Privacy Policy

Premiumium Sp. z o.o. Privacy Policy

Last updated: 4th of March, 2020

This Privacy Policy explains who we are, how we collect, and use personal information about you, 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 (“Games”, „Services”). By using our Services, you agree to be bound by this Privacy Policy and consent 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:

  1. 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.

  2. 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, such as:

    • 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 Services)
    • 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

    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 particular application.

  3. 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 same Game.
    • 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”).

  4. 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:

  1. 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.
  2. 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. Please see more in Advertising Section of this Privacy Policy.
  3. 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.
  4. 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 advertising campaigns.
  5. 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.
  6. Security. We use your information for enhancing the safety and security of our Games, products and services.
  7. Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
  8. 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 privacy policy and terms of service of your Apple and Google stores.

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:

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. Advertising

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:

  1. 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. 
  2. 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. Please refer to Unity’s privacy policy: Unity’s privacy policy
  3. 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 section Personalized Ads Consent Withdrawal of the Privacy Policy you will be able 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:

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:

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 to info@premiumium.com

6. General

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 of the European Economic Area (the “EEA”). Please check regularly for changes to our Privacy Policy.

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:

8. Security

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 of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to 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.

10. Retention

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 not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years 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.

11. Changes to our Privacy Policy

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current 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/. For previous versions of this Privacy Policy, please contact us via info@premiumium.com

12. Contact us

If you have questions or concerns about this Privacy Policy, please contact us through info@premiumium.com