Privacy notice

PRIVACY NOTICE

 

 

Effective Date: 16 August 2023

 

Welcome to Vizor. Your privacy is and will always be enormously important to us.

 

Please read it carefully because it is important for you to understand what we do with your information and how you can control it. Along with the general statements regarding your privacy rights below, you will also find the privacy requests you may make under applicable law.

 

Please visit this link for special disclosures pertaining to California, Colorado, Connecticut, or Virginia residents.

 

INTRODUCTION

 

This Privacy Notice explains how your personal data provided by you and/or received by us (‘personal data‘ or ‘personal information’) are collected and processed by VIZOR APPS LTD (‘we‘, ‘our‘, or ‘us‘).

 

This Privacy Notice also explains your legal rights in respect of your personal data and applies to:

• our games published on App Store, Google Play, Amazon and etc.,
• our games published on our portals klondike-online.com/ knightsbrides.com,
• our games published on social networking services,
• our activities in social networking services,

which we collectively call the ‘Services‘.

 

CONTACT US

 

If you have any questions, or if you experience any problems related to your personal data, or if you simply would like to reach out to us regarding your privacy rights, please feel free to contact us. We would recommend contacting us through the support feature you may find within the Services. This method of communication is the most efficient and we will be able to reply to you right away.

 

Otherwise, you may contact us:

Controller: Vizor Apps Ltd

Address: Archiepiskopou Makariou III, 169, CEDAR OASIS TOWER, flat/office 701, 3027, Limassol, Cyprus 

Attn: Privacy

Email: privacy@vizor-apps.com.

You may also contact our Data Protection Officer by email at dpo@vizor-apps.com.  

Please note that for the exercise of some of your privacy rights, we might be required by law to verify your identity.

 

THE PERSONAL DATA WE COLLECT

 

When collecting and processing your personal data, we are striving to be as transparent as possible, thus, consider checking the list of personal data that we collect and process.

 

Generally, we process your personal data to provide you access to the Services, to ensure proper and secure functioning thereof, to comply with applicable laws and regulations, and to enhance your experience while using the Services. We also use your personal data to contact you when necessary.

 

The categories of personal data	Data elements
Player Data and Identifiers	are information about your in-game profile and the identifiers linked to your in-game profile. Such information may include first or last name, or nickname, device ID, game ID, user ID, IP address, advertising ID (idfa/gaid), user ID in Apple/ Google/ Facebook, profile info (such as profile photo/ image), platform ID, platform advertising ID, or other personal data, or identifiers linked to your in-game profile.
Device Data	is device event information from the devices you use in order to get access to the games. Such information may include IP address, the game version player uses, advertising identifier, operating system (and version), device brand, device configuration, device model, device ID, time zone, connection type, network operator, device language and etc.
Game Data	is information about the games, including information about your in-game profile, date of registration, acceptance of the EULA, in-game achievements, progress and events, in-game purchases, completed game levels and activities, last exit, presence/absence of bans in the game, logs of previous and current game sessions, history of support requests, support chat data, reports and other information that may be generated by the Game.
Location Data	is information about your approximate location as derived from your IP address. For example, IP address, country, subdivision, city, region.
Payments data	is information about purchases/ transactions that you have made. For example, history of campaigns and offers that were available in your in-game profile, payments history (in-app purchases), date of payment, amount of payment, payment pack.
Crash Data	is crash log data from the player game. For example, operating system (and version), device brand, device model, device battery level, device time zone, device ID, connection type, device language, the version of the game you use, pixel density of the screen, screen height, device build ID, charging status, or other information directly related to a crash.
Additional data provided by you	is information you provide to us when addressing our support team (support features in Services), communicate with us through our official communities in social networks, or addressing the email privacy@vizor-apps.com.
Data from your social network profile	is information that you share publicly on the social network.
Email	is your email address, including but not limited to a hashed email address.

 

THE PURPOSES AND LEGAL BASES FOR DATA PROCESSING

 

If you play our games published on Amazon, AppGallery, App Store, and Google Play:

 

purposes	legal basis	personal data
to create accounts and allow you to play and use our games	performance of contractual obligations	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data
to enable in-app purchases	performance of contractual obligations	Player Data and Identifiers Location Data Payments Data Game Data
to log in via Apple/ Google/ Facebook	performance of contractual obligations	Player Data and Identifiers Email
to send you game-related communications	performance of contractual obligations	Player Data and Identifiers Device Data Game Data
to provide technical support and respond to player inquiries	performance of contractual obligations	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data Additional data provided by you
to improve and optimize our games and our players’ experiences, including by measuring interest in and engagement with our games	our legitimate interest to improve and optimize our games and our players’ experiences	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data
to display personalized advertisements from our partners	on the basis of your consent to such processing	Player Data and Identifiers Device Data Game Data Location Data
to provide advertising or marketing services, including attribution & media measurement, ad targeting of our players on social media platforms, ad targeting via ‘custom audience’ and similar systems	our legitimate interest to improve and optimize our games and our players’ experiences	Player Data and Identifiers Device Data Game Data Location Data

 

If you play our games published on our portals klondike-online.com/ knightsbrides.com:

 

purposes	legal basis	personal data
to create accounts and allow you to play and use our games	performance of contractual obligations	Player Data and Identifiers Email Password Device Data Game Data Location Data Payments Data Crash Data
to enable in-app purchases	performance of contractual obligations	Player Data and Identifiers Location Data Payments Data Game Data
to log in via Google/ Facebook	performance of contractual obligations	Player Data and Identifiers Email
to send you game-related communications/ gifts	performance of contractual obligations	Player Data and Identifiers Game Data
to provide technical support and respond to player inquiries	performance of contractual obligations	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data Email Additional data provided by you
to improve and optimize our games, and our players’ experiences, including by measuring interest in and engagement with our games	our legitimate interest to improve and optimize our games, and our players’ experiences	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data Email
to provide advertising or marketing services, including attribution & media measurement, ad targeting of our players on social media platforms, ad targeting via ‘custom audience’ and similar systems	our legitimate interest to improve and optimize our games, and our players’ experiences	Player Data and Identifiers Device Data Game Data Location Data Email

 

If you play our games published on social networking services:

 

purposes	legal basis	personal data
to create accounts and allow you to play and use our games	performance of contractual obligations	Player Data and Identifiers Email Device Data Game Data Location Data Payments Data Crash Data
to enable in-app purchases	performance of contractual obligations	Player Data and Identifiers Location Data Payments data Game Data
to send you game-related communications	performance of contractual obligations	Player Data and Identifiers Game Data
to provide technical support and respond to player inquiries	performance of contractual obligations	Player Data and Identifiers Device Data Game Data Location Data Payments data Crash Data Additional data provided by you Email
to improve and optimize our games, and our players’ experiences, including by measuring interest in and engagement with our games	our legitimate interest to improve and optimize our games, and our players’ experiences	Player Data and Identifiers Device Data Game Data Location Data Payments Data Crash Data Email

 

If you engage with certain activities in social networking services:

 

purposes	legal basis	personal data
to facilitate your participation in contests and activities on our official social networking services, and send you rewards if you win	performance of contractual obligations	Player Data and Identifiers Additional data provided by you
to manage relationships with members of the community, visitors of our pages in social networking service (to answer comments)	our legitimate interest to improve, and optimize our games, and our players’ experiences	Additional data provided by you Data from your social network profile

 

HOW WE COLLECT YOUR PERSONAL DATA

 

Personal data you provide us directly.

We may collect personal data that you directly provide us while using the Services or include it in an email, or other messages that you send us. Such kind of personal data collection would happen during usual business processes.

This personal data may include Player Data and Identifiers, Email, Password, additional data provided by the player, data from the player’s social network profile, Age.

Personal data we collect automatically.

We may automatically collect personal data when you use the Services.

Such personal data may include Player Data and Identifiers, Device Data, Game Data, Location Data, Crash Data.

Personal data we collect from our third parties and partners.

We may receive your personal data from third-party sources and combine it with the personal data we receive directly from you. For example:

• advertisers and analytical partners,

We may receive your Device Data on the performance of our apps from our analytical partners and combine it with the information we receive directly from you. We may also receive your advertising IDs from our advertisers if you have agreed to provide them with your advertising IDs.

• authentication partners,

We may receive your personal data from a third party to create your account on our Services, when you log in to our Services using third-party credentials.

• publishing platforms,

We also receive your personal data from the app stores where our Services are published.

• social networking service,

We may receive your personal data from the social networking service such as your social network ID, name/ nickname, photo profile/ image profile, email, friends list, or other information when you play our games, or access any part of our Service on the social networking service. The personal data we receive from the social networking service depends on your privacy settings on that social network.

Generated personal data.

We can also generate new data about you by computing and generating the personal data we have. Such personal data may include Payment Data, Identifiers (user ID), Game Data.

 

CHILDREN’S PRIVACY

Our Services are not directed to those under the age of majority, however, we are committed to protecting the privacy and safety of all our players, including children. Having said that, we do not intentionally or knowingly collect personal data from children. Nevertheless, we do recognize the importance of complying with the age of requirements which vary from country to country.

We encourage parents to educate their children on safe and responsible internet use, and to contact us if they have any concerns about their child’s data collection, usage, or storage. We understand the importance of parental control over their children’s online activities, and we respect parents’ rights to manage and delete their children’s data. If you become aware that we have unintentionally collected personal data from your child, please do not hesitate to contact us, and we will make all reasonable efforts to stop processing such data and erase it as soon as possible.

 

AUTOMATED DECISIONS/ PROFILING

We neither use automated decision-making nor engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Nevertheless, we may utilize your Game and Payments Data to categorize you as a player and generate a group offer for players within that same category.

 

HOW WE PROTECT YOUR DATA

 

We maintain appropriate administrative, technical and physical security measures to protect your personal data from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing.

We can also anonymize your personal data as soon as we do not need it anymore. Anonymisation is the process of removing personal identifiers, both direct and indirect, that may lead to an individual being identified. The result of this process is anonymous data that cannot be associated with any individual.

 

HOW LONG DO WE STORE YOUR PERSONAL DATA

 

Personal data will be kept only for the time needed to achieve the purposes for which it is processed, unless we have a legal right or obligation to retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

We delete your personal data which we process for the performance of the agreement or based on your consent in case you terminate your agreement with us, withdraw your consent, or where you request to remove your personal data, as described in this Privacy Notice.

We may also periodically de-identify unused player data, and we may regularly check and de-identify unnecessary data.

 

WITH WHOM WE SHARE YOUR PERSONAL DATA

 

The list of our current third parties and partners are available here.

Advertising and analytics partners.

We may use analytics services to collect analytical data, and evaluate the usage of our apps, and improve it and make them more appealing to you as a player.

We use advertising services to facilitate the sharing of information that may be relevant, or interesting to you, such as allowing you to earn rewards for viewing in-game ads.

Customer service platforms.

This type of platforms allows us to manage support and contact requests received via email, or by other means, such as the contact form. 

Law enforcement or government bodies.

In order to combat fraud and illegal activity, situations involving potential threats to the physical safety of any person or as required by law, we may process and disclose data with law enforcement or government bodies in response to lawful requests.

Other players.

If you play or register through a social networking service, other players may see your profile data (name and photo), descriptions of your game activity, and read the messages you have posted. If you use our game in response to an invitation from another player, that player may see certain information about your game activity.

Payment services.

We may share payment data with our payment services that process payment transactions or provide other financial services, and for fraud prevention.

We do not and will not collect or process any information related to your payment instruments, such as your credit card number, its expiration date, or your name as written on your card.

Service providers and partner organizations.

We may share your personal data with our service providers as their respective technical solutions may form an integral part of the Services. We also may share your personal data between and among our affiliated companies.

Standard Contractual Clauses are used to share your personal data to ensure that they are properly protected.

 

INTERNATIONAL TRANSFERS OF PERSONAL DATA

 

Our Service is global, and your personal data can therefore be transferred to anywhere in the world. We apply the Standard Contractual Clauses approved by the European Commission or other appropriate means as legal mechanisms for any such transfer, and make sure that such transfers occur only if there are adequate safeguards in place.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in the country of your residence. By using our Services or providing us with any information through them, you acknowledge such transfer, processing, and storage of your personal data in countries in which privacy regulations may not be as comprehensive as those in the country of your residence.

 

YOUR RIGHTS

 

You have certain rights in connection with your personal data and how we handle it.

 

RIGHTS UNDER THE GDPR

To ensure a swift response, we advise you to contact us through the support features available in our Services if you have any questions regarding data protection or require assistance with resolving issues related to your personal data. Alternatively, you may contact us via email at: privacy@vizor-apps.com.  

Right to access your personal data.

Under art. 15 of the GDPR, you have a right of access that gives you the right to obtain a copy of your personal data, as well as other supplementary information. It helps to understand how and why we are using your personal data, and check the lawfulness of the processing.

Right to rectify (correct) your personal data.

Under art. 16 of the GDPR, you have the right to have inaccurate personal data rectified. You may also be able to have incomplete personal data completed, although this will depend on the purposes for processing.

Right to have your personal data erased (deleted).

Under art. 17 of the GDPR, you have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

Right to restrict processing of your personal data.

Art. 18 of the GDPR gives you the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way that we use your data. This is an alternative to requesting the erasure of your data.

Right to transmit your personal data.

Under art. 20 of the GDPR, you have the right to data portability that gives you the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit those data directly to another controller.

Right to object to processing of your personal data.

Art. 21 of the GDPR gives you the right to object to the processing of your personal data at any time. This effectively allows you to stop or prevent us from processing your personal data.

Right to withdraw your consent for personal data processing.

Art. 7 (3) of the GDPR gives you the right to withdraw your consent for personal data processing. Any withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority.

In accordance with art. 77 of the GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

LIST OF OUR CURRENT THIRD PARTIES AND PARTNERS

 

Last updated: 01 June 2023

 

ADVERTISERS

 

name	link to Privacy Notice	services
Digital Turbine, Inc. (Fyber)	fyber-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
AdColony, Inc.	adcolony-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
AppLovin Corporation	applovin-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Meta Platforms Inc.	facebook-privacy	used for games downloaded from App Store and Google Play; used for games published on our portals (klondike-online.com/ knightsbrides.com); Mahjong Treasure Quest (Amazon AppStore)
HyprMX Mobile LLC	hyprMX-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
ironSource Ltd.	ironsource-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
Unity Technologies (Unity Ads)	unity-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Vungle, Inc.	vungle-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
Mintegral	mintegral-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Bytedance Pte. Ltd. (Pangle)	pangle-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Chartboost, Inc.	chartboost-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore
InMobi	inmobi-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
MGL MY.COM (CYPRUS) LIMITED (MyTarget)	mytarget-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Tapjoy, Inc.	tapjoy-privacy	used for games downloaded from App Store and Google Play; Mahjong Treasure Quest (Amazon AppStore)
Huawei Ads Kit	huaweiadskit-privacy	used for games downloaded from Huawei AppGallery
Google Ads	google-privacy	used for games downloaded from App Store, Google Play, and Amazon AppStore

 

ANALYTICAL PARTNERS

 

name	link to Privacy Notice	services
AppsFlyer Ltd.	appsflyer-privacy	used for games downloaded from App Store, Google Play, Huawei AppGallery, Amazon AppStore and Microsoft Store
Meta Platforms Inc. (Facebook Analytics)	facebook-privacy	used for games downloaded from App Store, Google Play, Huawei AppGallery, and Amazon AppStore; used for games published on our portals (klondike-online.com/ knightsbrides.com)
Google LLC (Firebase)	firebase-privacy	used for games downloaded from App Store and Google Play; used for games published on our portals (klondike-online.com/ knightsbrides.com)
Google LLC (BigQuery/ Google Analytics/ Search Console/ Google Tag Manager)	google-privacy	used for games published on our portals (klondike-online.com/ knightsbrides.com)
Hotjar Ltd.	hotjar-privacy	used for games published on our portals (klondike-online.com/ knightsbrides.com)
YANDEX LLC (AppMetrica)	appmetrica-privacy	Riddle Road: Solitaire
Upland (Localytics)	localytics-privacy	Riddle Road: Solitaire; Charmbrook:​ Merge Adventure; Mahjong Treasure Quest

 

CUSTOMER SERVICE PLATFORMS

 

name	link to Privacy Notice	services
Helpshift	helpshift-privacy	used for all Services

 

PAYMENTS SERVICES

 

name	link to Privacy Notice	services
Apple Inc. (Apple Pay)	apple-privacy	used for games downloaded from App Store; used for games published on our portals (klondike-online.com/ knightsbrides.com)
Google LLC (Google Play In-App Payments)	google-privacy	used for games downloaded from Google Play; used for games published on our portals (klondike-online.com/ knightsbrides.com)
Adyen	adyen-privacy	used for games published on our portals (klondike-online.com/ knightsbrides.com)
PayPal	paypal-privacy	used for games published on our portals (klondike-online.com/ knightsbrides.com)

 

DISCLOSURE FOR

CALIFORNIA, COLORADO, CONNECTICUT AND VIRGINIA RESIDENTS

 

 

Disclosure will be effective from 01 June 2023

 

Your privacy is and will always be enormously important to us.

If you are a resident of California, Colorado, Connecticut, or Virginia, please read additional information below carefully because it is important for you to understand what we do with your information, how you can control it, and the privacy requests you may make under applicable law.

 

THE PERSONAL DATA WE COLLECT, OUR PURPOSES AND LEGAL BASES FOR DATA PROCESSING

 

The categories of personal data, our purposes for collecting your personal data, the sources and the legal bases of said data we have collected in the preceding 12 months are described in the section ‘THE PERSONAL DATA WE COLLECT’, ‘THE PURPOSES AND LEGAL BASES FOR DATA PROCESSING’ in our Privacy Notice.

 

WITH WHOM WE SHARE/ OR SALE YOUR PERSONAL DATA

 

Please note that we do not ‘sell’ the personal data of our players to third parties and partners as most people would understand that term, however, we may share the personal data of our players with our third parties and partners such as advertising companies in order to improve and personalize your experience, adapt the content and interest-based advertisements of our Services, and attribute installs, and optimize our campaign performance.

As described in the section ‘WITH WHOM WE SHARE YOUR PERSONAL DATA’ in our Privacy Notice, we share personal data of our players within VIZOR and with third parties and partners for business purposes.

 

YOUR RIGHTS AND OPTIONS

 

You have certain rights in connection with your personal data. We describe below the rights that may be available to you, depending on your state of residence.

Right to request access to your personal data.

You have the right to confirm whether we are processing your personal data concerning the consumer and to request, up to two times in a 12-month period and free of charge, access to the personal data we have collected about you.

Right to request correction of inaccuracies in your personal data.

You have the right to correct inaccuracies in your personal data that we have collected about you. Some data may be exempt from such requests under law.

Right to have your personal data erased (deleted).

You have the right to request the deletion of personal data that we have collected about you, subject to certain exceptions. Some personal data may be exempt from such requests under law.

Right to data portability.

You have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your personal data to another controller without hindrance.

Right to designate an authorized agent.

In certain circumstances, you are permitted to use an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to us, as required by applicable law. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we may deny the request.

Right to opt out.

for California residents:

You have the right to opt out of the sale of personal data or the sharing of your personal data with third parties for targeted advertising (also known as cross-context behavioral advertising or interest-based advertising). You have the right to opt out of sale of your personal data, as defined by the CCPA.

for Colorado, Connecticut and Virginia residents:

You have the right to opt out of the processing of your personal data for purposes of targeted advertising; the sale of personal data; or profiling in furtherance of decisions (or solely automated decisions (Connecticut) that produce legal or similarly significant effects concerning you.

Right to non-discrimination.

We may not discriminate against you for exercising any of your rights, including but not limited to  denying goods or services to the resident; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to the resident; suggesting that the resident will receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to action.

If you are not satisfied with our response to your requests, appeal our decision by contacting us as described in the written notice we will provide you.

California ‘Shine the Light’.

California Civil Code Section 1798.83 permits players who are California residents to request certain information regarding disclosure of personal data to third parties for their own direct marketing purposes. We do not share our players’ personal data with unaffiliated third parties for their own direct marketing purposes without your consent. For inquiries about our disclosure notice, please contact us via email at: privacy@vizor-apps.com or by mail: Archiepiskopou Makariou III, 169, CEDAR OASIS TOWER, flat/office 701, 3027, Limassol, Cyprus.