Effective Date: January 1, 2020
Last Modified: December 19, 2019
Welcome! We are happy that you wish to learn more about how we keep your information safe. This policy will provide you information about how we look after your personal data when you play our game and visit our application (the “App”). The policy also tells you how we collect, store, use and share your personal data, about your privacy rights and how the law protects you.
This App is intended for use by parents and whole family, including young children under parental supervision.
Who we are
Luxoft is a group of companies spread around the world. Read more about the Luxoft Group here.
How to contact us
We have appointed a data protection officer (“DPO”) who is responsible for overseeing privacy questions. If you have any questions about data protection in Luxoft, please contact our DPO at: email@example.com.
Attn: Data Protection Officer
Luxoft USA, Inc., 1 Rockefeller Plaza, Floor 27, New York, NY 10020
Your privacy rights as data subject
At any point while we are in possession of or processing your personal data, you have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. If we are legally obligated to keep the information or if it is impossible or unproportionate, we won’t delete it but we will only keep it for as long as it is needed and we have time limits on our data systems.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to have a computer make decisions about you directly.
- Right to lodge a complaint with a supervisory authority.
What data about you is processed, why and by whom?
Unity is a provider that is automatically collecting the following information about user’s devices within our App:
- unique device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices); IP address; country of install (mapped from IP address);
- device manufacturer and model platform type (iOS, Android, Mac, Windows, etc.) and the operating system and version running on your system or device;
- CPU information such as model, the number of CPUs present, frequency, and instruction set support flags;
- the graphics card type and vendor name;
- graphics card driver name and version (e.g., “nv4disp.dll 188.8.131.52”);
- which graphics API is in use (e.g., “OpenGL 2.1” or “Direct3D 9.0c”);
- amount of system and video RAM present;
- current screen resolution;
- version of the Unity Editor used to create the game;
- sensor flags (e.g., device support for gyroscope, touch pressure or accelerometer);
- application or bundle identification (“app ID”) of the game installed;
- unique advertising identifiers provided for iOS and Android devices (e.g., IDFA or Android Ad ID); and
- a checksum of all the data that gets sent to verify that it transmitted correctly.
Unity also collects the data about events completed or actions taken within the game, including level, number of achievements, time it took you to earn them, metadata about in-game communications and the value and details of purchases.
Luxoft has ongoing access to the above mentioned data. This access makes it possible for your experience to operate as expected by permitting you to do things like unlock achievements you have earned or return to where you left off in a game. We process this information so we can understand and monitor usage of the App, customize content on the App and improve the performance of the App.
Luxoft also has access to aggregated reports about game activity. These reports are based, in part, on your game activities, but do not specifically identify you or your device. The reports help Luxoft make decisions on optimal methods to run the game we made for you. For example, we may need to know the types of devices running the game to determine how to support game updates on an ongoing basis.
Purpose of processing your data
Unity and Luxoft process the above listed data for the following purposes:
- to provide you with access to the App, game, progress, achievements and purchases;
- set up the connection of your device and our App;
- send you reminders and in-app notifications;
- provide you with our content, products and to enable your participation in activities supported by us;
- process your requests;
- provide consumer support and repair services;
- detect and prevent illegal activities (e.g. hacking or cheating);
- track App installs (for purposes of measuring the effectiveness of marketing campaigns);
- understand you, your preferences and user traffic to enhance your experience and enjoyment using our App;
- conduct research;
- remember your device next time you visit our App;
- provide you with in-game progress and achievements based on your in-game behaviors;
- comply with our legal obligations.
How we process your data
Luxoft may perform any operation or set of operations on your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Our App may send you ‘in-app ’ to mobile phones or devices to tell you about updates (sometimes even when the app is not in use). We don’t link the device identifier with any other personal information without parental consent.
How long do we keep your personal information
If data subject would like us to delete its data, we’ll only keep information that we need for legal reasons, to resolve disputes, to enforce our agreements or to prevent any future contacts with data subject.
Whenever we collect personal information from a child, we only keep the information for the time we need it to provide a service or for the time it’s legally required to be kept on record.
We may share personal information to meet legal processes or if disclosure is required by law. As allowed by relevant laws, we may also share personal information collected from children to:
- Comply with a request from to a law enforcement or public agency (including schools or children services) or to avoid liability
- Make a disclosure that we believe may stop a crime being committed
- Help an investigation related to public safety
- Protect the safety of a child who’s using our App
- Protect the technology of our service providers or security of our App
We don’t share information with third parties other than as described above.
We may also share personal information if Luxoft transfers ownership of Luxoft or its assets (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, liquidation). The buyer or transferee will be required to honor the commitments we have made in this policy.
Luxoft takes reasonable steps to help protect and secure children’s personal information. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, Luxoft cannot ensure or warrant the security of any information transmitted to us or our service providers through our App.
Cookies are small data files that your browser places on your computer or device. A cookie itself does not contain or collect information. However, when it is read by a server via a web browser it can help a website deliver a more user-friendly service – for example, remembering previous purchases or account details.
Like most websites, our App collects some information (e.g. information on IP addresses, browsers, internet service providers, referring pages, exit pages, operating systems, date stamps, time stamps and clickstream data). This information won’t be linked to any other information we collect about you unless you have given your consent that we may do this.
Both we and Unity use browser storage, app storage, cookies, pixls, beacons, scripts and tags to analyze trends, administer the site, track user movement through the site and collect demographic information about our overall user base. We may receive reports on these from Unity on an individual and aggregate basis.
To Parent’s attention:
Keeping children safe
Luxoft respects the privacy of children and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). This policy governs our App and describes our practices with respect to the collection of information from children under the age of 13.
When we do process personal information from children, we take extra steps to protect their privacy including:
- Making sure we tell parents what personal information we collect, store, use and process from their child and explaining whether we share the information;
- Meeting legal requirements by asking for parental consent to collect, use and process a child’s data and asking for consent to send their children information about our products and services;
- Limiting how we collect, store, use and process personal information from children so only data that is reasonably needed for them to take part in an online activity is collected;
- Giving parents access or the option to ask for access to personal information we’ve collected from their child – parents can also ask for their children’s personal information to be changed or deleted.
Collecting and using children’s information
We do not require children to actively share any personal information in order to use this App. For example, children can view content, play games and enjoy many features of the App without registration, purchasing or providing any personal information.
Where personal information is needed for features to function, we’ll only ask for information that is reasonably required to take part in the activity.
Under COPPA, you have the right to review and have any of your child’s information deleted from our records. You also have the right to tell us to stop collection or using your child’s personal information. If you have questions concerning our information practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s personal information in connection with the transaction for which it was originally collected, you may email us at firstname.lastname@example.org.
If you would like your child to stop receiving in-app notifications, you can change the settings on the device your child is using at any time.
Special Note to California Residents
For rights and choices specific to California consumers, please refer to our Privacy Notice for California Residents. Please note that we will take reasonable steps to verify your identity and the authenticity of your request. Once verified, we will maintain your request in the event our practices change.
Changes to this Policy
This Policy is current as of the date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected, we will provide you with notice in advance of such change by highlighting the change on our site.