Ultimate Games S.A. Privacy Policy Last updated: 16 08 2023

This Privacy Policy explains how your personal data is collected and processed by Ultimate Games S.A. („Ultimate Games”) when you use our mobile applications (the „App”).

The App is a free-to-play game (with optional in-game purchases), and to maintain high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy, and, depending on the specific changes, we will provide you with additional notice or require renewed consent.

Collection of Information Information we collect automatically through the app When you access or use the App, we automatically collect general information about you, including:

  • Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times, and your IP address.
  • Device Information: We collect information about the device you use to access the App, including information about the device manufacture, device model, device’s OS, time zone of the device, and language of the device.
  • Device identifiers: We collect online identifiers of the device you use to access the App, including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID.
  • Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements, and interactions with other players.
  • Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

Use of information – purpose and legal basis We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

Log-, device-, usage-, and consumption information and device identifiers are being processed:

  • to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
  • to provide and maintain the App and the game experience; and
  • to send you technical notices, updates, security alerts, and support and administrative messages;

Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.

  • to provide news and information about the App that we think will be of interest to you;
  • to personalize and improve the App and provide tailored content and features;
  • to monitor and analyze trends, usage and activities in connection with the App;

Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services by Article 6(1)(f) of the GDPR (also known as „the balancing-of-interest rule”).

  • to provide users who have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) to serve them with a personalized advertisement in the App (behavioral advertising).

Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you by Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for behavioral advertising is based on your consent by Article 6(1)(a) of the GDPR (see more below under Sharing of Information).

Information from other sources is being processed:

  • to provide and deliver the products and services you request and send you related information;

Our processing for the above purpose is necessary for the performance of a contract to which you are party to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.

  • to link or combine information we get from others to help understand your needs and provide you with better service; and
  • to provide news and information about the App we think will be of interest to you;

Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services by Article 6(1)(f) of the GDPR (also known as „the balancing-of-interest rule”).

We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of information Ultimate Games will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.

Your data are deleted or anonymized as soon as it no longer serves one of the above-mentioned purposes and in any event no later than three (3) years after your interaction with Ultimate Games has ceased.

Sharing of Information We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):

  • Social networks, see more under „Social Sharing features”;
  • Third parties if we are required to disclose your data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Ultimate Games or others;
  • Other players to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service; Furthermore, if you have given your consent by Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
  • MoPub, Inc. https://www.mopub.com/legal/privacy/
  • MoPub, Inc. Partners https://www.mopub.com/legal/partners/
  • Facebook, Inc. https://www.facebook.com/about/privacy/
  • Google LLC https://policies.google.com/privacy
  • Applovin Corporation https://www.applovin.com/privacy/

In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:

Social sharing features The App offers or can offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated into the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

Children’s Use of the App is limited to users aged 13 years and above, except in the European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depending on what is applicable) or more years old.

Collection and Use of Data for Rankings and Leaderboards

Ultimate Games S.A. collects and processes specific data to create user rankings and leaderboards within the App. This feature is designed to enhance the competitive aspect of the game and provide users with a platform to compare their scores, achievements, and progress with other players.

The data used for this purpose may include:

  • Your game scores and achievements.
  • Your in-game username or pseudonym.
  • Any other in-game metrics that contribute to the ranking system.

By using the App and participating in the game, you agree to the collection and display of this data for rankings and leaderboards. If you do not wish for your data to be displayed in the leaderboards or used for ranking purposes, you may opt out through the game settings or contact us at info@ultimate.games.

If you have additional questions about Ultimate Games’s privacy practices related to children under the applicable minimum age, please contact us at ceo@ultimate-games.com.

Transfer to third countries In connection with the processing, we will in certain circumstances transfer your data to recipients outside the EEU.

We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.

Consequently, the transfers will only occur based on the following safeguards:

  • If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework („Privacy Shield”) (you can view the entities certified under Privacy Shield at https://www.privacyshield.gov/), or
  • If we have entered into standard data protection clauses adopted by the European Commission with the entity, which is deemed to offer sufficient safeguards concerning the protection of the privacy and fundamental rights and freedoms of individuals.

Security Ultimate Games takes reasonable measures to help protect information about you from loss, theft, misuse unauthorized access, disclosure, alteration, and destruction.

Push notifications We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications, and other related messages if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

Does Ultimate Games actually „sell” personal data? Ultimate Games does not, and will not, provide your data in direct exchange for money. Therefore, in the literal sense, Ultimate Games does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of information“, to the third parties for business purposes as explained under “Use of information – purpose and legal basis”.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at ceo@ultimate-games.com to exercise your right to withdraw your consent to share your data with third parties.

YOUR RIGHTS Rights of EEU residents We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access You have the right to request access into the data that we are processing on you, See Article 15 of the GDPR, including information about:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
  • the envisaged period for which the personal data will be stored. Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

The right to object You have the right to object to our processing of your data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights, and freedoms or if the processing is necessary for the establishment, exercise, or defense of legal claims.

You have the right to object to our processing of your data for direct marketing purposes at any time. We will cease the processing of your data for this purpose after the objection.

Right to rectification You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.

The right to restriction You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise, or defense of a legal claim or to protect a person or important grounds of public interest.

The right to withdraw consent If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.

If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

Rights of California residents We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.

Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide the data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Right to opt out Under CCPA each California resident can request any business stop selling personal information to third parties.

Right to be informed You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.

Right to disclosure You can request us to disclose what personal data we have collected on you in the past 12 months.

We can assure you that our Privacy Policy is a relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, the sources of your data, and how we use your data.

You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.

When providing information under the right of access, we will provide you with the following information:

  • The categories of personal data we are collecting about you,
  • The categories of sources of the personal data,
  • The purpose of collecting your data,
  • The categories of any third parties with whom we share your data,
  • The specific pieces of personal data collected about you. Right to deletion You can request us to delete the personal data we have collected on you in the past 12 months.

We fully recognize your right to deletion, however, we would like to note that in some cases we are obliged to keep your data for a certain period. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech, or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.

Data Deletion Request You may request Ultimate Games to erase without undue delay your data when it is no longer necessary for Ultimate Games to retain such data.

For your data to be erased you can contact Ultimate Games at ceo@ultimate-games.com with a request.

Right to equal services and prices California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you the App,
  • Charge you different prices or rates for the App, including through granting discounts or other benefits, or imposing penalties,
  • Provide you with a different level or quality of the App,
  • Suggest that you may receive a different price or rate for services or a different level or quality of the App. How to exercise my rights If you wish to use any of the rights described below, you may contact us at any time by emailing us at ceo@ultimate-games.com.

Mandatory verification: We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods. To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, changed the device you used to access the App or you already requested us to delete your data.

Contact Ultimate Games has the following contact information:

Ultimate Games S.A. Address:  Ul. Marszałkowska 87/102

00-683 Warsaw, Poland E-mail: ceo@ultimate-games.com

You may also contact your local data protection authority for unresolved complaints.