Privacy Policy

Immortal Games Limited (hereinafter referred to as “IG”, “we”, “us”, or “our”) is dedicated to protecting the privacy of our users and handling any personal data obtained from users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.

This Privacy Policy (hereafter referred to as the “Privacy Policy” or “Policy”)) is applicable where the IG acts as a data controller with respect to the data we collect from you. This Privacy Policy will explain how we use the personal data we collect from you when you use our mobile game applications (also referred to as the “games” or “game”) or the official website of IG with the domain name https://immortalgames.co.uk/ (hereinafter referred to as the “website”). Providing access to the games and the website is collectively referred to as the “Services”.

1. What is the legal basis for processing your personal data?

The legal basis for processing your personal data is your freely given consent.

When you download and first access the game of IG on your mobile device, you will see the banner that will offer you to follow the URL links and read our Privacy Policy and Terms of Service and will include the button “Confirm”. Before you start using the game of IG, you shall read our Privacy Policy and Terms of Service and press the button “Confirm”.

By pressing the button “Confirm”, you provide IG with express and unambiguous consent to the processing of your personal data in accordance with this Policy and the provisions of General Data Protection Regulation 2016/679 (GDPR).

You cannot start using the game of IG before providing us with consent to the processing of your personal data. If you do not agree to the processing of your personal data in accordance with our Policy and do not press the button “Confirm” or put a tick in the box, you will not be provided with the opportunity to use the game. In this case, we will not process your personal data.

Processing of your personal data is necessary for providing you with the Services.

When you open the website of IG, you have an opportunity to use the “Feedback” tab to contact support via the form provided there. When you contact us, you provide us with express and unambiguous consent to the processing of your personal data necessary for providing the answer to your letter.

2. Who is the controller and the processors of your personal data?

For the avoidance of doubts, IG determines the purposes and the means of the processing of your personal data (“controller”). IG is a legal entity incorporated in accordance with the laws of the United Kingdom under company number 11876063 with the following address of registration: Companies House: A And L Suite 1-3 Hop Exchange 24 Southwark Street, London, SE1 1TY, England.
Trading address: 3rd Floor, 86-90 Paul Street, London , EC2A 4N.

For the avoidance of doubts, IG implements all the technical and organizational measures necessary for securing your personal data from unauthorized use.

Besides, we have the following categories of processors that interact with your personal data:

3. What personal data do we process and how?

IG collects information when you start using our Services. This information relates to how you use our Services including the type of device you use, and may include information that you submit when creating an account with us or through your social network accounts.

Particularly, when you download and start using our game, the SDK integrated into the game receive access to Identifier for Advertisers (IDFA) (if the mobile application is distributed via App Store and available on iOS operating system) or Google Advertising ID (if the mobile application is distributed via Google Play and available on Android operating system) of your mobile device (hereinafter referred to as the “Device ID”). Such Device ID tracks all the behavioural information about you that relates to your use of the game. Particularly, by use of Device ID we can automatically receive the information on your progress inside the game, on your interactions with other players of the game, on the virtual items you purchase via the game (either for free or for real or virtual currency), on the rewards you receive via the game, on your scores or achievements via the game, and other gameplay data. For the avoidance of doubts, we do not collect any information on other mobile applications installed on your mobile device.

Besides, the SDK integrated into the game allow IG to automatically collect the following data:

  • IP address of the device;
  • device name and operating system;
  • language settings;
  • precise location data (your actual GPS position), if you provide us with the consent to the processing of such personal data

Whether or not you create an account inside the game, we can receive the following information from you:

  • language preferences;
  • music and sound settings;
  • player’s nickname;
  • the information on the amount of money you spend on in-app purchases

In order to save the progress of the game (gameplay data) on your mobile device, you have an option to create an account via the game. You can create the account by registering inside the game or by linking the game to your social network account (such as Google Play account, Facebook page etc.). In this case we can process the following personal data that you provide to us:

  • ID of your social network account (Google ID, Facebook ID etc.); the social network that holds your social network account can also share your GPS position or general location data (the country of your residence) with us if your account settings allow to do so;
  • your real name or nickname;
  • the photo of your social network profile;
  • your age and gender;
  • your contact information (such as email, phone number etc.)

Besides, you can write a message to IG through our games. In this case we can process the information you provide to us and the information on chat logs and player support tickets. Additionally, we can process the information you provide to us which helps to identify your lost account of the game.

If you exchange messages with other players via the game, IG may also store your conversation history with other players, including chat logs.

If you send a complaint to us stating that you in-app purchase was not successful (for example, you did not receive the virtual item you had purchased, or the system debited the excessive amount of money from your account) or ask us to delete or restore you in-game account, we can process the following personal data:

  • identification information on your in-game account (including Facebook or Google ID);
  • payment details (meaning the information about the transaction itself); we do not process the information on your bank account or credit/debit card

We can also process other types of information that you willfully provide to us in order to verify your in-game account.

If you do not provide us with the identification information on your in-game account, payment details, or other types of information necessary to identify your account, IG reserves the right not to resolve your issue (refuse to delete or restore your account or reply to your complaint on in-app purchase), subject that it is not technically possible to resolve your issue without processing your personal data.

If you email us via the website, we can store the history of the conversation with you and use your message and the information from the message to provide you with the answer to the message.

4. Why do we process your personal data?

We use personal data and other information about you for the following purposes:

  • to provide you access to the Services and associated games and services, and continuously improve their features;
  • to operate the games and customize your player experience;
  • to store your game settings, gaming-history, and provide personalized content of the games;
  • to provide player support services;
  • to analyze and optimize the functioning of the games;
  • to respond to your comments and questions with the games and provide player support;
  • to enable in-game purchases;
  • to provide relevant advertisements and to send you promotional messages by email or other communications;
  • to enable social network integration;
  • to provide competitions via the games;
  • to prevent cheating, fraud, and other types of crime aimed at illegal obtaining of information or stealing your assets;
  • to meet legal and tax obligations

We need to use the IP address and the Device ID of your mobile device to tailor and improve the advertisements that may be introduced to the games and measure the effectiveness of these advertisements. Particularly, we may use the behavioural data tracked on the Device ID for the purpose of users’ segmentation and determining the “look-a-like” type of the user.

If you create an account via the game, we may use the personal data you provided to us for the following purposes:

  • to assist you in creating accounts via the games and allow you to play our games;
  • to update and develop player profiles;
  • to verify and confirm payments of the users;
  • to send you security alerts and support messages;
  • to enable you to communicate with other players of the games

5. How do we store your data?

We use Firebase database that is part of Google Cloud Platform. Firebase is a platform developed by Google for creating mobile and web applications. When we use Firebase, Google is generally the data processor under GDPR and processes personal data on their behalf. We store your personal data there for as long as your account is active or as needed to provide you with the Services. We will periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.

6. Are there any recipients of your personal data?

We do not provide personal data to any other body (either natural person, or legal entity, or public authority) for commercial or marketing purposes, except if you explicitly give us permission to do so, or if doing so is a part of a specific program or operation for which you have registered or applied. In such a case, you may withdraw your permission at any time.

Our ad management and recommendation system is designed so that your information is not shared directly with our advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type. If you fall within one of the target groups, you will receive an advert or recommendation.

Besides, other users of our games can see your in-game account data and your in-game activities (for example, the level of your character in the game or your game progress). They may also read the messages you post in a public chat or write in a personal chat and reply to such messages.

7. Cookies

Cookies are files containing a small amount of data that are commonly used on websites as anonymous unique identifiers. Sites you visit send these files to your browser, and they are then stored on your device’s internal memory.

This Service does not use cookies explicitly. However, the app may utilize third-party code and libraries that use cookies to collect information and improve their services. You have the option to either accept or refuse cookies and to know when a cookie is being sent to your device. If you choose to refuse cookies within Story Games, you may not be able to use some elements of this Service.

Cookies are files containing a small amount of data that are commonly used on websites as anonymous unique identifiers. Sites you visit send these files to your browser, and they are then stored on your device’s internal memory.

8. What are your data protection rights?

IG would like to make sure you are fully aware of all of your data protection rights. Every personal data subject is entitled to the following:

The right to access – You have the right to request us for copies of your personal data. We may charge you a small fee for this service. Besides, you have the right to request IG to provide you with the information on whether your personal data is being processed, and on the aspects of processing your personal data (namely, the information about the purposes of personal data processing, the categories of personal data processed, the categories of recipients of your personal data, the period during which your personal data is processed, the sources from which your personal data is collected, and your rights that you granted in accordance with GDPR).

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

You may send the request aimed at exercising your rights provided herein to our email info@immortalgames.co.uk or to our business address: 3rd Floor, 86-90 Paul Street, London, EC2A 4N, UK.

If you make a request, we have one month to respond to you. If you would like to exercise any of your rights, please state clearly in the request what information you would like to know, rectify, or erase. This request needs to be signed and dated and contain a copy of the front side of your identity document.

You can also withdraw your consent to the processing of your personal data. Please note that if you do so and do not have the access to the data that we need to maintain and administer the Services, you may not be able to use the Services and/or get registered at it.

Besides, you have the right to lodge a complaint with a supervisory authority of the state of your habitual residence, or of the state where your workplace is located, or of the state where the place of an alleged infringement of GDPR is located, if you consider that processing of your personal data by IG or its processors infringes GDPR. Exercising such rights does not preclude you from using other administrative or judicial remedies.

If you are not satisfied with the decision of the supervisory authority, you have the right to an effective judicial remedy against the decision of such supervisory authority. The exercising of such right depends on the procedural law of the state in which the supervisory authority is established.

You also have the right to an effective judicial remedy against IG or its processors if you consider that processing of your personal data by IG or its processors infringes GDPR. In this case, the lawsuit against IG or its processors shall be brought before the courts of the states where IG or its processors are established, or, alternatively, before the court of the state of your habitual residence.

9. What security measures are applied by IG and its processors?

IG and the processors of IG have applied all reasonable and appropriate technical and organizational measures to ensure that your personal data is processed securely.

Particularly, when your personal data is stored in the Firebase Database only a limited number of employees of IG have access to the personal data provided that they signed confidentiality agreements. Such employees receive access to your personal data, only if their employment relationship obligations require them to process your personal data.

10. How can we change this Privacy Policy?

IG reserves the right to amend this Privacy Policy at any period of time. Amendments will be effective as of the moment of publication on the website of IG. You should check the website of IG regularly for tracking such amendments.

 

This Privacy Policy was last updated on 18 October 2021.