PRIVACY POLICY
Effective Date: June 01, 2023
Thank you for playing our games! This Privacy Policy describes:
What Personal Data we collect from you,
The ways we collect your Personal Data and why we do so,
How we process your Personal Data, and
The choices you have regarding your Personal Data.
This Privacy Policy applies to 2HERO MOBI games, websites and related services, which we here collectively call the “App”. We may periodically update this Privacy Policy by posting a relevant notification at home page of the App. Your continued use of the App after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your Personal Data, we will request your consent or your renewed consent (in case it was obtained previously).
If you do not agree with this Privacy Policy, PLEASE do not download or use our APP.
CONTACT US
If you have questions regarding your Personal Data, we encourage you to contact us by e-mail at galaxygame2k@gmail.com.
2HERO MOBI is a controller and is responsible for collection and processing of your Personal Data (collectively referred to as “we”, “us” or “our”).
2HERO MOBI
Address: HaNoi - VietNam
e-mail: galaxygame2k@gmail.com
THE DATA WE COLLECT
When you use our App we collect information about you that can directly or indirectly identify you (“Personal Data”):
We receive Personal Data you provide us yourself, which includes:
Contact Data (name and e-mail address) and other data that you provide to us.
We process your Contact Data if you provide it to us when contact us on technical support issues, leaving feedback, etc.
Profile Data (nickname and profile photo). If you log into the App using third-party site or platform we can also collect other Personal Data as described in the section “Data we collect from our partners”.
The following groups of Personal Data are collected automatically:
Technical Data (your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI, IDFA), device name and operating system, browser type and language, general location data, precise geo-location data (GPS, with your consent)),
Usage Data (information about your use of the App, such as gameplay data and your interactions with other users inside the App, game progress, your in-app purchases). We also can create a Kurshi-specific ID for you when you use the App.
Technical Data is collected with the help of cookies. More information on how we use cookies can be found in the section “Cookies and similar technologies”.
Data we collect from our partners.
If you log into the App using a third-party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access your Personal Data from that site or platform, such as your screen name, profile information and friend lists, in accordance with the privacy policy of such third-party site or platform.
You can learn more about how such third-party sites or platforms process your Personal Data in the relevant privacy policy:
Facebook: https://www.facebook.com/about/privacy/
Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
Google Play Games https://policies.google.com/privacy
If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the applicable jurisdiction.
Data storage.
We respect the importance of your Personal Data, so we make every effort to store your Personal Data in a format that cannot be linked to a particular user. We keep your Personal Data related to activities within the App separate from your Contact Data (until you log into the App using a third-party site or platform, after which your Personal Data related to activities within the App is linked to your Personal Data received from relevant third-party site or platform in accordance with their privacy policy).
WHY DO WE COLLECT YOUR PERSONAL DATA
To provide access to the App.
To perform the contract concluded with you, we process your Personal Data as follows:
Give you correct access to the App,
Create account within the App,
Provide and deliver products and services you request within the App,
Send you App-related information, such as updates, security alerts, and support messages,
Enable you to communicate with other users.
For these purposes we collect and process your Contact Data, Profile Data, Usage Data and Technical Data.
To keep the App safe and fair.
Ensuring a level playing field in the App is a top priority for us.
In order to keep the App and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest based on the balance of interests to process necessary Personal Data in order to:
Analyze and monitor use of the App and its social features,
Respond to your comments and questions and provide player support,
Take action against fraudulent or misbehaving users.
For these purposes we collect and process your Contact Data, Profile Data, Usage Data and Technical Data.
To make the App more suitable for you.
To develop and improve the App and player experience we pursuing our legitimate interest based on the balance of interests to collect and process necessary Personal Data in order to:
Provide social features as part of the App,
Analyze your App experience,
Send you App-related communications, including our offers and recommendations,
With your explicit consent we may process your GPS location to show you users and communities near you.
For these purposes we collect and process your Contact Data, Profile Data, Usage Data and Technical Data.
To show you personalized advertisements.
To show you personalized advertisements in the App we use your explicit consent as a basis for processing of your Personal Data necessary to:
Track the content you access and your online behavior in connection with the App,
Deliver, target and improve our advertisements in the App.
For these purposes we collect and process your Profile Data, Usage Data and Technical Data.
If you want to renew your profile used for personalized advertising, you can reset your Mobile Advertising ID (GAID or IDFA) by yourself by following means:
IOS: go to “Settings” then “Privacy”, then “Advertising” and then “Reset Advertising ID” (see demo on Apple Support).
Android: go to “Settings” then “Google” then in “Ads” then “Reset Advertising ID” (see demo on Google Support).
Be aware. By resetting your Mobile Advertising ID you will still receive advertising on your mobile phone, but this will not be “personalized advertising” anymore and may not correspond to your interests.
WHO CAN SEE YOUR PERSONAL DATA
Apart from us, your Personal Data can be accessed by others in the following situations:
Other users.
Other users may see your in-App progress and read messages you have posted if they are intended to be publicly available.
Our partners.
We have partners which we attract to perform services regarding the App, such as hosting, player support, advertising, analytics and fraud prevention. These partners process your Personal Data only at and according to our instructions.
We can share your Personal Data with our partners only if the purposes listed in this Privacy Policy require so, and only in relevant amounts.
The following SDKs are implemented in the App and through which the relevant partners receive your Personal Data:
Facebook SDK,
Mail.ru SDK.
We also use IronSourse as an advertising partner that can display in-App advertisements.
Other companies and public authorities.
We may also disclose your Personal Data to comply with the law or to protect the rights, property or safety of us, our users or others. Particularly, in order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
Social media partners.
The App may include features from our partners such as social media interaction tools (such as the Facebook “Like” button). If you use features from our partners they may access your Personal Data collected by us. Please note that they operate under their own privacy policies.
Our corporate affiliates.
We may share your Personal Data with our corporate affiliates to be used in a manner consistent with this Privacy Policy. If we or our assets acquired or transferred in part or in whole to another organization, your Personal Data and any other information we have collected may be among the items transferred.
COOKIES AND SIMILAR TECHNOLOGIES
Like most online services, we and our partners use cookies and similar technologies.
Cookies are small text files sent to your computer or mobile device that enable services and website features to function properly. Cookies make it easier for you to use the App during future visits. They also allow us to monitor traffic and to personalize the content of the App for you.
Some of our cookies are necessary for certain uses of the App. These cookies allow us to make our App usable by enabling basic functions like page navigation and access to secure areas of the App. The App cannot function properly without these cookies.
We also have created and implemented our cookies and cookies from third parties for analytical and marketing purposes. Analytical and marketing cookies, among other things, collect information on how users use our App, the content and products that users view most frequently and the effectiveness of our third-party advertising.
The list of third-party cookies that we use is specified in the section “Our partners”. You can generally activate or later deactivate the use of cookies through a functionality built into your web browser or mobile device.
To learn more about how to control cookie settings through your browser:
Chrome – link
Internet Explorer – link
Safari – link (desktop) and link (mobile)
Firefox – link
For other browsers, please, consult the documentation that your browser manufacturer provides.
On your iPhone, iPad or Android device, you can change your device’s privacy settings to control whether you see online personalized advertisements:
iOS device: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.
Android device: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
You can also contact us via galaxygame2k@gmail.com with the request to disable particular categories of cookies.
International data transfers.
Our App is global by nature and your Personal Data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
YOUR RIGHTS AND OPTIONS
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total.
You have the following rights regarding your Personal Data we hold about you, unless provided otherwise by applicable law.
Opt-out of marketing e-mails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing e-mails from us by following the instructions in such communications.
Access the Personal Data we hold about you.
If you request, we will provide you a copy of your Personal Data in an electronic format. The request should be provided to via e-mail at galaxygame2k@gmail.com. You can access the following information upon your request:
the purposes of the processing;
the categories of Personal Data concerned;
the recipients or categories of recipient to whom the Personal Data have been or will be disclosed;
the planned period for which the Personal Data will be stored.
Your other rights.
You also have the right to correct your Personal Data, have your Personal Data deleted, object how we process or share your Personal Data, and restrict how we process or share your Personal Data. You can at any time send us a relevant request to correct, delete, stop or restrict processing or sharing of your Personal Data via e-mail at galaxygame2k@gmail.com.
If your explicit consent serves the basis for Personal Data processing, you can withdraw the consent at any time sending a relevant request via e-mail at galaxygame2k@gmail.com. You can also withdraw your consent using your device’s settings, for example by turning off GPS location sharing in your mobile device settings.
RIGHTS OF CALIFORNIA RESIDENTS
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by e-mail.
Right to opt out.
Under the California Consumer Privacy Act (CCPA) each California resident can request business stops selling Personal Data to third parties.
Do we actually "sell" Personal Data?
We do not, and will not, provide your Personal Data in direct exchange for money. Therefore, in the literal sense, we do not sell your Personal Data. However, we disclose some categories of Personal Data we collect to the third parties as explained in the section “Who can see your Personal Data”.
To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at galaxygame2k@gmail.com to exercise your right to withdraw your consent on sharing your Personal Data with third parties.
Other rights.
You also have a right to be informed about what categories of Personal Data we are collecting: you can request us to disclose what Personal Data we have collected in the past 12 months and right to get a free copy of your Personal Data disclosed in a readily usable and readable format. You can also request us to delete the Personal Data we have collected in the past 12 months. We will not discriminate against you for exercising any of your rights granted under CCPA.
Mandatory verification.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful log into your account in the App or the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you do not have an account in the App and have disable cookies, changed the device you used to access the App or you already requested us to delete your Personal Data.
HOW DO WE PROTECT YOUR PERSONAL DATA
Security Safeguards.
In order to ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your Personal Data from unauthorized access or against loss, misuse or alteration.
Data retention.
We retain your Personal Data for as long as it is necessary to fulfill the purposes specified in the section “Why do we collect your Personal Data”. We regularly (at least once a year) review and de-identify unnecessary data to store it for research or statistical purposes only.
Note that if you ask us to delete your Personal Data, we can retain your Personal Data as necessary to comply with our legal obligations or resolve disputes.
AGE LIMITS
We do not knowingly collect or solicit Personal Data about or direct or target personalized advertisements to anyone under the age of 13, except in European Economic Area (EEA), where the age is limited to users under 16, or knowingly allow such persons to use our App. If you are under the age of 13 (or 16 if you live in EEA territory), please do not send any Personal Data to us. If we learn that we have collected Personal Data about a child under age 13 (or 16 if applicable), we will delete that Personal Data as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of 13 (or 16 if applicable), please contact us at galaxygame2k@gmail.com.