This Privacy Policy has been introduced on the 1st of August 2023.
BY DOWNLOADING, INSTALLING AND/OR USING THE APP AND MAKING IN-APP PURCHASES YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY STOP USING THE APP AND UNINSTALL IT, AS WELL AS DO NOT PROCEED TO MAKE IN-APP PURCHASES.
VRNGames is a private company incorporated in Poland (hereinafter “the Company” or “we” or “us”, unless otherwise provided herein), that shall be the controller and the entity responsible for your personal data.
This Privacy Policy is General Privacy Policy, and applies to information we collect about persons who use mobile application software published by the Company (hereinafter “App” or “Apps”).
We do our best to follow and comply with the privacy law of those jurisdictions where the users of the Apps are located. As the Company registered and doing business in an EU country, we abide an EU regulatory framework, including General Data Protection Regulation (GDPR).
In the event that you have downloaded and installed the App from a third party, you must also refer to that third party’s Terms and Conditions of Use and Privacy Policy which may apply in addition to our own Privacy Policy.
In accordance with the applicable regulatory framework governing personal data protection pursuant to the laws of the Republic of Poland, and/or EU law, and/or any other applicable law of the countries where we offer Apps and services, we maintain a privacy policy embodied in the present Privacy Policy with a view of providing a general outline of what you should expect in respect of the collection and processing of personal data and information (hereinafter “personal data” or “personal information”) that you may be asked to submit or supply in the course of using any App published by us, and of the intended use of such personal data by us, our affiliated companies, contractors and subcontractors or by any third parties.
The provision of your data is voluntary, however, please note that if you do not provide us with the required personal data, we may not be able to provide the information, products or services you need or process your request. You are strongly urged to read the present Privacy Policy carefully and make sure that you agree with the contents thereof.
In case GDPR applies, we may lawfully process your personal data only if and to the extent that at least one of the following applies:
In case a different regulatory framework applies, we’ll do our best to comply with its requirements for the processing of personal data.
In accordance with the applicable regulatory framework we may collect, use, share and otherwise process your personal data solely for the purpose for which these have been provided by you and for no other purpose.
We may collect, use, share and otherwise process your personal data for the purposes of:
In most cases the processing is necessary for the performance of a contract to which you are a party or within our legitimate interest.
In case processing of your personal data is based on art. 6 (1)(a) of GDPR (i.e. based on consent) we will ask your consent for processing your personal data.
Based on contract performance and/ or based on our legitimate interest, we use the following processors to process your personal data for analytics and / or measurement purposes:
| Processor | Location and destination of a service | Privacy Policy (link) |
|---|---|---|
| Adjust | an analytics service provided by Adjust GmbH (Germany) | https://www.adjust.com/privacy-policy/ |
| Amplitude | an analytics service provided by Amplitude, Inc. (USA) | https://amplitude.com/privacy |
| Firebase | an analytics service provided by Google Inc. (USA) | https://www.google.com/intl/en/policies/privacy/ |
| Firebase Crashlytics | a real time crash reporting tool provided by Google Inc. (USA), helps Us prioritize and fix most pervasive crashes based on the impact on real users | https://www.google.com/intl/en/policies/privacy/ |
| Google Analytics | an analytics service provided by Google Inc. (USA) | https://policies.google.com/privacy (For more information visit the site “How Google uses data when you use our partners' sites or apps” available at https://policies.google.com/technologies/partner-sites) |
Personal data, or personal information, means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data does not include data where the identity has been removed (anonymous data).
Each time you use the App we may automatically collect the following information:
Please note that you may not be able to make use of the App unless we access and collect the aforesaid personal information.
When you address an inquiry or issue to our customer service team via our App, You will be asked to provide us with your full name and email for the purpose of contacting you within the inquiry you are addressing to us. We assume that the personal information provided is accurate. However, we are not in a position, nor do we intend to verify whether the personal information you have provided is accurate or to confirm your identity.
To comply with your privacy request, we will ask you to provide us with your game ID associated with our App and / or a screen capture from your device containing such game ID for the purpose of verifying your request.
If you object to the collection and use of such personal information by us in this way, you should refrain from downloading, installing and/or using the App. In the event that you have already installed, downloaded and/or using the App, you can always stop us from collecting such information by uninstalling or removing the App from your device.
We do not collect any Special Categories of Personal Data about you or Personal Data that may be defined in the applicable regulatory framework as sensitive personal information (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.).
When you make inner purchases in the Apps, we may automatically collect data about types of your purchases and currencies.
We may use GPS technology and/or other relevant technologies to determine your current location. We do not use it now. However, we may automatically collect the information that can be defined as information of location nature from your device or from any third party in the course of calculating your estimated location (not precise geolocation data, rough geolocation data). You can always change your location sharing options by visiting App settings and/or turning off the location services settings on your device.
For the purposes of promoting the App, we may also wish to use any comments or reviews that you may make on the App’s official page on any App Store or on any social networking sites (“the Social Networks”) or sent to our customer service team via email. In case any of your comment or review is posted or otherwise shared by you on the App’s official page on an App Store or on any publicly available page of any Social Network, we consider it as publicly available and may repost it without your additional consent. But we will always ask for your express, unambiguous consent before using any of your comments or material uploaded, posted or otherwise shared by you with us privately on the Social Networks or sent to our customer service team via email. In the event that you authorize us to do so, we may use your comments or reviews in full or in part and we may also use your name, user or profile name on the Social Network in question. You may revoke your consent authorizing us to use your personal information in this manner at any time by contacting us.
The General Data Protection Regulation requires that we appoint a Data Protection Officer entrusted with the responsibility of ensuring compliance with our obligations under GDPR in respect of matters pertaining to privacy and data protection. You may contact our DPO here.
Apps are made available free of charge, but may host third-party content or material such as advertisements of generic nature not specifically tailored to match your individual preferences. Such third-party content is hosted by default and we do not share your personal information with such third parties. However, provided that we receive your express, prior consent, we may share your information with carefully selected third parties whose products or services we believe may be of interest to you, in which case the advertisements appearing on the App may be related to your particular preferences. If, after having provided such express authorization for the sharing of your personal information by us in this way, you have changed your mind, you can always revoke such authorization to prevent us from disclosing your information in this manner by visiting App settings and/ or changing the advertising preferences on your device, as well as turn off the Advertising Tracking feature on it.
Alternatively and if available in the App, should you wish to use the App without having to view such third-party content at all, you may block it by making an in-app purchase.
We and our third party advertising networks and their partners may use Software Development Kits (SDKs), to provide targeted advertisements. Some of these technologies can synchronize behavior across different mobile apps, devices and websites so that advertisements can be tailored to your interests. This process is called personalized advertising. In addition, we and certain advertising networks may access your inventory of installed apps to avoid advertising already installed apps.
We may share your personal information with third parties based on your consent; and/or because such processing is necessary for the performance of a contract to which you are a party; and/or in the context of pursuing a legitimate business interest, provided that such legitimate business interest does not override your fundamental rights and interests; and/or where we need to comply with a legal or regulatory obligation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In order to safeguard your rights emanating from this Agreement, we have entered into Non-Disclosure Agreements (NDAs) and/ or Data Protection Agreements (DPAs) with our contractors, subcontractors and other third parties in order to ensure that your personal information remains confidential and obtains an adequate level of protection.
We may also share your personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in our Privacy Policy.
We have put in place the following security procedures and technical and organizational measures to safeguard your personal information: encryption, pseudonymization, firewalls, limited access, use of passwords and other relevant measures as appropriate.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will use all reasonable efforts to safeguard your personal information and for this purpose we undertake to review our security procedures and technical and organizational measures regularly in order to account for the latest technological developments. However, you should be aware that use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
Pursuant to the requirements of the GDPR in the event that we become aware of any suspected data breach in our system we are under an obligation to notify you of the nature of the data breach in question without undue delay. We are also obliged to report this to the Office of the Commissioner for Personal Data Protection (OCPDP) in its capacity as the competent supervisory authority concerning personal data protection, within 72 hours of any such suspected breach coming to our attention.
Any requests, inquiries, comments, feedback or complaints communicated to us via our user support feature, including your name and email address, shall be kept until such time as the relevant request, inquiry or complaint has been conclusively dealt with or resolved and for the request history purpose.
Personal information that you submit in the course of using the App shall be kept by us only as long as you use the App, or as long as it is absolutely necessary in order to attain the purpose for which such personal data was submitted by you in the first place, or as otherwise required by law or and/or applicable regulations.
The information you provide to us may be transferred to countries (hereinafter “third countries”) or organizations (hereinafter “international organizations”) outside the European Economic Area (EEA)* that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy.
Protection is afforded to your personal information by ensuring at least one of the following safeguards is implemented:
*The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information you consent to these transfers for the purposes specified above.
Also while transferring your personal data to the United States, we will check if this organization is EU-U.S. Data Privacy Framework compliant.
You have the right to request a copy of the information that we hold about you (including whether or not personal data concerning you is being processed, where and for what purpose). If you would like a copy of some or all of your personal information, please contact us and an electronic copy (unless otherwise requested by you) will be provided to you free of charge, within a month of receipt of such request.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to the Company changes please let us know the correct details by contacting us.
You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
You may withdraw your consent allowing us to collect and use your personal information at any time. If you elect to withdraw your consent you are entitled to have the personal information we hold about deleted or erased without undue delay, following a relevant request to this effect. You may also be entitled to require us to stop sharing this information and prevent any third parties from continuing to use this information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You may also exercise your right to have such information erased or deleted from our system in so far as the information in question is no longer relevant for the purpose for which it was originally provided by you for processing. If you would like to exercise these rights, please contact us.
You are also entitled to request an electronic copy of the personal data that you have provided and request that these be transmitted directly, where this is possible, to another entity without hindrance. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Furthermore, you have a right to object, at any time, to the processing of the personal information that you have submitted provided such an objection can be justified on legitimate grounds.
The App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and/ or apps and are not responsible for their privacy statements. When you leave the App, we encourage you to read the privacy notice of every website or app you visit.
Where required by applicable data protection laws, we will always seek to obtain your express permission before we ask you to submit your personal information via Apps. In respect of persons below the age of 16 or below such age limit as determined by applicable local laws, please note that we do not knowingly collect information about the age of our users. Furthermore, we undertake to immediately erase and/or delete from our records, archives and/or databases any personal information in respect of any child below the age of 16 or below such age limit as determined by applicable local laws, that was inadvertently collected, kept or stored by us and ask our partners to do so.
We take the privacy rights of users of Apps very seriously, including, without limitation, all and any rights bestowed upon children under the age of 13 pursuant to the US Children’s Online Privacy Protection Act (hereinafter “COPPA”).
In so far as COPPA is applicable in your country of residence and in the course of safeguarding the rights of children under the age of 13 and ensuring compliance with the stipulations of COPPA, We do not knowingly collect or store any personal information pertaining to children under the age of 13 residing in the United States of America. Furthermore, we undertake to immediately erase and/or delete from our records, archives and/or databases any personal information in respect of any child below the age of 13 that was inadvertently collected, kept or stored by us and ask our partners to do so.
We keep our Privacy Policy under regular review. If we change our Privacy Policywe will post the changes on this page. Also, we may inform you via the App, so that you may be aware of the information we collect and how we use it at all times.
We welcome your views about any of the Apps, and our Privacy Policy. You can contact us here.
If you have reason to believe that there has been an unauthorised use of your personal data or that your personal data may have been used in a manner inconsistent with the purpose for which you have agreed to provide or supply such personal data in the first place, or that your personal data may have been compromised by reason of improper use, you are encouraged to contact us in order to communicate your complaint.
Alternatively, you are entitled to submit a complaint to the Office of the Commissioner for Personal Data Protection (hereinafter the “OCPDP”) in its capacity as the competent supervisory authority in respect of the applicable regulatory framework pertaining to personal data protection. The contact details of the OCPDP are provided hereinbelow:
Office of the Commissioner for Personal Data Protection:
ul. Stawki 2, 00-193 Warszawa
Telephone no.: + 48 22 531-03-00
E-mail Address: kancelaria@uodo.gov.pl
For more information concerning your rights emanating from the Data Protection Law and the applicable regulatory framework including the relevant EU Regulations including the General Data Protection Regulation (GDPR) took effect on 25/05/2018, you are encouraged to visit the OCPDP website at the following address: https://uodo.gov.pl.
This Privacy Policy has been introduced on the 1st of August 2023.
This Specific US Privacy Policy supplements the information contained in General Privacy Policy and applies to the App users who reside in the USA.
In case of any inconsistency with this Privacy Policy and General Privacy Policy the former shall prevail. We adopt this policy to comply with the California Consumer Privacy Act of 2018 (CCPA), Virginia Consumer Data Protection Act of 2021 (VCDPA), the Colorado Privacy Act of 2023 (CPA), the Connecticut Data Privacy Act of 2022 (CTDPA) and other US data privacy regulatory framework that may be introduced in law either on state-per-state basis and / or as part of the Federal law (collectively referred to as US Privacy Acts) as amended. Any terms defined in the US Privacy Acts have the same meaning when used in this policy. In case of any inconsistency the terms in this policy to any of the US Privacy Acts the latest shall prevail and, please, inform us about such inconsistency by contacting us.
Depending on how You interact with us, we may collect the following categories of information as summarized in the table below. In particular, we has collected the following categories of personal information from our consumers within the last twelve (12) months:
Personal information does not include:
We may use, or disclose the personal information we collect for one or more of the business purposes described in Purpose of Collection of Personal Data and Intended Use and for one or more of the following business purposes:
The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing You notice.
The Company may disclose Your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share Your personal information with the following categories of third parties: Service providers.
In the preceding twelve (12) months, we has disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, the Company has not sold personal information.
The US Privacy Acts may provide the US residents with specific rights regarding their personal information. This section describes rights which may be vested on You under the US Privacy Acts and explains how to exercise those rights.
Access to specific information and data portability rights
You may have the right to request that the Company disclose certain information to You about our collection and use of Your personal information over the past 12 months. Once we receive and confirm Your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to You:
Exercising access, data portability, and deletion rights
To exercise the access, data portability, and deletion rights described above, in case such rights are vested on You, please submit a verifiable consumer request to us by email available here.
Only You, or a person that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to Your request or provide You with personal information if we cannot verify Your identity or authority to make the request and confirm the personal information relates to You.
Making a verifiable consumer request does not require You to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (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 electronically.
Any disclosures we provide will only cover the 12-month period 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 your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing Your request.
Residents of some States may opt out of the “sale” of their personal information. The "sale" of personal data of the consumers who are less than 16 years of age is possible only if the consumer, in the case of consumers between 13 and 16 years of age, or the consumer's parent or guardian, in case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer's personal information ("right to opt-in").
The Company does not “sell” Your personal information as we understand that term to be defined by the US Privacy Acts and its implementing regulations, if any.
We do not knowingly collect information about the age of our users.
You have the right to not be discriminated against for exercising Your rights as described in this policy. We will not discriminate against You for exercising your US Privacy Acts rights.
The Company reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the App and update the policy's effective date. Your continued use of our Apps following the posting of changes constitutes Your acceptance of such changes.
If You have any questions or comments about this policy, the ways in which the Company collects and uses Your information, Your choices and rights regarding such use, or wish to exercise Your rights under US law, please do not hesitate to contact us.