This policy applies to both my website and games, which I shall refer to collectively as the (“Service”).
Types of Data Collected
Among the types of personal data that my Service collects, by itself or through third parties, there are:
- Cookies (small sets of data stored in your machine or device)
- IP address
- Email address
- Operating system
- Mobile device identifiers (device ID, advertising ID, MAC address, IMEI)
Data may be freely provided by you or collected automatically when using my Serivce.
Unless specified otherwise, all data my Service requests is mandatory, and failure to provide this data may make it impossible for it to be provided. In cases where my Service specifically states that some data is not mandatory, you are free not to communicate this data without consequences to the availability or the functioning of the Service. If you are uncertain about which data is mandatory, you are welcome to contact me.
You are responsible for any third-party data obtained, published, or shared through my Service and confirm that you have the third party's consent to provide me the data.
Processing the Data
I take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The data processing is carried out following organizational procedures and modes strictly related to the purposes indicated. In addition, the data may be accessible to certain persons in charge, involved with the operation of my Service, as data processors by me.
Legal Basis of Processing
I may process data relating to you if one of the following applies:
- You have given your consent for one or more specific purposes. Note: Under some legislations I may be allowed to process data until you object to such processing (“opt-out”) without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the data processing is subject to European data protection law.
- Provision of data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Processing is necessary for compliance with a legal obligation to which I am subject.
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in me.
- Processing is necessary for the purposes of the legitimate interests I pursue or pursued by a third party.
In any case, I will do my best to help clarify the specific legal basis that applies to the processing, and in particular whether the provision of data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The data is processed locally and in other places where parties involved in the processing are located.
Depending on your location, data transfers may involve transferring your data to a country other than your own. To find out more about the place of processing of such transferred data, you can check the section containing details about the processing of data.
You are also entitled to learn about the legal basis of data transfers to a country outside the European Union (EU) or to any international organization governed by public international law or set up by two or more countries, such as the United Nations (UN), and about the security measures I take to safeguard your data.
If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquiring with me.
Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Data collected for purposes related to the performance of a contract between me and you shall be retained until such contract has been fully performed.
- Data collected for the purposes of my legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests I pursue within the relevant sections of this document or by contacting me.
I may be allowed to retain data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, I may be obliged to retain data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Purposes of Processing
Your data is collected to allow me to provide my Service as well as analytics and contacting you. I use it only for learning how I could improve certain aspects of my website. I will never ever sell your data to third parties who may use it for spam, stalking, or any other evil. You can find further detailed information about such purposes of processing and about the specific data used for each purpose in the respective sections of this document.
My Service collects data for two purposes:
To monitor and analyze web traffic for keeping track of user behavior, I use the following service:
Clicky (Roxr Software Ltd)
Clicky is an analytics service provided by Roxr Software Ltd.
Data collected are cookies and usage data.
By pressing the “Reach me now” button and sending me an email via your email program, you authorize me to use your email address to reply to information requests, quotes, or other kinds of requests.
Opting out of Targeted Ads
To opt-out of interest-based advertising on iOS apps, go to Settings > Privacy > Advertising of your device and enable “Limit Ad Tracking”. This even prevents the collection of mobile device identifiers.
The Rights of Users
You may exercise certain rights regarding your processed data. In particular, you have the right to do the following:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your data.
- Object to processing of your data. You have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent. There are further details in the section below.
- Access your data. You have the right to learn if I am processing your data, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your data and ask for it to be updated or corrected.
- Restrict the processing of your data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, I will not process your data for any purpose other than storing it.
- Have your data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your data from me.
- Receive your data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
- Lodge a complaint. You have the right to bring a claim before your competent data protection authority.
Details about the Right to Object to Processing
Where data is processed for a public interest, in the exercise of an official authority vested in me or for the purposes of the legitimate interests I pursue, you may object to such processing by providing a ground related to your particular situation to justify the objection.
You must know that, however, should your data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether I am processing data for direct marketing purposes, you may refer to the relevant sections of this document.
How to Exercise These Rights
Any requests to exercise your rights can be directed to me through the contact details provided in this document. These requests can be exercised free of charge, and I will address them as early as possible and always within one month.
Additional Information about Data Collection and Processing
I may use your data for legal purposes in court or stages leading to possible legal action for improper use of my Service. You agree to be aware that I may be required to reveal data upon request of public authorities.
Additional Information about Your Personal Data
System Logs and Maintenance
For operation and maintenance purposes, my website and any third-party services may collect files that record interaction with my website (system logs) and use other data (such as your IP Address) for this purpose.
Information not Contained in this Policy
I may request more details concerning the collection or processing of data at any time.
How “Do Not Track” Requests are Handled
This website does not support “Do Not Track” requests. To determine whether any third-party services I use honor the “Do Not Track” requests, please read their privacy policies.
My Service is not targeted towards users under the age of 13. I do not knowingly collect any data from anyone under 13. If I have learned I unintentionally collected data from users under 13, I will delete it.
Should the changes affect processing activities performed on the basis of your consent, I shall collect new consent from you, where required.
This privacy statement has been prepared based on provisions of multiple legislations, including Article 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). The section regarding age limits indicates my compliance with the Children’s Online Privacy Protection Act of 1998 (COPPA), 15 U.S.C. 6501–6505.
If you have any questions about this policy, feel free to contact me.
- May 20, 2019
- Replaced tracking system with Clicky
- Rewrote Analytics section to reflect the change
- March 27, 2019
- Removed AdColony as a third party ad network in games to simplfy number of providers
- February 25, 2019
- Removed Google Analytics as a third party tracker with a built-in, in-house solution to learn about users
- Rewrote the Analytics section to reflect the tracking system change
- August 14, 2018
- Added Third Parties section to address advertising, tracking, and purchasable content in games
- Established on May 27, 2018
Name of controller: Jon Kantner
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