Privacy Policy

the Privacy Policy

This Privacy Policy provides additional information on collecting and processing your personal data by nss nis’s games and apps upon installation and use.

nss nis is a developer and publisher of apps and games. Hereinafter, nss nis may be referred to as “we”, “us” or “our”, depending on the context.

Please read our Privacy Policy carefully before you start using our apps and games. This way, you will find out what personal information we collect, how your data is stored, and why, as well as what we do to ensure information safety.

Once you have read this document, you will understand that the personal data we collect is relevant and limited to what is necessary for the proper functioning of a certain app or game. Thus, you will be able to decide whether or not you agree with the adequate processing of your data.

For any additional questions or concerns, you can contact us via e-mail. You will find our e-mail address below in the section Contact and Complaints.

About this Privacy Policy

The purpose of this privacy policy is to offer further explanation and information on the personal data we collect from you, data processing as well as storage and information protection. You can read more about these topics in the following sections.

Our privacy policy applies to all of our apps and games, whether played on our website, on mobile devices, or on PCs. The policy also applies to our marketing and advertising activities on all platforms and other services provided to you from time to time. In this privacy policy, we refer to our apps and games, websites, marketing and advertising activities, and other services collectively as our “Services”.

Changes to the Privacy Policy

If any changes to this Privacy Policy were to occur, the date at the top of the policy will be revised. Depending on the type of these changes, we will require renewed consent or provide you with additional notice.

Whenever you use our apps and games, we recommend taking a little time and review this policy. This way, you will stay informed about your personal data processing, as well as how you can protect your privacy.

Collected and Processed Data

In order to provide smooth app and game functioning, we might acquire some personal data. The following list contains the information we collect.

Automatically collected data

When you use or access our apps and games, general information about you is automatically collected, including:

• Age – Minor or not
• Log Data – Type of device, app, and game features
• Device – Device data (device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push messages, mobile network information, time zone
• Usage – Game progress, scores, achievements, interaction with other players
• Consumption – Consumption habits (type of purchases, in-game reception of virtual goods)

Requested information

In order to function properly, some of our apps and games must access your personal data. If you are using one of these apps or games, the following information might be required:

• Nickname – used in the app or game
• E-mail address – your e-mail address.

Information collected from other sources

In case you log into our app or game via a third-party site or platform (Facebook, Apple Game Center, Google Sign-In), we access data from such sites or platforms. This includes your screen name, friend lists, and profile information, according to third-party authorizations, and your consent is given to such a third party.

Whenever you log into our app or game using a third-party site or platform, you represent and warrant that:

Purpose of processing data

Your personal data is used according to the legal basis for each data type as described below:

Information regarding your age is processed:

a. to identify whether you are a minor or an adult for the purposes of data protection as well as to determine the legal requirements for our processing of your personal information.

The aforementioned processing is necessary for compliance purposes, see Article 6(1)(c) of the GDPR.

Device, log, usage, and consumption information is processed:

b. to provide you with related information as requested or agreed by you and provide the requested products and services;

c. to deliver and maintain apps or games and the adequate app/game experience;

d. to provide customized content and features by personalizing and improving apps or games;

e. to track and analyze usage, activities, and trends related to the app or game;

f. to provide children (as this term is construed under GDPR in the EU, COPPA in the US, and the relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in an app or game.

g. to provide adult users that have given 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 a personalized advertisement in an app or game (behavioral advertising).

The aforementioned purposeful processing is justified by our legitimate interests in providing advertisements and content of interest as well as improving our services 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).

Nickname is processed:

h. to identify your ratings and scores among other users on leaderboards and high-score lists.

The processing of the aforementioned data is necessary in order to facilitate the delivery of the products and services you request. See Section 6(1)(b) of the GDPR.

The E-mail address is processed:

i. to synchronize your data on all your devices through identifying your account.

The processing of the aforementioned data is necessary in order to facilitate the delivery of the products and services you request. See Section 6(1)(b) of the GDPR.

Information from other sources is processed:

j. to provide the requested products and services and send related information
The processing of the aforementioned data is necessary in order to facilitate the delivery of the products and services you request. See Section 6(1)(b) of the GDPR.

k. to combine data provided by third parties to better meet your requirements and deliver better service.
The aforementioned purposeful processing is justified by our legitimate interests in providing advertisements and content of interest as well as improving our services in accordance with Article 6(1)(f) of the GDPR.

Your data is processed only to the extent needed to fulfill the purposes for which it was collected.

Push Notifications

In case you have agreed to such alerts, push notifications will be sent to your mobile device in order to provide app or game-related information, service updates, promotional communications, and similar announcements. You can deactivate these alerts by changing the notification settings on your device.

Information Storage

Your personal data is stored for a necessary period of time so as to enable our app or game properly functioning. Further storage is sometimes required in order to comply with applicable laws and accounting rules or to establish, exercise or defend a legal claim. Once your personal information no longer serves the aforementioned purposes, or following no later than three (3) years of inactivity, it will be deleted or anonymized.

Information Sharing

Personal information is disclosed based on the legal bases in Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR to these categories of recipients:

• Social networks, see more under “Social Sharing features”;
• Third parties, in such cases when 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 in case 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 the Company 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 in question include your IP address, Device ID, and advertising ID).

However, if you have agreed to share your advertising ID in accordance with Section 6(1)(a) of the GDPR, we shall disclose it to advertising network companies so that behavioral advertisements within the App can be provided. This may refer to the following advertising network companies:

• Ad Mob – https://policies.google.com/privacy?hl=en
• Unity Ads – https://unity3d.com/legal/privacy-policy
• Facebook Ads – https://www.facebook.com/about/privacy/
• Adcolony – https://www.adcolony.com/privacy-policy/
• Chartboost – https://answers.chartboost.com/hc/en-us/articles/200780269
• AppLovin – https://www.applovin.com/privacy/
• IronSource – https://www.ironsrc.com/privacy-policy/

This Privacy Policy does not cover the recipients’ use of disclosed information. In case you have questions regarding the third party’s information processing, 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

Our apps and games offer social sharing options and other integrated tools, which enable you to share actions you take in our app or game on different media. These social features in our apps or games are only available to persons over the minimum age limit that is prescribed by the legislation in individual jurisdictions. Social sharing enables you to share data with your friends or the public, according to your choice of settings on such site or platform. Our games and apps include social features from the following providers:

• Facebook
• Google

For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit:

• Facebook: https://www.facebook.com/about/privacy/
• Google: https://www.google.com/about/company/user-consent-policy.html

Children

Our apps and games are designed for a general audience. While launching our app or game, an age screen will appear, in order to comply with the legislation. It is important to provide your correct age.

Based on your age information and your device settings, the personal data of children under the minimum age limit that is prescribed by the legislation in the individual jurisdictions will not be processed for behavioral advertisement.

In case such personal data have been processed without our knowledge, we will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any aforementioned data from our records.

For any additional questions about our privacy policy related to children under the applicable minimum age, please contact us via our e-mail address.

Security

In order to protect your personal information and ensure the security of our systems, commercially reasonable precautions are being taken.

It is also important that you take precautionary measures against unauthorized access to your computer and password.

Personal data rights

Every user of our apps and games has certain rights regarding their personal data according to EU General Data Protection Regulation (GDPR). Contact us via e-mail if you wish to use any of the rights described below.

Right to request access

You have the right to request access to processed data, see Article 15 of the GDPR, including information about:

• processing purposes
• personal data categories
• the recipients or categories of recipients to whom the personal data have been or
  will be disclosed
• personal data storing and storing period

Moreover, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

Right to rectification and erasure

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• if you have withdrawn your consent and there are no other legal grounds for the processing,
• if you have objected to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
• the personal data have been unlawfully processed or
• personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Right to restriction of processing

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise, or defense of a legal claim or to protect a person or important grounds of public interest.

Right to withdraw consent

In case you have been asked for consent to the processing of your data, you have the right to withdraw your consent at any time (see Article 7 of the GDPR).

If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

Please note that if you withdraw your consent, your user license to use our game or app will cease automatically.

The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

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.

Right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights, and freedoms or if the processing is necessary for the establishment, exercise, or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the app or game will cease automatically.

If you wish to make a complaint over your personal data processing, you have the right to lodge a complaint with the relevant supervisory authority.

Data Controller

We are responsible for deciding how and why we collect and use your personal data. If you wish to contact us, you will find our contact details in the section below.

Contact and Complaints

nss nis, the following contact information:

E-mail:

• katarina.krstic.018@gmail.com