PRIVACY POLICY


Definitions:

  1. AddAppTr GmbH – AddApptr GmbH, Alsterufer 4, 20354 Hamburg, Commercial registry: HRB 124705 (Hamburg), support@addapptr.com;

  2. Application - mobile application owned by Simplicity Games;

  3. Google Advertising ID – advertisement display ID assigned by Google Play to Applications downloaded from Play Store, which enables displaying personalized advertisements to Users;

  4. Trusted Partners – AddAppTr GmbH;

  5. Simplicity Games – Simplicity Tomasz Dyrak, registered office in Rzeszów, al. Niepodległości 9, 35-303 Rzeszów, NIP 8133460207, REGON 181124003, e-mail: info@simplicitygames.pl;

  6. User - natural person using the Application;


§ 1.

  1. This Privacy Policy indicates the type of User’s data downloaded while using the Application, as well as the person who downloads the data and the purpose for which the data is used.

  2. Simplicity Games declares that it treats its Users’ privacy with special care.

  3. All Simplicity Games Applications are subject to this Privacy Policy.

  4. By using Applications, the User gives their consent to the terms and conditions in this Privacy Policy.


§ 2.

  1. Simplicity Games represents that, during the use of Applications, the company does not collect any data that would enable the identification of the User.

  2. Simplicity Games represents that, as of the installation of the Application on a mobile device, a special code is installed to download the Google Advertising ID of the device and collect data on an ongoing basis with regard to the Wi-Fi networks available for the device (hereinafter referred to as Data), which enables specifying the approximate location of the device at a particular time.

  3. Simplicity Games represents that the code mentioned hereinabove does not download any other data and it is a completely separate data flow channel, which technically precludes associating the data collected by the code with the data provided by the User while performing any other activities on the mobile device.

  4. Simplicity Games declares that the objective of Data collection is to:

  1. enable displaying personalized advertisements to the User on the widely understood Internet.

  2. produce statistics and marketing studies.

  1. The statistics and marketing studies mentioned in section 4b) are prepared solely based on data that precludes identifying the User.


§ 3.

  1. Simplicity Games does not take any actions related to downloading and collecting Data.

  2. All actions related to downloading and collecting Data are taken by Trusted Partners.

  3. Trusted Partners provide Data privacy protection based on 4 pillars:

  1. THEY DO NOT IDENTIFY the User (the User remains completely anonymous to the them);

  2. THEY DO NOT CONNECT Data (they do not connect obtained Data with any other Users);

  3. THEY DO NOT SHARE Data (they do not transfer User’s Data to any other entities);

  4. THEY DO NOT TAKE RISK with regard to Data (they apply the highest security standards).

  1. To obtain accurate information about collecting and processing Data, please read the Trusted Partner’s Privacy Policy: http://bit.ly/AddApptr-PP;

  2. Simplicity Games informs that data about the location of the device may (or may not) suggest the health condition, religious beliefs, political views or other sensitive information about the User. Regardless of the fact that Trusted Partners never identify specific people, Simplicity Games informs that Data sets shall never be searched and analyzed in terms of any data suggesting this kind of information.


§ 4.

  1. Subject to Articles § 2 and § 3 of this Privacy Policy, the basis for collecting and processing Data is the User’s consent.

  2. The User may grant their consent through selecting a relevant option during the installation and the first launch of the Application.

  3. Granting the consent is voluntary, however, it is necessary for the Application to work as its maintenance is financed mainly from advertisers’ funds.

  4. If the User refuses to grant their consent, the will have to leave the Application without the possibility to use any of its resources.


§ 5.

  1. Data about the location of the mobile device shall not be transferred to other entities.

  2. While ordering advertisements in entities providing advertisement display services (e.g. Google, Facebook), only the anonymous Google Advertising ID shall be provided. The Google Android operating system provides the possibility to reset the ID at any time.

  3. Data is deleted or irrevocably anonymized no later than a year after its collection.

  4. If Data is used for a specific marketing campaign, its deletion may be postponed by the end of the campaign, however, for no more than six months.


§ 6.

  1. Data is collected and processed without identifying the User.

  2. Due to the fact that Partners have access only to data from the location of the mobile and Google Advertising ID, the identification of the User may be a complex process, even if it is made at the request and with the involvement of the User.

  3. Regardless of the above, at any time, the User has the right to withdraw their consent for processing data by choosing the “Withdraw” option in the “Privacy” menu in the Application settings.

  4. The withdrawal of the consent by the User does not have any influence on the legality of the processing that took place in the past.

  5. If the User withdraws their consent, the collection of data from the mobile device on which the Application is installed will be ceased and all data related to the last Google Advertising ID will be deleted.

  6. The User may file a complaint against the collection and processing of Data to the President of the Personal Data Protection Office. 

  7. Subject to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, each person whose personal data is processed has the right to access, correct, limit, delete or transfer their data.

  8. The right to access, correct, limit, delete or transfer data may be executed only after a prior, clear identification of the User, which, as specified in section 2, may be difficult and in some cases impossible. Identification means associating the User with the Google Advertising ID of the mobile device. To identify the User, our Partners may request specific information and/or provide documents and the mobile device.


§ 7.

  1. In case of any questions and the need for information about the Privacy Policy, please contact us at the following address: info@simplicitygames.pl .

  2. Simplicity Games reserves the right to introduce changes into the provisions of this Privacy Policy.

  3. The last update of this Privacy Policy was introduced on 20 August 2018.