Privacy Policy

(latest update: 24.05.2018)

Intro


This policy describes how Tamasenco Limited, having its legal seat at Gladstonos Str. M. Kyprianou House, 3rd and 4th floor, 3032, Limassol, Republic of Cyprus Tamasenco [Greece] and Tamasenco [Cyprus] (collectively described as hereinafter: “Tamasenco”, “we”, “us” or “our”) and its third party marketing and advertising partners collect, use, process and share information about you.


This Privacy Policy applies to all of our games, whether played on our website, www.tamasenco.com, on mobile devices, PCs or on other platforms such as Facebook. It also applies to our Marketing and Advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our "Services".


By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to Tamasenco’s and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.

Playing our games


By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of information about you by us. Most of this data comes directly from you or your device, such as device information, country and region, and game play information. We use this data to provide our games and Services to you, including for the purposes of optimization, preventing fraud, customizing in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.


Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made) and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.


In more detail, depending on which of our Services you interact with we may collect and process the following types of information:


Providing and optimizing our Services


We use your information to enable us to provide our websites, advertising and other Services to you and to optimize all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices.

Chat


Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to Tamasenco customer services or publicly on our forums. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.

Customer Services


We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.

Analytics and Research


We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.

Social and Community


We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.

Promotions and Competitions


From time to time we may run promotions or competitions during which we may collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We may also publish the names and entries of competition entrants. That information may also be combined with your Tamasenco Profile and other account information and will be processed, stored and shared in accordance with this Privacy Policy.

Cheating, Crime and Fraud Prevention


We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as the police.

Legal Uses


We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.

Visiting our websites


When you visit our other websites, such as www.tamasenco.com, and other websites and forums operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis. The information we collect and process about you when you visit our Websites includes:

Tamasenco Profile and Playing Socially


You can choose to add information to your Tamasenco Profile or to connect our Services to your account with a third party network (such as Facebook). If you do this, then your personal information will be visible to other players and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising.

Tamasenco Profile


When you play our games, we will give you a randomly generated unique identifier which we will associate with an account known as a "Tamasenco Profile". Your Tamasenco Profile will not be personally identifiable unless you choose to add your personal information to it, such as your name, avatar, email address or other information.


Your Tamasenco Profile and the information it contains will be visible to other users of our Services. If you choose to add personal information to your Profile it will be visible to your friends and other players anywhere in the world.


If you choose to view another individual's Tamasenco Profile, that individual and other users of our Services will know that you have visited them because some of your social information and a link to your Tamasenco Profile will be displayed on that individual's Profile.

Connecting with a third party network


Where we make this available, you can choose to log in to your Tamasenco Profile using your account details with a third party network, such as Facebook or Google. If you do this, you will be able to use your account to log in on multiple devices and synchronize progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play, asking other players for lives and 1-2-1 messaging.

Information we receive from Facebook


If you log in to your Profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your Profile. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.


We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your Profile. If you provide us with your email address we may from time to time use that email address to send you marketing emails about our other games and Services. You can opt out of this at any time - see Opting-out of direct marketing from Tamasenco below.


Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings. We would recommend that you read Facebook’s Privacy Policy and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.

Information we receive from Google


If you log in to your Profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture. If you choose to grant us access to your Contact List, we will use and store this to help you find those of your Google contacts that are already playing our games. You can revoke future access to your information at any time by following the steps at Use your Google Account to sign in to other apps or services. We would recommend that you read Google’s Privacy Policy and review your privacy settings from time to time to make sure that you understand fully how your Google data is shared.

Marketing


Unless you opt out as explained below, we and our third party partners may use information collected about you to send you marketing communications about other Tamasenco games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices. We may use the information that we hold about you to promote Tamasenco’s own Services in a number of ways. This might include:



What information do we use for marketing? We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:

Marketing partners


When we market our games in media published by other companies, we may use various third party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes.


Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Tamasenco’s games or Services, they will serve you with a Tamasenco ad while you are using other websites and services.


By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.


This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners’ privacy policies for more information. A list of our marketing partners and their privacy policies can be found here.


Opting-out of Direct Marketing from Tamasenco


You can exercise choices over the direct marketing we send you in the following ways:

You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for Tamasenco products, but that advertising will not be targeted using your personal information.

Advertising


Our games may include advertising for third party products and services. By accepting this Privacy Policy and downloading or continuing to play our games or use our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.


We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services.

What information is used for advertising?


We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:

Advertising partners


When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.


Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.


You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. Please feel free to contact us should you need to We recommend that you review our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found here. You can refuse or withdraw your consent to such use at any time - for more information, see How to adjust your preferences for interest based advertising.


Opting-out of interest-based advertising


You can choose to prevent your device's ad identifier being used for interest-based advertising by updating the settings on your device. For more information, see “How to adjust your preferences for interest based advertising” below.


Please note that if you opt out of interest based advertising, you will still be able to play our games and you may still see advertising in our games but those ads will not be targeted using information that we hold about you. However, they may still be delivered based on contextual criteria such as the game that ad is to be displayed in, or the region in which your device is located.


Ad identifiers, cookies and similar technologies


To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.


Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:

How do ad identifiers, cookies and similar technologies work?


Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.


Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.

How to adjust your preferences for interest-based advertising


You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings. If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.


Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).

Your Rights


You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below. Those rights include:

Right of Access

You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.


Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.


Right to Rectify Personal Information.

We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know at support@tamasenco.com and we will correct it as soon as we can.

Data Deletion

Upon request you have the right of deletion of your personal data that we hold about you as declared in GDPR - Article 17. Should you wish to have any information about you deleted, please Contact Us.


Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity.


We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.

Account Deactivation

If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device.


Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items will be lost and we may not be able to restore them in the future.


Data Portability

In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller. Please allow us a reasonable time frame of thirty (30) days to satisfy such request.


Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.

Right to Object

You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).


Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.


There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.

Children


You must be over a certain age to play our games and use our Services, depending on where you live (relevant age). We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the ages set out below relevant age, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.


Our games are intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our games or use our Services if you are under the relevant Relevant Age.


If you believe that we might have any information from or about a child under the relevant age set out above, please Contact Us. In the event that we learn that we have collected personal information from a child under the relevant age set out above, we will delete that information as quickly as possible.


General


Our Privacy Policy contains further details about:

Sharing

Security


Tamasenco takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.

Legal Bases


In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following:

Contractual Necessity


This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;


Legal Obligation


This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;

Legitimate Interests


This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimization of our games and other Services.

Consent


This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games; (ii) the storage of data on your device by us and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising above).


You consent to this collection when you accept this Privacy Policy and you can withdraw your consent to this processing by following the steps at how to adjust your preferences for interest based advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.


In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

Retention


We will keep your information for as long as your account is active, or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.

Location of storage


We store your information on servers that we control which are primarily based in the EEA. We may also use servers and engage providers that are located outside the EEA in order to process and store your information and to provide services to us.

International Transfer


We may transfer your information to affiliated entities or third parties to jurisdictions either inside or outside the EEA. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA.

Changes to this Privacy Policy


We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.

Contact us


If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting us:

You may at any time lodge a complaint at the competent Data Protection Authorities Authoritiy at the following addresses: