This document "Privacy Policy" (hereinafter referred to as "Policy") is the terms and conditions for collection and use of the Personal information of the User (hereinafter referred to also as "You") by Sacralium Limited Liability Company (hereinafter referred to as "Sacralium") during download, installation and use of the mobile application "One Life Story" (hereinafter referred to as "Mobile application")
USER'S CONSENT:
By checking the box "I agree" accompanied with the link to this Policy you (hereinafter also referred to as "User") with your own free will and for your benefit give your written consent to the processing of User's Personal Information for the purposes and under the terms and conditions stipulated by this Policy.
1.1. This Policy is an integral part of the End User Sublicense Agreement for the Mobile application (hereinafter referred to as the "EULA"). Therefore, when executing the above said EULA by methods defined therein including by downloading, installation and using the Mobile application you fully accept the terms of this Policy.
1.2. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.
1.3. The terms and definitions provided for by the EULA are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.
2.1. When using Mobile application the User does not actively provide any information about him/her.
2.2. Personal information in this Policy means as follows:
2.2.1. Data transmitted in a depersonalized form in automatic mode during use of Mobile application, depending on the settings of the User's software including operating system of User's device.
2.3. Sacralium collects and stores the following impersonal data about the User: location of User's devise (country and city) and unique identifier of User's device (UID). Sacralium does not collect and store the data that enables identification of User (personal data).
2.4. The User understands, accepts and agrees with use of third party software in the Mobile application by Sacralium; as a result, such third parties can automatically receive and transmit the impersonal data about the User.
The aforementioned third party software includes:
a) analytic systems:
Such data collected with third party software may include:
The scope and conditions for collection and use of impersonal data by such software's titleholders are determined directly by its titleholders and governed by documents available at their websites.
Accepting this Policy as well applying certain setting in his/her software including device's operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.
The legal basis on which Sacralium relies for the use of Personal information includes:
3.1. Processing of Personal information where User has given consent for one or more specific purposes.
3.2. Processing of Personal information that is necessary for performing a contract to which User are party.
4.1. Sacralium does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Mobile application. If Sacralium gets to know that the information was collected from a child under 16, Sacralium shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail: support@sacralium.games.
5.1. Sacralium is entitled to use the Personal Information for the following purposes:
5.1.1. Anonymized identification of the User within the fulfillment of the EULA. The User is identified anonymously by unique identifier of a device.
5.1.2. Fulfillment of obligations under EULA, including providing the User with an opportunity to use the Mobile application.
5.1.3. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 2.4 hereof.
5.1.4. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 2.4 hereof.
6.1. Subject to specific provisions of applicable law, the User has the right:
6.1.1. to be informed about the collection and use of his/her personal data.
6.1.2. to access his/her personal data and have it corrected if it is wrong or incomplete.
6.1.3. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Sacralium no longer needs the personal data for the purposes for which Sacralium has processed it.
6.1.4. to object to the processing of his/her personal data and also restrict its processing in those instances where Sacralium undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
6.1.5. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Sacralium that is based on the consent User had given before he/she withdrew it.
6.1.6. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
6.1.7. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
6.1.8. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Sacralium processes by automated means personal data that User has provided.
6.2. These rights may be exercised by contacting Sacralium with specific request through the methods described below. Sacralium will address any such requests in a timely manner and according to applicable law. In certain cases, Sacralium may ask User to verify identity before acting on User's request. If User is unsatisfied with Sacralium's response, User may refer his/her complaint to the relevant supervisory authority in User's jurisdiction.
7.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Sacralium will review its data processing systems to determine whether or not the purposes for the collection and processing of User's personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Sacralium, whether or not any requests made by User from Sacralium have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Sacralium, and whether or not there is a contractual or legal basis for continuing to retain User's personal data. Based on that review and any notifications received from data subjects, Sacralium will update its systems.
8.1. Sacralium stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
8.2. With regard to the User's Personal Information, its confidentiality is protected.
9.1. Sacralium is entitled to transfer Personal Information to third parties in the following cases:
9.1.1. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that do not limit the provision of certain information.
9.1.2. The transfer is necessary in the context of the User's use of the Mobile application's functionality.
9.1.3. In connection with use in Mobile application of third party software for collection and processing of User's data. Specifically, Sacralium may use the third party software for collection and processing of User's data according to clause 2.4. of this Policy.
9.1.4. Due to whole or partial transfer of Sacralium's assets to the third party, including assignment of rights under agreements concluded with the User in benefit of such third party.
9.1.5. Upon request of a court or other state authority within the procedure established by law.
9.1.6. To protect the rights and legitimate interests of Sacralium in connection with failure to comply with the agreements entered into with the User.
10.1. Any questions related to this Policy, use, amendment, deletion of the User's and/or exercising of any User's rights with respect to the Personal Information can be mailed to Sacralium at the address: support@sacralium.games
11.1. This Policy may be amended or terminated unilaterally by Sacralium without prior notice to the User. The User is recommended to read this Policy in the current version regularly.
11.2. The new version of the Policy becomes effective upon its placement, unless otherwise provided for by the new version of the Policy.
11.3. The current version of the Policy is available at: https://sacralium.games/onelife/privacy.
"Sacralium" LLC
Registration number: 1187154024584
Address: 2 Ul'yanova, lit. A, 2nd floor, office 1, Tula, Russia.
E-mail: support@sacralium.games
The current version of the Policy of 15.04.2019.
The Russian Federation is outside the European Economic Area. An adequacy decision by the Commission with respect to the Russian Federation is absent.
This Privacy Policy is designed by the law firm IT Lex