PRIVACY NOTICE

This privacy notice (hereinafter „notice“) explains how Clickwork Games OÜ(hereinafter “we” or „us“) processes personal data of Idle Panzer mobile game (available on iOS and Android platforms (hereinafter “application”)) players and other individuals who have installed it on their device. This notice also explains how we process personal data of visitors of our website https://clickworkgames.com/ (hereinafter “website”).

This notice describes the processing of personal data by us as a data controller. This means that we individually or along with others determine the purposes and means of the processing of personal data.

1.      DATA CONTROLLER

Clickwork Games OÜ

Registry code: 14825796

Address: Roseni 9-5, 10111 Tallinn, Estonia

Email: info@clickworkgames.com

Contact details of data protection officer: privacy@clickworkgames.com

2.      PERSONAL DATA WE PROCESS

2.1.   Identity and contact data” – this includes your name and email address.

Sources of collection of data: we get this data when you send us a message either via our website or by e-mail.

2.2.   “Correspondence data” – this includes personal data personal data contained in the correspondence with us.

Sources of collection of data: we get this data when you send us a message either via our website or by e-mail.

2.3.   “Location data” – this includes data such as your country code, state, city, postal code, and designated market area.

Sources of collection of personal data: we get the personal data from you when you download, install, and launch the application on your device.We may also receive some this data from our advertising partners.

2.4.   Device and network data” – this includes your IP address, information about your mobile network operator, type of your device, type of your operating system.

Sources of collection of personal data: we get the personal data from you when you download, install, and launch the application on your device. We may also receive some this data from our advertising partners.

2.5.   Application data” – this includes the advertising ID, as well as your Apple or Google ID depending on the mobile platform you are using.

Sources of collection of personal data: We get your Apple or Google ID when you connect the application to your respective account. We also receive some application data, such as the advertising ID from our advertising partners.

2.6.   ”Website visit data” – this includes the personal data which is processed upon visiting and using our website. Depending on the particular cookie we use, the types of personal data may include e.g.: online identifiers, including cookie identifiers, IP addresses, device identifiers, client identifiers or session ID.

Sources of collection of data: we get this data when you visit and use our website.

3.      Purposes and legal grounds for data processing

When we process your personal data, we rely on the following legal grounds:

3.1.       Processing is necessary for the performance of a contract to which you are the party, or in order to take steps at your request prior to entering into a contract

Purposes of processing

Personal data that we process

Your personal data is processed to provide our services, i.e., to enable you to use the application, including to make in-app purchases.

Location data; device and network data; application data

 

3.2.       Consent

In some cases, we need your consent for data processing. You always have the right to withdraw the consent by sending us respective email (please Section 1 of this notice for our contact details). As for cookies, you always have the right to withdraw the consent by changing your preferences on our website. Withdrawal of the consent does not affect the legality of the processing of your personal data prior to withdrawal. 

Purposes of processing

Personal data that we process

We process your personal data to promote our application.For that purpose,we use marketing cookies on our website that process your personal data.

 

Website visit data

 

3.3.       Legitimate interests

We process your personal data based on our legitimate interests for purposes described below. You have the right to ask clarifications regarding the processing based on the legitimate interests. You also have the right to send the objection, if you find that processing of your personal data for the purposes provided below prejudice your rights. Please see Section 1 of this notice for our contact details.

Purposes of processing

Personal data that we process

Processing of the website visit data via technical cookies for the purposes of main functioning of the website.

 

Our legitimate interest is to operate a website that provides general information about us and our application.

 

Without using this type of cookies, our website will simply not work properly.

Website visit data

General business communication with the individuals. You can send us a message either via the website or by e-mail. Depending to the content of the received message, we either reply to it, archive it, or delete it.

Identity and contact data; correspondence data

Displaying our and our partners' ads in the application.

Location data; device and network data; application data

 

3.4.   Processing necessary for compliance with a legal obligation

We process personal data on this legal ground if the legal obligation for processing arises from the law.

Purposes of processing

Categories of data

Notification of and response to the information requests of public authorities and government institutions.

location data; device and network data, application data; identity and contact data; correspondence data, website visit data

 

4.      CATEGORIES OF RECIPIENTS OF PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

In some cases, we may transfer your personal data to certain recipients who are categorized as follows:

4.1.   Advertising and marketing networks, app monetisation platforms, advertising exchanges and similar service providers.

4.2.   Partners who provide the services to us, and who process the personal data on our behalf (data processors), e.g.:

(a)           Providers of ICT services (including providers of website and platform hosting services and other providers of cloud services);

(b)           Providers of mobile marketing analytics and attribution platforms;

(c)           Various contractors (IT development, support).

4.3.   Public authorities and supervisory bodies, e.g., court, law enforcement authorities, Data Protection Inspectorate. We transfer your personal data to public authorities and supervisory bodies only if the law requires it.

Unless necessary for the provision of services, we do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures.

You have the right to get additional information about the transfer of your personal data by sending us the relevant request atinfo@clickworkgames.com.

5.      RETENTION OF PERSONAL DATA

We keep your personal data for the period necessary for the achievement of purposes stated in this notice or until the law requires it. The retention periods for cookies are described in Section 7 below.

Specific terms of retention can be exercised by accessing your personal data. Please see the explanation in the section “Your rights regarding the personal data”.

6.      YOUR RIGHTS REGARDING THE PERSONAL DATA

Right of access to your data: you have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the personal data is disclosed (especially the recipients in third countries), for how long the personal data is retained and what are your rights concerning rectification, erasure and restriction of the processing.

Right of rectification: you have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.

Right of erasure: in some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the personal data.

Right to restrict the processing: in some cases, you have the right to restrict processing of the personal data concerning you for a certain time (e.g., if you have objected the processing of personal data).

Right to object: you have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

Right to data portability: if processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim to transmit those personal data to another service provider if it is technically possible.

Right to turn to us, supervisory authority, or a court: if you want to exercise the above-mentioned rights, please send us an email at info@clickworkgames.com. If you find that your rights have been breached,you have the right to turn to the court and/or localdata protection authority. Contact details for data protection authorities in the EEA are available here.

7.      COOKIES AND OTHER WEB TECHNOLOGIES

We use all the cookies, except the "essential" technical cookies, with your prior consent. You always have the right to withdraw the consent by changing your preferences on our website. Should technical cookies process your personal data, we rely on our legitimate interests in processing of such data (see the section above that explains our legitimate interests).

We may use both session cookies and persistent cookies. Session cookies or in other words non-persistent cookies are cookies that exist only temporarily while you browse our website. Your web browser should delete these cookies when you close your browser. On the other hand, persistent cookies that we use expire at a specific date or after a specific length of time set by the third-party or us.

For your convenience, we have categorised the cookies we use our website by their purposes as follows:

Technical

We use this type of essential cookies to run our website properly, i.e., without these cookies our website would not function as it should. Due to the nature of such cookies, and in accordance with applicable law, we have the right to use them without your prior consent. However, if these cookies process personal data, we rely on our legitimate interests upon processing of such data.

Marketing

We use this type of cookies to target advertising to a you based on your website visiting activity. We use the analytical cookies only based on your prior consent.YouTube-related cookies areinter aliaplaced on our website as a result of embeddingYouTube video about our application.

Hereunder we have listed all the cookies used on our website. You will find the information regarding their purpose, retention period and whether it is a first-party or a third-party cookie.

Category

Name

Purpose

Retention period

First party or third party

 

Technical

CONSENT

The cookie is used to detect if the visitor has accepted the marketing category in the cookie banner.

195 months

Third party (Youtube.com)

Technical

test_cookie

The cookie is used to check if the user's browser supports cookies.

1 day

Third party (Google: doubleclick.net/Google Marketing Platform)

Marketing

IDE

The cookie is used by Google DoubleClick to register and report the web site user's actions after viewingorclicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the u ser.

1 year

Third party (Google: doubleclck.net/Google Marketing Platform)

Marketing

VISITOR_INFO1_LIVE

The cookie tries to estimate the users' bandwidth on pages withintegrated YouTube videos.

179 days

Third party (Youtube.com)

Marketing

YSC

The cookie registers a unique ID to keep statistics of what videos from YouTube the user has seen.

Session

Third party (Youtube.com)

Marketing

yt.innertube::nextId

The cookie registers a unique ID to keep statistics of what videos from YouTube the user has seen.

Persistent

Third party (Youtube.com)

Marketing

yt.innertube::requests

The cookie registers a unique ID to keep statistics of what videos from YouTube the user has seen.

Persistent

Third party (Youtube.com)

Marketing

yt-remote-cast-available

The cookie stores the user's video player preferences using embedded YouTube video.

Session

Third party (Youtube.com)

Marketing

yt-remote-cast-installed

The cookie stores the user's video player preferences using embedded YouTube video.

Session

Third party (Youtube.com)

Marketing

yt-remote-connected-devices

The cookie stores the user's video player preferences using embedded YouTube video.

Persistent

Third party (Youtube.com)

Marketing

yt-remote-device-id

The cookie stores the user's video player preferences using embedded YouTube video.

Persistent

Third party (Youtube.com)

Marketing

yt-remote-fast-check-period

The cookie stores the user's video player preferences using embedded YouTube video

Session

Third party (Youtube.com)

Marketing

yt-remote-session-app

The cookie stores the user's video player preferences using embedded YouTube video

Session

Third party (Youtube.com)

Marketing

yt-remote-session-name

The cookie stores the user's video player preferences using embedded YouTube video

Session

Third party (Youtube.com)

                             

8.      AMENDMENT OF THIS NOTICE

We have the right to amend this notice unilaterally. We will notify of amendment of this notice in the application, by email or in other manner.