POLICY SUMMARY

Personal Data collected for the following purposes and using the following services:

Advertising: ADMOB, TAPJOY

Personal Data: Cookies and Usage Data

Advertising serving infrastructure

OpenX Ad Server

Personal Data: Cookies and Usage Data

Analytics

Google Analytics

Personal Data: Cookies and Usage Data

Unity Analytics

Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service

Contacting the User

Contact form

Personal Data: email address

Location-based interactions

Non-continuous geolocation

Personal Data: geographic position

Registration and authentication

Google OAuth

Personal Data: various types of Data as specified in the privacy policy of the service

FURTHER INFORMATION ABOUT PERSONAL DATA

See details in “Full Policy”

Push notifications:

This Application may send push notifications to the User.

Access to media/files/photos:

The application has the ability to use the file on the device with the application installed. This includes reading and writing to the SD card and USB storage. The app can also mount and unmount external storage as well as format external storage. This permission deals with reading external storage on newer devices.

Access to device information and call information:

An app can access your device ID(s), phone number, whether you're on the phone, and the number connected by a call. Device ID & call information may include the ability to read phone status and identity.

Access to network (wifi / cellular) state:

Application may require an access to the internet.

Access to credentials:

Application uses this access for Google OAuth.

Access to accounts:

App may use this access for Google Play Games Services.

Selling goods and services online:

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.

User identification via a universally unique identifier (UUID):

This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences.

CONTACT INFORMATION

Data owner: PenCraft App Mods., Moscow, Russia

Data owner e-mail:

pencraftappmods456@gmail.com

FULL POLICY

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, email address and geographic position.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Advertising, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Advertising serving infrastructure, Contacting the User, Location-based interactions and Registration and authentication.

The Personal Data used for each purpose is outlined in the specific sections of this document.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following services:

Advertising:

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

Appodeal (Appodeal Inc.)

Appodeal is an advertising service provided by Appodeal Inc. (Delaware Corporation)

Personal data collected: Cookies and Usage Data

Place of processing: US - Privacy Policy

AdColony (Jirbo, Inc.)

AdColony is an advertising service provided by Jirbo, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt out

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Amazon Mobile Ads (Amazon)

Amazon Mobile Ads is an advertising service provided by Amazon.com, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

AppLovin (AppLovin Corporation)

AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt out

Chartboost (Chartboost, Inc.)

Chartboost is an advertising service provided by Chartboost Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Heyzap (Fyber GmbH)

MoPub is an advertising service provided by Fyber GmbH.

Personal Data collected: Cookies and Usage Data.

Place of processing: Germany– Privacy Policy

MoPub (MoPub Inc.)

MoPub is an advertising service provided by MoPub Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

OpenX Ad Exchange (OpenX Technologies, Inc.)

OpenX Ad Exchange is an advertising service provided by OpenX Technologies, Inc.

The service provides an ad exchange platform that facilitates the optimization of ads from multiple ad networks, which can be third parties to both OpenX and the Owner.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out

StartApp (StartApp, Inc.)

StartApp is an advertising service provided by StartApp, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Tapjoy (Tapjoy Inc)

Unity Ads is an advertising service provided by Tapjoy Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US– Privacy Policy

Unity Ads (Unity Technologies ApS)

Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: Denmark – Privacy Policy

Vungle (Vungle, Inc.)

Vungle is an advertising service provided by Vungle, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Yandex (Yandex, Inc.)

Yandex is an advertising service provided by Yandex, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Fyber (SponsorPay GmbH)

Fyber is an advertising service provided by Fyber GmbH.

Personal Data collected: Cookies and Usage Data.

Place of processing: Germany – Privacy Policy

Advertising serving infrastructure:

This type of service has the purpose of providing an advertising serving infrastructure that enables this Application to maintain its own network that serves optimized and targeted advertisements.

To this end, the services listed below may allow the Owner to track unique User visits and their navigation patterns, also with the help of Cookies.

This tracking may occur across different sites or apps, in order to serve optimized and targeted advertisements.

OpenX Ad Server (OpenX Technologies, Inc.)

OpenX Ad Server is an advertising server provision service provided by OpenX Technologies, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Analytics:

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out

Unity Analytics (Unity Technologies ApS)

Unity Analytics is an analytics service provided by Unity Technologies ApS.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Denmark – Privacy Policy

Contacting the User

Contact form (This Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Location-based interactions

Non-continuous geolocation (This Application)

This Application may use User location Data in order to provide targeted advertising.

Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.

The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data collected: geographic position.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. This Application is able to access some Data, stored by these third party services, for registration or identification purposes:

Google OAuth (Google Inc.)

Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy

Remarketing and behavioral targeting

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.

Google OAuth (Google Inc.)

Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy

FURTHER INFORMATION ABOUT PERSONAL DATA

Push notifications:

This Application may send push notifications to the User.

Removing push notifications:

For Android: After an Application is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the Application and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the Application.

Access to media/files/photos:

The application has the ability to use the file on the device with the application installed. This includes reading and writing to the SD card and USB storage. The app can also mount and unmount external storage as well as format external storage. This permission deals with reading external storage on newer devices. Please be aware that we use this access ONLY to temporary write to the SD card or USB storage status of a game (savegame) or to download an advertisement. All files will be deleted when not needed anymore. We do not read, store, copy or use your personal data such as photos, messages, or any other informations you store on your device.

Access to device information and call information:

An app can access your device ID(s), phone number, whether you're on the phone, and the number connected by a call. Device ID & call information may include the ability to read phone status and identity. The app uses this access to check the status of the phone (awake/sleep) or whether the phone call is held. The app does not listen to any phone calls, does not use the phone numbers stored on the device and does not use the call information to any other purposes than checking the status of the phone. This access is mostly used by advertisers.

Access to network (wifi / cellular) state:

Some features (like chat, ads, leaderboards) of the Application may require an access to the Internet therefore the Application needs to check the Internet connection.

Access to credentials:

The Application uses this access for Google OAuth (payments).

Unique device identification:

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

Access to accounts:

App may use this access for Google Play Games Services.

CHAT FEATURE

There is a chat function within the app, which allows the player to have a conversation with a virtual person (a bot). Data from the conversation are stored on the player’s device in order for the player to return to the previously started conversation. A part of the data is stored on the server in order to maintain the context of the conversation. The bot uses the information provided by the player (e.g. player’s replies about their favourite music) to choose the context of the conversation. These data are not made available to any outside party (with the exception of legal institutions, such as the police or the court, if they submit a proper request). The data are deleted after a year. No outside person has the access to the stored data. We do not sell or give access to the data stored on the server. Furthermore, we would like to point out that the function is still being improved so that it is safe and proper for all users of all ages.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User's device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to this Application.