например, мы можем находить для вас полезные объявления , контакты друзей и знакомых в Интернете или интересные видеоролики на YouTube.

Информацию мы берем из следующих источников:

Информация от пользователей . Чтобы использовать многие наши службы, необходимо иметь аккаунт Google. При его создании мы запрашиваем у вас персональные данные , например имя, адрес электронной почты, номер телефона или реквизиты кредитной карты , и сохраняем их в вашем аккаунте. Тех, кто желает задействовать все возможности совместного доступа, мы также просим создать общедоступный профиль Google , в котором можно указать свое имя и добавить фотографию.

Анализ ваших действий . Мы собираем информацию о том, как и какие сервисы вы используете. Это происходит, когда вы, например, смотрите видео на YouTube, посещаете веб-сайты, рекламируемые в AdWords или AdMob, или просматриваете или взаимодействуете с нашими объявлениями либо контентом. Эти данные включают следующее:

Уникальные номера приложений
В некоторых службах используются уникальные идентификаторы программ. Они вместе с информацией о приложении (например, о номере версии или типе операционной системы) могут отправляться в Google при установке или удалении службы, а также во время автоматических сеансов связи с серверами (при загрузке обновлений и т. п.).
Локальное хранилище
Мы собираем и храним данные (в том числе и персональные) на ваших пользовательских устройствах с помощью таких средств, как веб-хранилище браузера (включая HTML5) и кеш данных, используемых приложениями .
Файлы cookie и аналогичные технологии
Чтобы получать и записывать данные о том, как используются сервисы Google, мы применяем самые разные технологии, например можем добавлять на ваше устройство файлы cookie или аналогичные технологии . Таким же способом мы получаем статистику по сервисам, предназначенным для наших партнеров : обычно это решения для работы с рекламой и функции Google, реализуемые на внешних сайтах. Например, Google Analytics анализирует трафик на сайтах и в приложениях и может подключаться к другим нашим сервисам, в том числе использующим файлы cookie DoubleClick. В этом случае технологии Google позволяют совмещать собранную нами или владельцем аккаунта Google Analytics информацию с данными о том, какие сайты посещают пользователи и какие действия на них выполняют .

Как мы используем собранные данные

Благодаря полученным данным мы можем предоставлять , поддерживать , защищать , развивать существующие сервисы и создавать новые , а также обеспечивать безопасность Google и наших пользователей . Помимо прочего, эти данные нужны для того, чтобы более точно персонализировать контент, в том числе повышать релевантность результатов поиска и отображаемой рекламы.

Имя, которое укажет пользователь в своем профиле Google, может применяться во всех наших службах, где требуется аккаунт Google. При этом все предыдущие имена, связанные с аккаунтом Google, могут быть заменены в целях единообразия предоставления наших служб. Если ваш адрес электронной почты или иная идентификационная информация уже известна другим людям, они также смогут найти ваш общедоступный профиль Google, включая имя и фотографию.

Общедоступные данные вашего аккаунта Google (имя и фото в профиле), а также сведения о действиях, которые вы совершаете в сервисах Google или во внешних приложениях, связанных с вашим аккаунтом (например, об отзывах, комментариях и отметках +1), могут быть использованы нами в коммерческих целях, в том числе в рекламе. Мы не нарушаем уровень доступа и настройки конфиденциальности , которые вы используете в своем аккаунте Google.

Когда вы обращаетесь в Google, ваши сообщения сохраняются, чтобы мы могли решить проблему быстрее. Иногда мы присылаем на электронную почту пользователей уведомления о предстоящих изменениях или улучшениях в работе сервисов.

Данные, собранные с помощью файлов cookie, веб-маяков и аналогичных инструментов, позволяют функциональность и общее качество наших сервисов. Один из инструментов, который мы используем для этого, – Google Analytics. Например, зная языковые предпочтения пользователей, мы будем предлагать им версию того или иного продукта на их языках. При выборе персонализированной рекламы мы не связываем файлы cookie и различные идентификаторы с данными сугубо личного характера , такими как расовая принадлежность, религия, сексуальная ориентация или состояние здоровья.

Наши системы автоматически анализируют ваш контент (в т. ч. электронные письма), чтобы предоставлять функции, полезные вам. Это могут быть отобранные для вас результаты поиска, релевантные рекламные объявления выявление спама и вредоносных программ.

Как найти и изменить свои персональные данные

Если компания Google будет вовлечена в сделки по слиянию, поглощению или продаже активов, мы по-прежнему будем обеспечивать конфиденциальность всех персональных данных. Мы также уведомим всех заинтересованных пользователей о том, что их персональные данные будут раскрыты или регулируются теперь другой политикой конфиденциальности.

Защита информации

Мы делаем все возможное для того, чтобы обезопасить Google и наших пользователей от несанкционированных попыток доступа, изменения, раскрытия или уничтожения хранящихся у нас данных. В частности, мы делаем следующее:

Активно используем SSL-шифрование в наших службах.
Предоставляем двухэтапную аутентификацию для доступа к аккаунту Google и функцию Безопасный просмотр в браузере Google Chrome.
Постоянно совершенствуем способы сбора, хранения и обработки данных, включая физические меры безопасности, для противодействия несанкционированному доступу к нашим системам.
Ограничиваем нашим сотрудникам, подрядчикам и агентам доступ к персональным данным, а также накладываем на них строгие договорные обязательства, за нарушение которых предусмотрены серьезная ответственность и штрафные санкции.

В каких случаях применяется настоящая политика конфиденциальности

Наша политика конфиденциальности распространяется на все сервисы, предоставляемые компанией Google и ее дочерними компаниями, в том числе на YouTube, приложения для устройств Android и продукты, доступные на внешних сайтах (например, рекламные). Однако у некоторых продуктов есть собственные правила, не опирающиеся на эту политику конфиденциальности.

Политика конфиденциальности не действует в отношении служб, предоставляемых другими компаниями или частными лицами (включая продукты или сайты, которые могут отображаться в результатах поиска), сайтов, использующих службы Google, а также других ресурсов, на которые ведут наши ссылки. Также политика конфиденциальности не охватывает правила работы с информацией сторонних компаний и организаций, которые рекламируют наши службы и применяют для показа релевантных объявлений такие технологии, как файлы cookie, пиксельные теги и т. п.

Соблюдение закона и сотрудничество с государственными органами

Мы регулярно проверяем, как политика конфиденциальности соблюдается нами. Кроме того, мы используем несколько систем самоконтроля . Получив письменную жалобу, мы связываемся с ее отправителем и рассматриваем проблему. Если нам не удастся решить какой-либо вопрос о передаче персональных данных напрямую с пользователем, мы обратимся за помощью в местные государственные учреждения соответствующего профиля, включая органы власти, обладающие компетенцией в сфере защиты персональных данных.

Изменения

Время от времени наша политика конфиденциальности может изменяться. Однако мы никогда не будем ограничивать права пользователей без их явно выраженного согласия. Все обновления политики конфиденциальности отражаются на этой странице, а о самых значительных мы сообщаем особо (в случае с некоторыми службами – по электронной почте). Кроме того, для удобства пользователей все предыдущие версии этого документа сохраняются в архиве.

Продукты с особыми условиями

Ниже перечислены продукты и службы Google, в отношении которых действуют несколько иные меры обеспечения конфиденциальности.

Более подробная информация о нашей политике конфиденциальности относительно наиболее популярных сервисов Google представлена на этой странице .

Ресурсы о конфиденциальности и безопасности

Вы можете найти другие полезные материалы, связанные с конфиденциальностью и безопасностью, на странице Правила и принципы . Некоторые из них перечислены ниже.

Сведения о технологиях и принципах , в том числе следующая информация:
- какие технологии мы применяем в рекламе ;
На этой странице описано, какая именно информация передается от вас в Google и для чего она используется.
Проверить настройки конфиденциальности можно с помощью

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