Last updated: 4th of March, 2020
and how you can exercise your privacy rights. We are Premiumium Sp. z o.o., a private company
residing in Poland (“Premiumium” or “we”), a developer and publisher of mobile game applications that
are made available via app stores including the Apple App Store and Google Play Store. This Privacy
Policy applies to personal information that we collect through our games, mobile applications
to our processing of information as specified therein.
1. Information we collect from you
Most of the information that we collect about you comes directly from you when you play our Games
or interact with third-party ads in our Games or with our ads in other publisher’s Games. In general,
the information we collect about you relates to the type of device you are using, information that helps
us identify your device, how you play our Games and may include information that you submit to us when
you voluntarily contact us. We may also collect information from app store platforms and partners and
other third parties such as information about your interests and in-app purchases (provided that we
never receive your payment or credit card information).The information that we may collect about you
through the Services broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will
ask for certain information in order for you to submit enquiries to us, such as:your name, email address or
other details, necessary to process your inquiries; any information you submit to our support team via email.
The personal information that you are asked to provide and the reasons why you are asked to provide it, we
will try to explain to you at the point we ask you to provide your personal information.
Information that we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or
your device which may be considered personal information under applicable data protection laws,
Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Andorid Advertising
Identifier (“AAID”). These are unique identifiers for mobile device that advertisers use for
personalized advertising. They are consistent across all mobile applications and thus allow
cross-app tracking. On Apple, you can opt out of it by choosing “limit ad tracking” option in
your privacy settings. On Google Android, you can opt out of these ads by choosing
“Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers,
which are uniquely associated with your device.
Device identifier / information means device type, device model, device maker, device operating
system and its language or other technical data like screen size or processor, or combination of
this data available from a device for a developer for checking the device compatibility with a
Data and analytics about your use of our Services (e.g. in-game play progress, levels,
games played, session length, preferred settings, which in-game adverts you may have viewed,
in-game references or just game preferences, the means by which you were referred to our
Your IP address and device identifiers such as your Advertising ID, Device ID numbers
(for more see here “Advertising IDs and Device IDs”)
Your device type and the operating system that you use Broad geographic location
(e.g. country or city-level location) based on your IP address
Information we obtain from third-party sources
- Third-Party Social Network/s: Google Play Games Service, Apple Game Center.
Third party service providers. We may receive personal information about you from
third-party sources. We may get your personal information for example when you
installed our Game and prior to installing you have clicked an advertisement for the
Advertising partners. From time to time, we may also receive personal information about
you from other third-party sources. For example, if you clicked on an advertisement to direct
you to one of our Services (such as an advert of one of our Games in other publisher’s game),
we will be provided with information from which ad network and advertising campaign the
install originated from (See below also “Advertising”).
No special categories of information
We do not request or intend to collect any “special categories of
information” such as any information on health, race, religion, political opinions or
philosophical beliefs, sexual preferences or orientation.
2. How we use your information
2.1 In general
We use the information we collect about you/your device to deliver Services and our Games to you and to
operate our business. We use it also for improving our Services and Games, for enhancing security and for
analytics and research purposes to make sure we provide you with the best experience. In addition, we
use your information to promote our Services and Games in our Games and also in other publisher’s apps
and to display third-party advertisements to you. We use your information also for tracking and fraud
prevention for advertising purposes and for complying with our legal obligations.
We use your information for the following purposes:
Delivering and improving our services. We use your information for developing, delivering
and improving our Games and other products, services, and content, tailoring our products and
services, providing Game updates, technical troubleshooting, understanding and analyzing
trends in connection with usage of the Games, and administering the Games.
Displaying advertisements. We use your information for showing advertisements for our
Games in other publisher’s apps and for displaying third-party advertisements in our Games.
Cross-promotion. We use your information for cross-promoting our Games and services,
meaning to promote one of our Games while you are playing our different Game.
Tracking and fraud prevention for advertising purposes. We use your information for tracking
how our advertising campaigns perform and for identifying and preventing fraud for our
Analytics and research. We use your information for understanding and analyzing trends in
connection with the usage of the Games, gathering demographic information about our user
base, data about where the Game was downloaded from. We may also create reports and analysis
for the purposes of research or business intelligence, for example to track potential problems
or trends with our Games and services, or to test our new game features and content.
Security. We use your information for enhancing the safety and security of our Games, products and services.
Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations. We use your information when we are required to do so by law,
for example, we use your country or region for tax reporting purposes.
2.2 In-App Purchases
Our Games enable in-app purchases. We do not process payments for in-app purchases
nor have access to your credit card information.
Payment transactions for in-app purchases are completed through the app store via your
App Store account or Google Play account. Any post-purchase processes are controlled by the Apple
and Google stores and are subject to specific terms of such Apple and Google stores. Please review
3. How we share your information
We do not share your personal data with third parties without your prior consent.
We cannot provide all services necessary for the successful operation of the Games by ourselves.
We must, therefore, share collected information with third parties for the purposes of developing
and delivering our services, displaying advertisements, conducting analysis and research and for
measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose
your information (including personally identifiable information) when we are legally required to do so,
to disclose your information in an anonymous and aggregated manner, meaning you could not be personally
identified from it. We may share such information to:
Our analytics providers. We use third-party analytics such as Unity for the purposes of
delivering our services, conducting analysis, and research. The device data we share with
such providers are encoded. The providers may assign a random ID to these data and they are not
able to match it back to You. We can aggregate the data for benchmarking feature.
Third-party advertising partners. We have contracted with certain third-party advertising
networks that assist us in delivering advertising to you that allows us to continue offering the
Games for free or at low cost. Such third-party advertising partners include but are not limited
Advertising partner’s third-party tracking provider. We allow our advertising partners to
track impressions, clicks, installs or other advertising campaign performance indicators
through their tracking providers for the purposes of measuring their advertising campaign
performance. They may use their own third-party tracking providers.
Other third-party service providers. For our Games, we use Unity Software to develop such Games.
For the data processing by Unity please see
or change existing Partners in the future to perform any services in connection with the Games.
These changes shall be updated from time to time or promptly in case of material changes in our
data processing practices. We reserve the right to disclose your information (including personally
identifiable information) in response to law, legal process, litigation, and/or requests from
public and governmental authorities within or outside your country of residence. We may also
disclose information about you if we determine that for purposes of national security, law
enforcement, or other issues of public importance, the disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably
necessary to enforce our terms and conditions or to protect our operations, users or user
experience. Additionally, in the event of a reorganization, merger or sale we may transfer
any and all information (including personally identifiable information) we collect to the
relevant third party.
For any additional questions about third-party information collection,
please refer to email@example.com
3.1 Children data
We never knowingly or willingly collect any personal data concerning children under 16 years of age.
3.2 List of our parterns that may use the data
4.1 In general
We use advertising to fund our Services and to make our games available for free.
We offer our Games for free or at low cost and in order to do that we need to share information we
collect from you with our third-party advertising partners. As a safeguard to protect your privacy,
we only store personal information temporarily. The information collected helps us to improve our
Games. If you are an European Economic Area (EEA) – based user be aware that:
When you use our Games, we rely on our legitimate interest to show advertisements to you.
The legal basis to show ads to EEA-based users is the legitimate interest in accordance
with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we
evaluated together with our data protection officer. In addition, a data processing agreements
were concluded with external ad technology providers networks in accordance with the
requirements of Art. 28 GDPR .We also ensure that our external service providers are
committed to a high level of data protection by concluding data protection agreements.
We automatically share necessary informations regarding your device wit Unity
advertising provider. The Unity advertising provider by default shows you
personalized ads, but you can easily opt-out from personalized ads by clicking
Data Privacy icon which is shown with the corresponding ad – you can also delete
there any information that the Unity advertising provider stores about your device.
Before sharing any other information with different advertising partners for the purposes
of personalized advertising, we always ask for your consent, given when you press
accept at relevant button at loading of the Game. We allow our advertising partners
to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window
and so consented to the sharing of your personal information for the purposes of
personalized advertising. Our advertising partners use different technologies for the
purposes of personalized advertising that process your personal information in different
ways, so please review their data processing practices before you ACCEPT to show you
personalized ads at loading of the Game. The legal basis to show personalized ads to
EEA-based users is consent in accordance with the European data protection requirements
under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were
concluded with external ad technology providers networks in accordance with the
requirements of Art. 28 GDPR. We also ensure that our external service providers are
committed to a high level of data protection by concluding data protection agreements.
The purpose is to improve our Games and provide the player with more relevant ads.
You have an option to withdraw your consent to sharing your personal information for
the purposes of personalized advertising at all times. You can withdraw your consent
by going to the Game settings and clicking the terms & Privacy button therein, in
to manage your preferences by choosing to which advertising you would like to get.
When you decide to withdraw your consent or if you do not provide your consent, you
may still see the same number of ads on your mobile device; however, these ads may
be less relevant because they won’t be based on topics you like, your interest,
behavior, demographics, etc. Our advertising partners may continue to show you
ads based on the content of the application you are using.
4.2. In-game advertising (i.e. when you view ads in Our Games)
To enable us to show in-game ads, we send your advertising ID and IP-address to advertisers (or ad networks)
to enable them to find appropriate ads to serve to you in our games and on third-party properties. We do not
control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist
certain categories of ads. Advertising IDs are used by the ad networks for a number of purposes
(please refer to the Privacy Notices of our advertising partners listed here) including:
limit the number of times you see the same ad;
ensure they are dealing with humans with real devices and not ‘automated’ bots;
serve you with advertisements likely to be relevant to you based on your advertising ID
engagement with other brands and ads, also recorded using your advertising ID and using your
general geographic area. Other brands buy advertisement placement via an ad network or ad exchange
to advertise their products in Our Games. The ad network or ad exchange acts as intermediary
between the other game companies and Us. In order for an ad network to charge the company
buying the ad, clicks from the ad and potentially installs of other developers’ applications
party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;
keep track what games you have used to market you similar kind of games. IP-address is
typically used by advertisers to broadly see the general geographic area you are coming from
for example country, state, and sometimes at city level).
4.3. View of Our ads on third-party services
We also advertise Games in other apps by asking ad networks to serve them to audiences that will be interested
in them (determined using Advertising IDs).The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices
of our advertising partners listed “Third Parties”) including:
measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their
advertising in other publishers’ games);
informing players, that have not been playing for a while, about new content in the Game. We give a list of
these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about
the new content;
not showing ads on a game which a player is already playing. We can send a list of active players in the
form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad;
marketing games to a group of potential players.
5. Your rights
If you are EEA-based user you have certain rights in connection with your personal information and how we
handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise
these rights at any time by following the instructions below or sending us relevant requests
Your rights include:
Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you may withdraw your consent to show you personalized ads to you by clicking on Data Privacy icon while watching an ad (available to EEA-based users only))
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your email address has been changed and we should replace your old email address)
Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can do it by withdrawal of your consent in accordance with instructions above)
Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data if you want to upload it to another service)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly).
Your information privacy and security is important to us and we always pay special attention to ensure
that we process your information lawfully in accordance with one of the legal bases set out under EEA
data protection laws that apply to EEA users. We have appointed data protection officer to help us ensure
compliance with EEA data protection laws. We store your information for as long as needed to provide you with
our services. We may store information longer, but only in a way that it cannot be tracked back to you. We
operate globally and we share your information with our Partners as for the purposes described above in
“How We Share Your Information” Section, which may include a transfer of your personal information outside
7. Legal Bases
In each case where we process your information, we do so lawfully in accordance with one of the legal
bases set out under EEA data protection law.
The legal bases that we rely upon are the following:
Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Games (such as in-app chat feature, multiplayer feature, leaderboards and other third-party social network features), to deliver content of the in-app purchase you make.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Games free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes.
We have implemented appropriate technical and organizational measures to protect the confidentiality,
security and integrity of the collected information, and to prevent unauthorized access and the use
assure that your information remains secure when maintained by us, please be aware that no security
measures are perfect or impenetrable.
9. International Transfer
Your personal information may be transferred to and processed in countries other than the country in which you
are resident. These countries may have data protection laws that are different to the laws of your country.
This means that when we collect your personal information, we may process it in other countries. However, we
ensure appropriate safeguards are in place so that your personal information will remain protected in
accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual
Clauses for transfers of personal information between us and third party service providers and partners,
which require us to protect personal information they process from the EEA in accordance with European
Union data protection law. It also includes transferring personal information to third party service providers
and partners which are certified under the EU-US Privacy Shield.
We store your information for as long as needed to provide you with our services. We may store information
longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do
after your interaction with all of our Games has ceased. When required by law, we will retain your information
for as long as we are legally obligated to do so. If you request us to delete your data will delete your data
as described above in “Your Rights” Section.
information, and respond to legal and technical changes. The most current version of the Privacy
Policy will govern our use of your information and will be available at :http://www.premiumium.com/privacy-policy/.
12. Contact us