PREAMBLE. GENERAL PROVISIONS
For the purposes of complying with GDPR the following terms are subject to application:
“Cookies” means small text files, located in browser directories. They are used to help users navigate through Services efficiently and perform certain functions of the Services.
“GDPR” means General Data Protection Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data.
The term “information” includes personal data of data subjects.
“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.
When We use the term "personal information" or “personal data” in this Policy, it can include an individual's first and last name, address, telephone number, e-mail address, and a credit card or other account number. The terms "personal information" and “personal data” are synonyms.
“Processing of the personal data” or “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Controller” means Nekki Limited, the legal person that determines the purposes and means of the processing of personal data.
The terms “Nekki” or “Nekki Limited” include Nekki Limited and its affiliates.
“Services” means the Games of Nekki, including, but not limited to, Shadow Fight 2, Shadow Fight 3, Vector, Vector 2, Beat da Beat, Lintrix and other related services, including the Nekki (Nekki Limited) official web-site www.nekki.com and other services, at which this Policy is published.
1. Contacting Nekki
116, Gladstonos str,
M. Kyprianou house; 3rd&4th floors,
3032, Limassol, Cyprus
Our processors that take part in processing of Your personal data on behalf of Nekki Limited are:
(1) Amazon AWS
(2) Akamai CDN
(3) Helpshift Inc.
(4) Selectel ltd.
These processors provide Nekki Limited with the services of support systems for Our Services.
They process Your personal data in accordance with the terms of the written contracts conсluded between Nekki Limited and the processors. These contracts provide that the processors shall process and use Your personal data only to the extent provided in the contract. The terms of the contracts do not violate the processors’ obligations provided in Art.28 GDPR and Your rights as a personal data subject.
2. Information That We Collect From You
2.1. Nekki processes Your personal data under the consent given by You. We ask You for providing Us with the consent before processing Your personal data. When You use Our Services, We will collect the following categories of personal information about You:
(1) User ID
(2) Player’s payment ID;
(3) Device Token;
(5) Device ID;
(6) Device Name;
(7) Device Type;
(8) OS (Android, iOS);
(9) Country (location data);
(10) Display Width;
(11) Display Height;
(12) Core Count;
(13) App Version;
(14) GP/GC Account;
(15) Created Date;
(16) Login Date;
(17) Push Token ;
(18) Auth Type.
These personal data are processed by Our internal monitoring system.
2.3. Any materials or information that You post or upload to the Games or to Us may be visible to other users of the Games and will be stored on Our servers for the purposes of making the Games available. We advise You to be selective about what information You post. Please do not include the following information in any post: telephone numbers, addresses, surname, date of birth, or other information you might want to hold private.
2.5. We also may collect information about the location of your computer or the device upon which you access the Games. We may also collect information about in-game activity and how the Games are used. Such information may include but shall not be limited to:
(a) login information (time of login and the number of logins)
(b) locations visited within the Games;
(c) character interactions within the Games;
(d) items purchased;
(e) items sold;
(f) missions accepted;
(g) missions completed;
(h) the amount of virtual currency You have; and
(i)and the amount of virtual currency You have either earned or purchased.
We may use this information for a number of purposes such as optimizing gameplay, security, and to help us provide more efficient customer support.
2.7. When You download Nekki mobile application by or through a Third Party Platform You allow us to access and/or collect certain information from your Third Party Platform profile/account (for example, Your name, surname, e-mail, etc.). You additionally allow us to access information contained in cookies placed on your device by the Third Party Platform as permitted by the terms of your agreement and privacy settings with the Third Party Platform. We may share this information with the Third Party Platform for their use as permitted by the terms of your agreement and privacy settings with the Third Party Platform.
3. Use Of Your Information
3.1. We may use Your information for the following purposes:
(a)to administer Your membership account and identify You as the user of the Game;
(b)to enable Us to provide You with access to the Games and Services and adjust You to the Game ID;
(c)to enable You to download information and materials from the Games and Services;
(d)to provide You with services You subscribed to;
(e)to display Your username and contact details (for example, your nickname) to other players;
(f)to enable other members of the Games to contact You;
(g)to provide customer service in relation to Your use of the Games;
(h)to administer, support, improve and develop the Games;
(i) to control the quality of the Games;
(j) to conduct the internal analytics (including without limitation for displaying advertisement and Our promotions).
3.2. We may also use Your information to contact You about the Games or to send You other content We think may be of interest to You. We will only do this if You have so consented or requested to receive such information when you downloaded the Games. If at any time You no longer wish to be contacted, please let Us know in writing and We will arrange this.
We also guarantee that employees of Nekki Limited and all its affiliates that deal with Your personal data are under confidentiality and non-disclosure of personal data agreements.
4. Rights Of Data Subjects
4.1. You as the data subject have the following rights relating to the processing of Your personal data:
(1) Right of access (right to obtain from Nekki Limited as the controller confirmation as to whether Your personal data are being processed and other information concerning Your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of Your personal data, the period of personal data storage, the existence of automated decision-making, including profiling, in respect of Your personal data);
(2) Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal data of data subjects);
(5) Right to restriction of processing (right to obtain from Nekki Limited as the controller restriction of processing on the legal grounds provided in Art.18 GDPR(for example, when the accuracy of the personal data is contested by You or We no longer needs the personal data for the purposes of the processing));
(6) Right to data portability (the right to receive the personal data concerning You, which You has provided to Nekki Limited as the controller, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from Nekki Limited to which the personal data have been provided);
(7) Right to object (right to object, on grounds relating to Your particular situation, at any time to processing of personal data concerning You, including the right to object at any time to processing of personal data concerning You for marketing purposes);
(8) Right not to be subject to a decision based solely on automated processing, including profiling;
(9) Right to file the request or complaint to Nekki Limited as the controller of Your personal data.
5. Disclosure Of Your Information
5.1. We will not share, sell or distribute any of the information You provide to Us without Your consent.
5.3. We may pass to third party payment processors certain information that identifies you as the Game’s player along with information on whatever you have selected to purchase.
5.4. We may disclose generic non-personal (anonymous) information in the aggregate (that is not specific to and does not identify You) to third parties including, but not limited to, third party advertisers and/or any third party game developer that develops or modifies the Games for Us on Our behalf.
5.5. You should always be careful when submitting information about Yourself within the Games and You should only submit information that You consent to make public.
6.2. If you are between 13 and 16 years old, we will not collect Your personal data without the explicit consent of a person that is the holder of parental responsibility over You. The consent of the holder of parental responsibility shall be given through the e-mail or other ways.
8. Third Party Sites and Contributors
8.3. The Games may also contain third party tracking tools from service providers. We may use these third parties' tools in our Games, which may enable these third parties to analyse user information (including your personal data). While these third parties may have access to your personal information in connection with the performance of Games and other related services, they may not use such information for any purpose other than providing their services.
9. Security And Data Retention of personal data
We employ reasonable security measures to protect Your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. These measures include: 1) personal data encryption; 2) technical measures in order to ensure the ongoing confidentiality; 3) personal data back-up to restore access to personal data following an incident; 4) test the effectiveness of the measures on the regular basis. Besides, We use the system of authentication, restrict the access to Our servers that store Your personal data, and provide the appropriate update of Our software necessary for securing Your personal data. We may update the list of such measures from time to time, provided that such updates and modifications do not result in the degradation of the overall security of personal data processing.
All Your personal data is stored in the closed internal analytical system. If You use Our support system You will be identified via Your e-mail by Our processor Helpshift Inc.
We will retain Your information for the duration of Your membership of the Games and/or whilst you continue to have access to the Games and for a reasonable period thereafter or as long as the law requires or permits. Your personal information will be deleted when You explicitly gives up the Games usage namely request your account deletion or request Us to delete Your personal data. If you send us such requests, We will delete your personal data as soon as technically possible. The period process of erasing personal data can take up to one month. Considering the complexity and number of requests, this period may be extended by a further two months.
Also Your personal data, which was collecting during Your using of the web-site nekki.com, can be stored and proceeded by Us for the period of time, during which it is needed for marketing or advertising purposes, but in any case no longer than 5 (five) years from the date of first collection.
You also need to understand that after deletion of your personal data the information that you have shared with others (for example, group posts) will remain visible. We does not control copying of such information by other users and its publication at our or third parties Internet resources.
10. Data Access and Corrections
10.1. You are entitled to see the information We hold about You and You may ask Us to make any necessary changes or rectifications to ensure that it is accurate and kept up to date. If You wish to do this, please contact Us in writing using the information provided above.
10.3. If you are accessing Our Games via Facebook, you may update, amend or delete Your information on Facebook, that we may receive from Facebook, by amending Your Facebook account information in accordance with Facebook’s terms and conditions of use.