PRIVACY AND COOKIE POLICY
Effective Date: March 22, 2024
Limited liability company «X-Media Digital», having company tax number 7733572241 (“Publisher” or “We”) is dedicated to protecting the privacy rights of our users (“Users” or “You”). This Privacy and Cookie Policy (the “Policy”) has been crafted to inform You as to the ways we collect, store, use, and manage the information You provide in connection with any Publisher game or application (games and applications are, collectively, the “Services”).
Please note that the scope of this Policy is limited only to information collected by Publisher through use of the Services. This Policy does not apply to the practices of third parties that Publisher does not own or control. Publisher offers its Services also to Users resident in the EU. Publisher is the data controller for personal information collected of those Users. Users who are resident in the EU may address questions relating to the way we collect, store, use and disclose their personal information either to Publisher at the address identified below, or to our representative at the following address: 125466, Russia, Moscow, Novokurkinskoe avenue 27, apt. 78.
For Users not located in the EU
By downloading and installing our Services, You are invited to agree with this Policy and the processing of your data, including your personal information, also called personal data in some jurisdictions (we refer to this information/data collectively as “personal information” throughout this Policy), in the manner provided in this Policy and our End User License Agreement. We therefore process your personal information based on your consent. In any event, any use of the Services will be construed as your agreement with this Policy and our End User License Agreement. If You do not agree to these terms, please do not use the Services.
Specifically for Users located in the EU
This Policy is merely informative about how Publisher collects, stores, uses and discloses your personal information. We are not asking You to consent to this Policy. If we require your consent we will ask for it in separate notice and consent forms. Please note that if You provide us with consent, you have the right to withdraw this consent at any time by contacting us at mult@xmediadigital.ru.
It is advised that You review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).
Other terms and definitions used in this Policy are to be understood in the sense they are defined in the End User License Agreement.
1. General Terms
1.1. The purpose of this Policy is to ensure the appropriate protection of information about Users, including their personal data, from unauthorized access and disclosure.
1.2. Activities associated with the collection, storage, dissemination, and protection of User information are regulated by this Policy, other official documents of Publisher, and current legislation. We aim to minimize how much personal information we collect from Users when they use the Services.
1.3. The current version of the Policy, which is a public document, has been drafted by Publisher and is available to any Internet User at: https://xdigital.ru/policy.
1.4. Publisher has the right to make changes to this Policy. When changes are made to the Policy, Publisher notifies its Users about it by publishing the new version of the Policy on the Site; the changes take effect from the date when the new version of the Policy is posted on the Site.
2. Principles of Information Processing
2.1. The processing of personal data is based on the following principles:
a) legitimacy of the purposes and methods of personal data processing and good faith;
b) the purposes of personal data processing corresponding to the goals predetermined and stated when collecting personal data, and to the authority of Publisher to process such data;
c) the volume and nature of the personal data being processed, as well as the methods of personal data processing, corresponding to the purposes of personal data processing;
d) no combining of databases containing personal User data, where such databases were originally created for incompatible purposes.
2.2. The collection of personal data. Personal data of the User is transferred to Publisher with the consent of the User.
2.3. Storage and use of personal data. Users’ personal data is stored exclusively on electronic media and processed using automated systems. How long we store your personal information will depend on the purpose that we originally collected it. We will not retain personal information for longer than is necessary for our business or for legal requirements.
2.4. Transfer of personal data. Users’ personal data is not transferred to any third parties, except in cases expressly provided for in this Policy. The provision of Users’ personal data at the request of state (local) government bodies is carried out in the manner set forth by law.
2.5. When you make in-app purchases in the applications (Paid Services), we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. AppStore) or your platform’s payment processor.
3. Third party services
3.1. Please note that third party partners/providers, such as analytics companies, may also use cookies or other technologies, and those partners are subject to their own policies.
3.2. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often You use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the mobile application.
3.3. Our Services may contain third party tracking tools from our partners. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze User information on our behalf. The third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their Services under their respective privacy policies. This Policy does not cover the use of tracking tools from third parties. We do not have access or control over these third parties. The following are third parties that we use for analytics:
a) AppMetrica
Publisher uses AppMetrica to help understand usage of the Services. For more information about AppMetrica privacy practices, please see the https://yandex.com/legal/metrica_termsofuse.
b) Firebase
Firebase helps us understand clearly how Users behave, which enables You to make informed decisions regarding app marketing and performance optimizations. For more information about Firebase privacy practices, please see the https://firebase.google.com/terms/analytics.
d) Google Analytics
Google Analytics collects information such as how often Users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing You on return visits to this Site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see the Google Privacy Policy (https://policies.google.com/privacy?hl=en). To prevent Google Analytics from using your data through a web browser, you can get the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/).
4. Purposes of Information Processing
4.1. Publisher processes information about Users, including their personal data, in order to fulfill Publisher’s obligations to its Users regarding the use of the Services.
4.2. Publisher can use personal User information for the following purposes:
a) Research and analytics. To analyze how You interact with the Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes based on impersonal data.
b) Marketing and communications. To communicate with You, including via email or push notification about use of the Services, including to send Services and games and applications updates; to respond to your inquiries; to provide You with news and newsletters, special offers, promotions, and other information we think may interest You; and for other informational, marketing, or promotional purposes.
c) Providing and improving. For improve the Services; for develop new features, games, applications or services; for authenticate Users; for perform technical operations, such as updating Services; for validate our Users and ensure their qualifications to use the Service; and for other customer service and support purposes. As an online business, it is important for us to know how Users interact with our Services. Our third party services will collect your location information, device information, so that we can deliver our application to our Users, measure, analyze, and improve performance of the Services, and to continually update and develop our Services. For example, we will use this information to assess the difficulty level of games, fix any bugs or errors in the games, evaluate the demographic of our Users, and to determine whether or not we need to support a new device type for the Services.
d) Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
5. Information collection and processing
5.1. We collect and process the personal information of Users on the following conditions:
| Personal Information | Purpose(s) | Who |
| — e-mail address; — additional information provided by the User at the request of Publisher in order to fulfill the obligations of Publisher to the Users regarding the use of the Services. Specifically, Publisher has the right to request from the User a copy of an identity document or any other document containing the User’s name, surname and photo, as well as any additional information that, at the discretion of Publisher, will be necessary and sufficient to identify the User and allow it to prevent abuses and infringements on the rights of third parties |
Marketing and communications, Legal compliance | Publisher |
| IP address | Providing and improving, Research and analytics | Publisher, AppMetrica, Google Analytics |
| Information about your gender and age | Research and analytics | AppMetrica, Firebase |
| Location information, which means general information about the location from which You’re using the Services (e.g. country, and city) | Providing and improving, Research and analytics | AppMetrica, Firebase |
| Device information, which means technical information about your device. When we refer to device Information, this means your device ID, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your device, the language You’ve set for your device, the version of the application installed on your device, and the name of your carrier | Providing and improving | AppMetrica, Firebase |
| Information obtained as a result of the actions of other Users via the applications (e.g. purchase / subscription, bugs and errors) | Providing and improving | AppMetrica, Firebase |
| Users interests | Research and analytics | Firebase |
| Cookie | Providing and improving, Research and analytics | Google Analytics |
6. Your rights and choices in relation to your personal information
6.1. Publisher takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others’ privacy), You can request information from us about the personal information we hold in relation to You and You can correct any inaccurate data we hold.
6.2. In certain territories (including the EU), you also have a legal right to ask for a restriction of processing, to object to processing as well as the right to data portability. However, these rights are subject to conditions and may not always be applicable.
6.3. You have the right to withdraw your consent, on the basis of which we process your personal information, at any time, however, this does not affect our lawful processing based on your consent before this withdrawal.
6.4. Push notifications
We may occasionally send You push notifications through our games, applications to send You game or application updates, high scores and other Services related notifications that may be of importance to You. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.
6.5. For Users in the European Union.
A. Legal Basis for Processing. Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information. Typically, we will rely on the following legal bases for processing your personal information: (i) your consent; (ii) where our processing is in our legitimate interest; or (iii) where our processing is necessary to perform a contract with You (e.g. to make the Services accessible to You). If we rely on your consent to process your personal information, You have the right to withdraw your consent at any time.
B. Transfer of Personal Information Outside of the EU. Because our third party services are located in countries outside of the European Union, your personal information may be transferred to other countries that may not offer the same level of data protection as the laws of your country of residence.
C. How to File Complaints. If You believe your rights have been violated, You may lodge a complaint with the supervisory authority of your country of residence.
If You want to exercise any of these rights, please contact us at: mult@xmediadigital.ru.
7. Children’s personal information.
We do not knowingly collect children’s personal information without parental consent, except as permitted under applicable laws such as the U.S. Children’s Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, Publisher, its providers/ partners may collect personal information strictly to support Publisher’s internal operations and/or legitimate interests, such as analytics. If You are a parent of a child using applications (Services), You may review or have your child’s personal information deleted and refuse the further collection of his/her personal information by contacting us at mult@xmediadigital.ru. Please contact us if You believe we are collecting a child’s personal information in violation of COPPA or the GDPR.
8. Measures For the Protection of User Information
8.1. Publisher takes technical, organizational and legal measures to protect the Users’ personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal activities.
8.2. We have implemented commercially reasonable technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes.
8.3. In the event that personal information has been or is compromised as a result of a breach of security, Publisher will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.
8.4. The security of your personal information is important to us. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our third party services stake appropriate security measures to protect against unauthorized access or disclosure of the information collected by us.
9. Restrictions to Policy’s Services
This Policy does not apply to the actions and Internet resources of third parties. Publisher is not responsible for the actions of third parties who, as a result of using the Services, have access to information about the User, which, by the nature of the Services, is available to any Internet User. Publisher recommends that Users take a responsible approach to the amount of information they provide about themselves.
10. User Queries
10.1. Users are entitled to send their queries to Publisher, including queries regarding the use of their personal data in writing to: 125466, Russia, Moscow, Novokurkinskoe avenue 27, apt. 78, or in the form of an electronic document containing a qualified electronic signature in accordance with the legislation of the Russian Federation to our e-mail address mult@xmediadigital.ru.
10.2. Publisher shall review and reply to the received User query within 30 (thirty) days of the receipt of the query. That period may be extended by two further months where necessary, taking into account the complexity and number of the request.
10.3. All correspondence received by Publisher from Users (queries in writing or submitted electronically) is considered information with limited access, and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the query cannot be used without the express consent of the User in any way other than to respond to the issue described in the query received or in cases expressly provided for by law.