● This Privacy Policy explains how your personal data is collected and processed by

GamesTurf Studio (“GamesTurf”) when you use the our mobile application (the “App”).

● The App is a free to play game (with optional in-game-purchases), and in order to

maintain the high quality and a great game experience we process information from and

about you in particular to improve the entire experience in the App and to support

internal operations.

● We update the Privacy Policy from time to time. If we make changes, we will notify you

by revising the date at the top of the policy and, depending on the specific changes, we

will provide you with additional notice or require a renewed consent. We encourage you

to review the Privacy Policy whenever you access the App to stay informed about how

we process your personal data and how you can protect your privacy

COLLECTION OF INFORMATION

Information we collect automatically through the app

● When you access or use the App, we automatically collect general information about you,

including:

○ Age: we log your age as indicated by you in the age gate upon downloading the App.

○ Log Information: We log information about your use of the App, including the type

of device you use, the features you use, access times and your IP address.

○ Device Information: We collect information about the device you use to access the

App, including information about the device’s software and hardware, unique device

identifiers (i.e. Device ID and advertising ID), device tokens for push-messages,

mobile network information and time zone.

○ Usage Information: We collect information relating to your use of the App, including

you

○ Consumption information: We collect information about your consumption habits

relating to your use of the App, including which purchases you make with both

virtual and real currencies and the reception of virtual goods in-game.

Information we collect from other sources

● 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 information about you from that site or platform,such

as your screen name, profile information and friend lists, in accordance with the

authorisation procedures determined by such third party site or platform provided that you

have given the third party site in question such consent.

● 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 individual jurisdictions.

Use of information – purpose and legal basis

● We use information about you for the following purposes in accordance with the legal bases

for each type of personal data as described below:

Age

● is being processed:

○ to identify whether you are a child or adult for data protection purposes to

determine the legal requirements for our processing of your data.;

○ Our processing for the above purpose is necessary for compliance purposes, see

Article 6(1)(c) of the GDPR. 1

○ to monitor and analyze trends, usage and activities in connection with the App.

○ Our processing for the above purposes is justified by our legitimate interests in

providing content of interest to you and improving our services in accordance with

Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").

Log-, device-, usage-, and consumption information

● are being processed:

○ to provide and deliver the products and services you request and send you related

information as requested by you / as agreed with you;

○ to provide and maintain the App and the game experience; and

○ to send you technical notices, updates, security alerts, and support and

administrative messages; Our processing for the above purposes is necessary for the

performance of a contract to which you are party in order to support the operation

of the App, facilitate the delivery of requested products and services and enable

maintenance and update of the App, see Article 6(1)(b) of the GDPR.

○ to provide news and information about the App that we think will be of interest to

you;

○ to personalize and improve the App and provide tailored content and features;

○ to monitor and analyze trends, usage and activities in connection with the App; and

○ to provide children (as this term is construed under GDPR in EU, COPPA in the US

and relevant applicable legislation in other jurisdictions) with reasonable contextual

advertisements in the App. Our processing for the above purposes is justified by our

legitimate interests in providing advertisements and content of interest to you and

improving our services in accordance with Article 6(1)(f) of the GDPR (also known as

"the balancing of-interest rule").

○ to provide non-child users that have given us consent to share their advertising IDs

with our ad network partners (as further specified under Sharing of Information) for

the purpose of serving them with personalized advertisement in the App (behavioral

advertising). Our processing for the above purpose is justified by our legitimate

interests in providing advertisements and content of interest to you in accordance

with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties

for the purposes of behavioral advertising is based on your consent in accordance

with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).

Information from other sources

● are being processed:

○ to provide and deliver the products and services you request and send you related

information;

● Our processing for the above purpose is necessary for the performance of a contract to

which you are party in order to facilitate the delivery of requested products and services,

see Section 6(1)(b) of the GDPR.

○ to link or combine information we get from others to help understand your needs

and provide you with better service; and m. to provide news and information about

the App we think will be of interest to you;

● Our processing for the above purposes is justified by our legitimate interests in providing

content of interest to you and improving our services in accordance with Article 6(1)(f) of

the GDPR.

● We only process your information to the extent that is necessary to achieve the purposes

for which the information has been collected.

Storage of information

● GamesTurf will store your personal data for as long as necessary in order to provide you

with the App or otherwise fulfil the purposes as described above, unless further storage is

required in order to establish, exercise or defend a legal claim or to comply with applicable

law, including accounting rules.

● Your personal data are deleted or anonymized as soon as it no longer serves one of the

above mentioned purposes and in any event no later than three (3) years after your

interaction with GamesTurf has ceased.

Sharing of information

● We disclose information about you to the following categories of recipients based on the

legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal

bases above):

○ Social networks, see more under "Social Sharing features";

○ Third parties if we are required to disclose your personal data by applicable law,

rule, regulation, legal process or in connection with, or during negotiations of, any

merger, sale of company assets, financing or acquisition of all or a portion of our

business by another company;

○ The authorities if we believe your actions are inconsistent with the spirit or language

of our policies or if the disclosure is necessary to protect the rights, property and

safety of GamesTurf or others;

○ Other players in order to provide certain in-app features, such as leaderboards, if 
you log into the App using a third party service, such as Facebook or Apple Game 
Center; 
○ Advertising network companies in order to serve contextual advertisements (the 
data include your IP-address, Device ID and advertising ID). 
● Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, 
we share your advertising ID to advertising network companies for the purpose of them 
serving behavioral advertisements to you within the App. We use or may use the following 
advertising network companies: 
○ Adcolony https://www.adcolony.com/privacy-policy/ 
○ Chartboost https://answers.chartboost.com/hc/en-us/articles/200780269 
○ Facebook Ads https://www.facebook.com/about/privacy/ 
○ Flurry 
https://policies.yahoo.com/us/en/yahoo/privacy/products/developer/index.htm 
○ InMobi http://inmobi.com/privacy-policy/ 
○ Supersonic/IronSource https://www.ironsrc.com/privacy-policy/ 
○ Tapjoy https://home.tapjoy.com/legal/#privacy-policy 
○ Vungle https://vungle.com/privacy/ 
○ Mobvista https://www.mobvista.com/en/privacy/ 
○ Yeahmobi https://www.yeahmobi.com/privacy-policy/ 
○ SuperAwesome https://www.superawesome.com/awesomeads-privacy-policy/ 
○ Adverty https://www.adverty.com/privacy-policy/ 
● The recipients' use of the disclosed information will not be covered by this Privacy Policy. If 
you have questions concerning the processing carried out by such third parties, you should 
review their privacy policy. 
● In connection with our processing, we use data processors such as server hosting providers, 
technical service providers for supporting internal operations, user login services and 
analytics service providers. 
 

Social sharing features

● The App offers social sharing features and other integrated tools (such as the Facebook

“Like” button), which let you share actions you take in the App with other media. You must

be over the minimum age limit that is prescribed by the legislation in the individual

jurisdictions to use any social sharing features integrated in the App. The use of such

features enables the sharing of information with your friends or the public, depending on

the settings you establish with the entity that provides the social sharing feature.

● The App has social features from the following providers:

○ Facebook

○ Game Center

○ For more information about the processing carried out by the respective third

parties in connection with social sharing features, please visit the privacy policies of

the entities that provide these features, which can be found here:

○ Facebook: https://www.facebook.com/about/privacy/

○ Game Center

Children

● The App is for a general audience. In order to comply with the legislation, you will be

presented to an age screen, when launching the App. When presented with this age screen,

it is important that you state the correct age.

● Based on your age information and your device settings, Gamesturf does not process

personal data of children under the minimum age limit that is prescribed by the legislation

in the individual jurisdictions for behavioral advertisement. If such personal data have been

processed without Gamesturf's knowledge, Gamesturf will, after having become aware of

the incident, immediately take reasonable measures to stop such processing and promptly

delete any such data from Gamesturf’s records.

● If you have additional questions about Gamesturf’s privacy practices related to children

under the applicable minimum age, please contact us at gamesturfstudio@gmail.com

Transfer to third countries

● In connection with the processing, we will in certain circumstances transfer your personal

data to recipients in the U.S which has been declared an unsafe third country by the

European Commission.

● We only transfer personal data to entities in third countries that have provided appropriate

safeguards to ensure that their level of data protection is in agreement with this privacy

policy and applicable law.

● Consequently, the transfers will only occur based on the following safeguards:

○ If the entity is certified to comply with the principles for data protection under the

US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities

○ certified under Privacy Shield at www.privacyshield.gov), or

○ If we have entered into standard data protection clauses adopted by the

Commission with the entity, which is deemed to offer sufficient safeguards with

respect

○ to the protection of the privacy and fundamental rights and freedoms of individuals

(you can obtain a copy of the clauses by contacting Gamesturf).

The right to data portability:

● You have the right to receive the personal data you have provided us with which we process

in a structured, commonly used and machine-readable format and have the right to

transmit those data to another controller if the processing is based on consent or contract

performance, see Article 20 of the GDPR.

Push notifications

● We send push notifications or alerts to your mobile device to provide game-related

information, service updates, promotional communications and other related messages, if

you have agreed to such notifications. You can deactivate these notifications by changing

your notification settings on your device.

Contact and complaints

● Gamesturf has the following contact information:

○ GamesTurf

○ E-mail: gamesturfstudio@gmail.com

● If you wish to remove processing your personal data write us email to

gamesturfstudio@gmail.com with Subject “ Remove My Personal Data”

NOTE:

● If you install the application it's untestable that you agreed to share your personal

information and processing it for.

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