Apelsin Games


Privacy Policy


Version 1.0


Effective as of 10 April 2018


This privacy policy (the “Privacy Policy”) explains how this iOS and Android based mobile game platform application (the “Application”) maintained by Apelsin Games SIA, a company established pursuant to the laws of the Republic of Latvia with registration number 40203040474, having its registered address at Dzirnavu iela 57A - 4, Rīga, LV-1010 (“Apelsin Games”, “we” or “us”), collects and uses information when you (the “User”) interact with us. This Privacy Policy applies to all the Users of the Application. By using or interacting with any of the services provided by Apelsin Games under this Application you agree to the provisions of this Privacy Policy and consent you have read and understood all of the provisions stated herein. Further, you provide freely given, specific, informed and unambiguous consent that Apelsin Games may process your personal data as provided under this Privacy Policy where you consent is the basis for the processing of your personal data. Please read the provisions of this Privacy Policy carefully and do not hesitate to contact us if necessary.


  1. 1.Data Collected 

    1. 1.1.Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  

    2. 1.2.If you are a natural person, who authorises into the Application using your Facebook, Inc. platform www.facebook.com (“Facebook”), profile we collect the following personal data (“Personal Data”) about you: 

      1. 1.2.1.Any of the publicly available information about you indicated in your Facebook profile, which depending on the circumstances can be but is not limited to first name, last name, age, profile picture, gender, location, uploads and information shared to your Facebook profile and is publicly available; 

      2. 1.2.2.Unique identification number assigned to you by us in the Application; 

      3. 1.2.3.Information about your activities carried out while using the Application including your gaming experience and interactions within the Application; 

      4. 1.2.4.Any additional information that you provide about you in your Application user profile (“Profile”).  

    3. 1.3.If you are a natural person who authorises into the Application directly through the Application, we collect the following Personal Data about you: 

      1. 1.3.1.Unique identification number assigned to you by us in the Application; 

      2. 1.3.2.Information about your activities carried out while using the Application including your gaming experience and interactions within the Application; 

      3. 1.3.3.Location of your device. If you wish, you can disable location tracking function in your device; 

      4. 1.3.4.Any additional information that you provide about you in your Application user profile (“Profile”). 

    4. 1.4.The data collected about you is necessary for Apelsin Games to ensure basic functions of the Application as well as to develop its functionality and analyse the use of the Application to improve your experience when using this Application. 

    5. 1.5.The data collected about you in the Application is also summarised into statistics that may be given to third parties such as advertisement or media agencies. Statistics contain only the criteria and numeral data, therefore, a natural person cannot be identified by the aforementioned third parties, and we do not transfer your Personal Data to such third parties.  

    6. 1.6.Pease note that other Users of the Application can see the information available at your Profile or related to your public activity in the Application.  


  1. 2.How the Data is Collected 

    1. 2.1.We may: 

      1. 2.1.1.collect Personal Data from you when you register, create an account, or otherwise interact with the Application.  

      2. 2.1.2.we also may receive your Personal Data from such third parties whose services we use in order to ensure you with a possibility to get authorized to use the Application, such as Facebook. 


  1. 3.Purposes and Basis for Personal Data Processing 

    1. 3.1.By downloading and using the Application you give a freely and informed consent to the processing of your Personal Data. You have the right to withdraw your consent at any time in accordance with Clause 5.4 of this Privacy Policy.  

    2. 3.2.Apelsin Games processes your Personal Data based on your consent to: 

      1. 3.2.1.ensure the possibility to use the functionality of the Application described in the terms and conditions or another relevant document. In cases where you accept the terms of any other document, to which you and Apelsin Games are parties, the Personal Data is also processed for the performance of the obligations of Apelsin Games and pursuant to the purposes referred to in such document; 

      2. 3.2.2.communicate and provide additional information that may be of interest to you about our services; 

      3. 3.2.3.send you reminders, technical notices, updates, newsletters, security alerts and support and administrative messages, service bulletins, or marketing materials; 

      4. 3.2.4.provide advertisements to you through third-party websites, e-mail messages, text messages, applications, or other methods of communication. 

    3. 3.3.Please note that if we do not have you consent for the processing of your data for the aforementioned purposes, we will not be able to provide you certain services or functionalities within the Application that are based on the processing of your Personal Data.  


    1. 3.4.Apelsin Games processes your Personal Data based on our legitimate interests (such as business development and development of the Application functionality) to: 

      1. 3.4.1.operate and improve the Application; 

      2. 3.4.2.evaluate eligibility of the Users to receive our services; 

      3. 3.4.3.evaluate the type of services that may be of interests to the Users; 

      4. 3.4.4.identify the most active use of our services by location in order to ensure the client-oriented provision of the Services and our business development; 

      5. 3.4.5.perform various analytics; 

      6. 3.4.6.provide customer support to the Users; 

      7. 3.4.7.fulfil requests related to our services; 

      8. 3.4.8.provide the statistical information to third parties such as advertisement or media agencies, Google Inc., bloggers in order for them to place their targeted advertisements of the Application using the third-party services; 

      9. 3.4.9.manage our everyday business needs such as the Application administration, analytics, fraud prevention, or to comply with provisions of the applicable law. 


    1. 3.5. Decisions pursuant Clause 3.4.2. of this Privacy Policy are partly automated, the eligibility of the Users to receive our services is established by the Personal Data provided either through Facebook or yourself. 


    1. 3.6.Subject to specific statutory requirements, we may provide your Personal Data to corresponding authorities. Please note that if Apelsin Games has an obligation to provide your Personal Data to third parties according to the statutory requirements, you will not have the right to request us to stop such processing of your Personal Data. 


  1. 4.Data Storage and Transfer 

    1. 4.1.We may transfer your Personal Data to such recipients as technical services providers, advertisement or media agencies, Supervisory authorities, including but not limited to such recipients: 

      1. 4.1.1.State authorities and other authorized parties that may request us to provide your Personal Data subject to specific statutory requirements; 

      2. 4.1.2.Technical services providers such as developers who may access your Personal Data while performing testing or support activities. However, we minimize the amount of the Personal Data available to such recipients; 

      3. 4.1.3.Other Users who may see Personal Data available about you in your Profile.  

    2. 4.2.We will only store your Personal Data for as long as it is needed to fulfil the purposes for which it was collected, subject to applicable data retention periods imposed upon by the applicable legislation as well as until such time as is required to meet the aforementioned Personal Data processing purposes. If the game is accessed via Facebook, the use of the Application can be continued through any other device by logging into your Profile. However, if you access the Application via your Profile made in the Application, the Application may only be used from the device that Profile is created in. Moreover, the Personal Data that is collected and stored in case you use your Facebook profile to log into the Application is stored for a longer period of time in order to ensure you with the possibility to continue sing from another device. If the Application is accessed only by logging directly into your Profile through the Application, the Personal Data are stored while the Application is in use.   

    3. 4.3.The Data collected from you may be transferred to, and stored at, a destination outside the European Union ("EU"). It may also be processed by data processors operating outside the EU such data storage service providers. We may also disclose information about you that is not personally identifiable or in case required under applicable laws and/or required by state or municipal authorities.  

    4. 4.4.By submitting your data, you agree to the processing of your data including storing and transfer outside the EU for the purposes set out in this Privacy Policy. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with the applicable data protection laws and regulations. We will not store your data longer than necessary to fulfil the purposes set out in this Privacy Policy. For example, we may transfer your Personal Data based on the adequacy decision of the European Commission, standard data protection clauses elaborated by the European Commission or supervisory authorities. or by using other possible safeguards and derogations where it is allowed by the applicable laws. You may receive the necessary copies of them by addressing us using the contact information indicated in this Privacy Policy. 

    5. 4.5.Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Application, therefore any transmission is at your own risk and you are free to choose whether to use our Application or not. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. 


  1. 5.Access to Data and Other Rights 

    1. 5.1.If you are a natural person and have provided your personal data to us you have the right to access to your data and to receive the information on: the purposes of the processing, the categories of personal data concerned; the categories of recipient to whom the personal data have been or will be disclosed, retention term if applicable, your rights, information on the source from which your personal was received by us, information on the automated decision-making and profiling. 

    2. 5.2.You also have the right to request a copy of your personal data that we process. For any further copies requested, we may charge a reasonable fee based on administrative costs.  

    3. 5.3.You have the right to request rectification or erasure of your personal data or restriction of processing or to object to processing, to lodge a complaint with a supervisory authority, as well as the right to data portability. 

    4. 5.4.You are free to refuse from any further processing of your personal data at any time by informing us by e-mail: a.logachev@apelsingames.com, if the processing of your Personal Data is based on your consent as indicated above. Such withdrawal will not affect the lawfulness of processing done before the withdrawal, however, it may impact your further use of our services. 


  1. 6.Third-party Data 


    1. 6.1.You may not upload or otherwise submit to the Application the personal data of other natural persons, for example, other users of Facebook. 


    1. 6.2.By accepting this Privacy Policy, you confirm that you understand that you are completely responsible and liable for the processing of the personal data of such third parties via Application. Apelsin Games shall be neither responsible nor liable for the personal of the third parties that you process via Application.  


    1. 6.3.Hereby you confirm that you understand that you have the right to use Application for the processing of the third party’s personal data only if you have a legal basis to carry out such activities with the personal data and if you comply with the requirements of the applicable laws. 

  1. 7.General terms and conditions 

    1. 7.1. You are liable for the appropriate use of our Application. Any action which causes or could cause any disturbance to the operations of Application is strictly prohibited. You may not interfere into the operations and technical solutions of Application.  

    2. 7.2. All copyrights in or to the Application or part of them are owned by us, our licensors or our partners, who reserved their rights. Any kind of monitoring of the Application and/or copying, reproducing, usage or republishing of the acquired information, as well as its contents unless it is stated otherwise is strictly prohibited without our prior written consent.  

    3. 7.3.We are entitled to prohibit you the usage of the Application if there are sufficient grounds to consider that this Policy is not complied with.  


  1. 8.Modification of the Privacy Policy 

Apelsin Games may revise the terms and conditions of this Privacy Policy at any time without notice. By using this Application, you are agreeing to be bound by the current version of this Privacy Policy.


  1. 9.Governing Law 

Any disputes arising from this Privacy Policy shall be governed by the laws of Latvia and subject to the exclusive jurisdiction of the courts of the Republic of Latvia.


  1. 10.Contact Information 

If you have any questions about this Privacy Policy, please contact us at: a.logachev@apelsingames.com,  +371 2 5704245