Zillion Whales Limited Privacy Policy

1. Who we are

1.1. We are Zillion Whales Limited, a British company, located at 1 Princeton Mews, 167-169 London Road, Kingston upon Thames, Surrey, KT2 6PT, United Kingdom of Great Britain and Northern Ireland (hereinafter Zillion Whales” or “We”).

1.2. This Privacy Policy sets out how we collect and use your personal information when you use any of our games, services and products (hereinafter “Services”). List of such Services is available, inter alia, on our website http://zillionwhales.com. Some of the Services may imply registration (authorization) therein by means of creating user account.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions at  http://zillionwhales.com/tos/ (“Terms”).

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

2. This Privacy Policy

2.1. This Privacy Policy is a document that explains what kind of your personal data we use, how exactly do we use it, for what reasons do we need your personal data and what rights do you have concerning your personal data.

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

(a) have all necessary rights to register on and use the Services;

(b) provide true, accurate, current and complete information about yourself;

(c) understand that by the posting your personal information, if there is such technical possibility in the Services and where it is accessible by other users of the Services, you have manifestly made this information public, and this information may become available to other Services users and internet users, be copied and disseminated by them;

(d) are at least 16 years of age or your parents agree that you use our Services;

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

2.2. Here are the cornerstones on how we view data privacy:

   we do not collect any data without your consent, legitimate interest or performance of our contract with you;

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

2.3. This Privacy Policy applies only to the European Union-based users. If you are not a European Union-based user, please refer to the Privacy Policy applicable in the relevant jurisdiction.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, 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, organize, extract, compare, use, and supplement your data (hereinafter processing”). We will also receive and pass this data, and our automatically processed analyses of 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

Purpose

Legal Basis

1

Data you provide for registering in the Services including your email and/or mobile phone number

We use this information in order to manage and administer the Services provided to you.

 

We use this data to enable us to fulfill our obligations to you as part of the Services (e.g. in cases where you request restoration of your account).

 

See section 8.3 of this Privacy Policy for more information.

 

We also use this information in order to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.

Legitimate interests

 

Performance of our contract with you

2

Where necessary, a copy of your identity or  another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and another additional data, with that you may provide us, including through our support service.

 

We may take additional verification steps where we consider reasonable in order to verify your account.

We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights.

 

For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.

Legitimate Interests

3

Additional data you provide when registering in/using the Services including your first and last name, nickname, gender, date of birth, avatar picture and language preferences.

We use this information in order to provide our Services to you, to manage and administer Services and as additional information to verify your account to prevent abuse and infringements of your or other persons' rights.

 

We also use this information in order to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.

 

We use this information in order to tailor and improve the adverts that may be presented on the Services and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Legitimate interests

 

Performance of our contract with you

4

Additional data received when you access the Services, including information regarding technical devices, technical interaction with the Services such as your IP-address, time of registration in the Services, device ID, country and language settings, device model and operating system used, your installed apps, screen resolution, RAM size and your in-app behaviour.

We use your data for internal review in order to constantly improve the content of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalize the use of our Services. We use this information in order to tailor and improve the adverts that may be presented on the Services and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Legitimate Interests

5

Information that is automatically received at the time of access to the Services with the use of cookies.

Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for.

 

We use this information in order to tailor and improve the adverts that may be presented on the Services and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Consent

6

Information that is created by you while using the Services (if there is such technical possibility in the Services) this information can be available to some or all other users of our Services.

We use this information in order to manage and administer the Services including providing our services to you.

Legitimate Interests, which inter alia, include the processing of manifestly made public by you data where it is accessible by other users of the Services

 

Performance of our contract with you

7

Information that is received as the result of your behavioural actions when using the Services, that is received as the result of your using payment functionality of the Services (e.g. first and last four digits of your card number that are required in order to match these details with your account), etc.

We use this information in order to manage and administer the Services including providing our services to you.

 

We use this information in order to tailor and improve the adverts that may be presented within the Services and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.

Legitimate interests, which inter alia, include the processing of manifestly made public by you data where it is accessible by other users of the Services

 

Performance of our contract with you

8

Information that is created by you while placing requests to our Services support.

We use this information in order to verify your identity and to fulfil your support request.

 

We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

Legitimate interests

 

Performance of our contract with you

9

Data collected via third parties, including your social network ids, application store ids, nickname, email and friends list, when you register in our Services via you social or application store accounts and/or connect your social account to our Services (e.g. Steam, PSN, Xbox Live, Game Centre, Facebook, Twitter etc.).

We use this information in order to manage and administer the Services provided to you.

 

We use this information for certain social functions of our Services.

 

We also use this information in order to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.

Legitimate Interests

 

Performance of our contract with you

3.3. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law. 

3.4. As part of maintaining and administrating the Services we use the information to analyze user activity and ensure that rules and terms of use for the Services are not violated.

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 defense 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. You may withdraw your consent to sending you marketing information by amending your privacy settings of your account (if any). An option to unsubscribe will also be included in every SMS or email sent to you by us or our selected third party partners.

3.7. 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 post this information or share this data on the Services. Once you have provided this data it will be accessible by other Services users and it becomes difficult for us to remove this data.

3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages.

3.9. 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 take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information (if there is such technical  possibility in the Services and where it is accessible by other users of the Services) you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users.

4.2. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms. 

4.3. We may also share your data with our third party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by your use of the applications they offer.  The developers use the information provided to them in order to provide you with additional services. Data will only be shared with these developers with your consent. You can authorize developers to access your information via our Services.

4.4. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party 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, e.g. cars or fashion. If you fall within one of the target groups you will receive an advert or recommendation.

4.5. An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches.  They will see the number of matches but not the matches themselves.

4.6. Zillion Whales Limited, 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. Cookies and similar technologies.

5.1. We do not use any browser cookies, but we use Analytics and Advertising technologies in our products that utilize the cookies - pieces of data and technologies that help to identify you and your devices, which in turn can help personalize an experience, including the ads that are displayed, prevent fraud, and store preferences. These technologies are described below.

6. Privacy Settings

6.1. The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

6.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.

6.3. We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Services.

7. International Transfers

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

7.2. 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.

8. Retention Periods

8.1. 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.

8.2. You may delete your personal data by contacting us via e-mail hello@zillionwhales.com.

8.3. We may remove your account (if any), or the information you post as provided by the Terms.

9. Your Rights

9.1. You have the following rights, in certain circumstances, in relation to your personal information:

   Right to access your personal information: at any time, you can ask us about what your personal data do we have, what do we do with them, why do we process them, who we have told about you, etc. You also can ask us to give you a copy of the personal data processing, if you like. To request access, send us an email at hello@zillionwhales.com headed "Subject Access Request";

   Right to rectify your personal information:  at any time, you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or there is no need to proceed it anymore;

   Right to erasure: at any time, you can ask us to delete all the personal data that we have about you – it is your right to be forgotten, like if we have never met before. We will also deactivate your account. If you do so, you will no longer have access to the games you used to play associated with your account;

   Right to restrict the use of your personal information: for example, if you think, that your personal data is not accurate and we need time to check it, we can make a pause in processing of your personal data enough to clarify, is it so or not. If you do not request deletion, then it is possible to request the reactivation of your account if it was accidentally or wrongfully deactivated. Please, note, that we cannot restore permanently deleted accounts;

   Right to object to processing of your personal information: at any time, you can tell us to stop and we will no longer process your personal data, but we can still keep them;

   Right to data portability (in certain specific circumstances): if you wish, you can ask us to download (export) all personal data that we have in the format acceptable to give it to someone else or ask us to give them your data directly;

   Right not to be subject to an automated decision: if the fact that we process your personal data automatically and we make some decisions according to it, and it affects you in any serious way, you can express your point of view and contest such decision;

   Right to lodge a complaint with a supervisory authority: you always can complain about us and about the way, we are processing your personal data.

9.2. If you would like to exercise these rights, please contact us at hello@zillionwhales.com or send your request to us, in writing to address defined in clause 1.1 of this Privacy Policy. 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.

10. Security Measures

10.1. 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.

10.2. Access to the Services is authorized using your login (e-mail address or mobile phone number) and password if applicable. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential. 

10.3. If you forget your login details, you can request us to send you an SMS or email, which will contain a restoration code.

10.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your account. 

11. Changes to this Policy

11.1. 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 change.

12. Contact Us

12.1. If you have any questions, please send your inquiries to hello@zillionwhales.com or in writing to 1 Princeton Mews, 167-169 London Road, Kingston upon Thames, Surrey, KT2 6PT, United Kingdom. So we can deal with your inquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request. 

12.2. 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.

DPO contacts:

Name, surname: Olga Butyagina

E-mail: olga@zillionwhales.com