Privacy Policy for Paid Apps

Revised to be in line with the General Data Protection Regulation (GDPR), this privacy policy has been written for the sole purpose of explaining how we collect and use the information as well as what information that might be when you visit or use any of the Peaksel products and services. By accessing and/or using this or any affiliated websites, you are agreeing to the policies and practices described in this Privacy Policy.

As the controller, the Peaksel D.O.O. Nis has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through its services. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.

1. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Peaksel D.O.O. Nis
Kursumlijska 5
18000 Nis
Serbia
Phone: +381643314064
Email: contact@peaksel.com
Website: www.peaksel.com

2. Information Collection and Distribution

Automatically Collected Information
We do not collect any user provided information, but we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the apps and games. Also, we collect the automatically given information provided by Facebook such as public profile, friends list and e-mail.

Do we collect precise real time location information of the device?
We do not collect precise information about the location of your mobile device.

Do third parties see and/or have access to information obtained by Peaksel?
Yes. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose Automatically Collected Information:
– as required by law, such as to comply with a subpoena, or similar legal process;
– when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
– with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
– if Peaksel is involved in a merger, acquisition, or sale of all or a portion of its assets, the new owner and/or partner will have access to all the information collected provided that the mentioned policies and principles of the privacy policy are followed and respected as stated above.
to advertisers and third party advertising networks and analytics companies as described in the section below

3. Automatic Data Collection and Advertising

We may work with analytics companies to help us understand how our apps and games are being used, such as the frequency and duration of usage. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties can’t identify you personally. These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non- precise location information in order to help analyze our apps. We also may require the permission to use your phone camera or microphone strictly for the purposes of an app functionality (e.g. taking photos within the app). We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis purpose.

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

5. Rights of the data subject

Peaksel DOO collects only anonymous information for the purposes of targeted advertising and tracking of user behavior within the game. Should the user wish to eliminate the right to access to this automatically collected information, he or she can turn off individual device tracking on his or her portable device.

6. Analytic Companies

Flurry
Flurry Analytics provides accurate, real time data to developers about how consumers use their mobile applications, as well as how applications are performing across different handsets. Application developers receive anonymous, aggregated usage and performance data, as well as robust reporting and analysis tools. With this data, developers can identify issues and opportunities, create a more informed product roadmap, increase retention and grow their user base. Click here to read about their privacy policy.

Firebase Analytics
At the heart of Firebase is Firebase Analytics, a free and unlimited analytics solution. Analytics integrates across Firebase features and provides you with unlimited reporting for up to 500 distinct events that you can define using the Firebase SDK. Firebase Analytics reports help you understand clearly how your users behave, which enables you to make informed decisions regarding app marketing and performance optimizations. To read more about their privacy policy, click here.

Facebook Analytics for Apps
Facebook Analytics for Apps gives you insight about your audience, see how they use your app and learn about their activity on Facebook. It brings together web and app analytics so that it’s easy to understand how your business is performing. To read more about their privacy policy, click here.

7. In-app Purchases and Sales

Our Applications enable in-app purchases and can be sold on some markets.

In-app purchase
Although some of our Applications are free, they include in-app purchases. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. Your authentication and security maintaining is subject to specific terms of the app store and the OS of your mobile device. You should be aware of the iOS’ 15-minute and Android’s 30-minute window after the downloading of an Application, during which in-app purchases may be made without inserting an in-app store password. You should also take into account that OS 2.1 or older versions of Android mobile phones do not require entering of the app store account password to carry out in-app purchases.

Amazon
We sell our apps on Amazon or they offer in-app purchases thus all the payments are being processed by Amazon following the company’s rules and regulations. To read about Amazon’s Terms of Use for games and software, click here. If you want to know more about Amazon’s privacy policy, click here.

Samsung
We sell our apps on Samsung or offer in-app purchases. However, all the payment is being processed by the corresponding services provided by Samsung. To read more about Samsung’s privacy policy, click here. If you’d like to know more about Samsung’s Terms of Use, you can read them here.

8. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Whether our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, is to be based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
10. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact Peaksel DOO. The company clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

11. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

12. Data Retention Policy, Managing Your Information

We will retain Automatically Collected information. If you’d like us to delete User Provided Data that you have provided via any of our services, please contact us at PeakselGames@gmx.com and we will respond in a reasonable time.

13. Children

We do not use our products to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at PeakselGames@gmx.com. We will delete such information from our files within a reasonable time.

14. Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our services. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

15. Changes

This Privacy Policy may be updated from time to time for any reason. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

16. Your Consent

By using our services and products, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States your information will be transferred, processed and stored there under United States privacy standards.

17. Contact us

If you have any questions regarding privacy while using our products and services, or have questions about our practices, please contact us via email at PeakselGames@gmx.com.