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 [email protected].

If you have additional questions about Ultimate Games’s privacy practices related to children under the applicable minimum age, please contact us at [email protected].

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 b