Privacy Policy | FROSTGATE

Last updated: June 15, 2023

Thank you for using our games, websites, participating in marketing activities or related Services ("Service" or "Services").

Introduction
1. This policy contains a description about:
  what information Medialed LLC, its subsidiaries and related companies (hereinafter referred to as "FROSTGATE" or "we" or "our"), third parties collect through our Services installed on your mobile device, computer or on any other device, on platform or website and why we collect it, how we use this information, and
  how you can exercise your privacy rights.
2. By installing, using or otherwise accessing the Services, you consent to the collection, storage, processing and transfer of your personal data in the manner set forth in this Privacy Policy. We may use this data in different ways, but we always do so legally in accordance with the grounds set out in Section 10 of this Privacy Policy.
3. If you are concerned about how your personal data is used in accordance with the provisions of this Privacy Policy, please refrain from using our Services.
4. Our policy does not allow individuals under the age of 16 to provide personal information, nor do we knowingly allow such individuals to use our Services. In some countries, you must be over 16 years of age to use our Services. Persons who have not reached the appropriate age cannot provide any personal data. If we discover that we have collected personal data from a person who has not reached the appropriate age, we will delete this data as soon as possible. If you believe that we may have any information about a person under the appropriate age, please contact us.
Information we collect and receive
We may collect and receive information that may be considered personal data under applicable law in a variety of ways. Namely:
1. When you play our games, we may collect and store:
  - Information that you provide voluntarily, such as: name, email address, telephone number or other contact information; player name and password, profile photo; information provided to our support team through the Services or email; the content of messages sent using our chats and messaging systems, or other information that you send to us (for example, data to identify a lost account).
  - Information that is automatically collected and stored from you and/or your device when you use our games, such as:
    - data about your account, nickname and how you use the Services and interact with the Services (for example, data about gameplay, game achievements, level, points, session duration, preferred settings; in-game links or simply game preferences; about what kind of friends do you communicate with).
    - your IP address, Internet connection, non-exact geographic location (eg country or city), cookie identifiers;
    - device details, including: device type, device model, device operating system, device settings, device language, or other technical data such as device settings, screen size, or processor, or a combination of these data available from the device for a developer to check device compatibility with a specific application; Application IDs, Device ID, Vendor ID.
    Whether we collect any or all of the above information often depends on the type of device you use and its settings. These technologies allow us and third parties (including marketers) to recognize your device when you use websites and applications. They are contained in all applications and thus allow you to track information between applications.
  - Data we collect from our partners:
    Data we receive if you link a third party service to the Service (such as Facebook);
    Data to combat fraud (for example, the abuse of payments in games);
    Order details (for example, products, date, amount, status, description, extended geographic location (for example, country or city));
    Data for marketing purposes;
    Data for analytics in order to improve the quality of service provision;
    Data from another group of companies or third parties who have obtained your consent or are otherwise legally entitled to share such information with us (including publishing partners, publishing platforms, and data aggregators). This may include data about you and your interests, as well as information about other games and services you use, demographic and general location information. We will use this information in the manner described in this Privacy Policy.
    confidentiality, and subject to any limitations in the privacy policy of the company that collected the information from you.
2. When you visit our website.
  - When you provide us with any feedback through the means available to you on this website, including but not limited to submitting a resume, we may collect and process the personal data you provide to us, such as your name, email address, email, phone number or any other information that you send to us.
  - Information automatically collected and stored when you use the website from your device or browser, including your device model, operating system, screen size, browser type, information about how you use the website (for example, the time and number of user visits, time spent on the website, IP address, data collected through cookies and similar technologies (eg "software development kits" or "SDKs").
3. If you are representatives of our business partners, suppliers or corporate clients.
  If you are representatives of our business partners, suppliers or corporate clients, we may collect and receive:
  - Any information directly from you;
  - Any information from your employer or other third parties (for example, from publicly available sources or during networking events).
4. We may from time to time ask you for your consent to collect other information from you or information about your device. If we do this, we will make sure to tell you what information we would like to collect, why we need it, and what we will use it for.
5. Please note that we do not collect or store any of your payment information when you purchase items through our mobile applications (such as those you can purchase from the App Store, Google Play, Microsoft Store, Amazon Appstore, Facebook and other platforms).
6. Some of this data may be collected using cookies, which are small files that store information on your device to help us optimize your use of our Services and/or similar technologies (such as "SDKs" or software development kits). Some cookies are from the website itself, while others are "third party" cookies from analytics organizations or social networks. Cookies are generally used to quickly identify your device and "remember" your device during subsequent visits in order to provide functionality, determine preferences and improve the performance of the website. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your experience of using the Services.
7. Please note that FROSTGATE does not guarantee the protection of any personal information that you choose to post on your account, or that you may post in comments posted through the Services or otherwise made visible to others, including but not limited to chats, forums, blogs where you can post your Content. We are not responsible for how this information is used by other parties. Therefore, please be careful when submitting any data through the Services.
How is your personal data used?
1. We primarily use personal data when the processing is necessary for the performance of a contract to which you are a party or to take steps at the request of the data subject prior to entering into a contract.
  Accordingly, we use your data in the following ways:
  - to enable you to use the Services;
  - to communicate with you, whether for customer service or sending information about our Services;
  - to manage your account and improve the quality of your service when using our Services;
  - to research, conduct surveys and interact with you, such as via email or other communications;
  - to develop and improve the Services and customer service;
  - to set up the Services;
  - to provide you with our offers in the Services, as well as on other websites and services;
  - to provide you with relevant information, safety alerts and support messages at your request;
  - for the implementation of social functions within the Services;
  - to moderate chats automatically or manually;
  - so that you can communicate with other players.
2. We may use this data when processing is necessary to comply with FROSTGATE's legal obligation to ensure the security and fairness of the Services and social features, fight fraud, prevent crime or attempts to mana, as well as ensuring the proper use of the Services and taking action against fraudulent activities or dishonest players.
3. We may use data where the processing is necessary to achieve the purposes of legitimate interests for analysis, profiling and segmentation, unless such interests outweigh the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, in particular where the data subject is a child who has not reached the appropriate age.
  In all of the above cases and purposes, we may analyze, profile and segment all data collected (for example, to create reports, analyzes or similar reports for our own research or market purposes, for example, to track trends or issues using our Services).
4. With your consent.
  With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.
Your personal data may be transferred to third parties
1. We may share your information with (i) third parties, vendors and partners who provide data processing services to us and with whom we have relevant signed agreements or who otherwise process personal information for the purposes described in this Privacy Policy, or notify you when we collect your personal information (for example, technical support providers, software providers, professional advisors (for example, lawyers, accountants, tax advisors, auditors, and insurance brokers); (ii) government agencies, courts, government representatives, or other third parties, if required by applicable laws and regulations; (iii) third parties when a corporate restructuring or sale of assets involving FROSTGATE occurs, or as a result of a change in control of FROSTGATE or its affiliates, or in preparation for any of these events Any third party who is the recipient of such transfer or sale is entitled to continue to use your personal data in accordance with this Privacy Policy; or (iv) any other person or entity with your consent to the disclosure of personal data.
2. We do not sell or rent your personal data to third parties, unless it is related to one of the above points.
3. By accepting this Privacy Policy, downloading or continuing to play our games or use our Services, you also authorize us to provide anonymous and statistical data that does not contain personal data to third parties at any time and at our sole discretion.
Playing our games with other players
1. If you use a third party social network or platform (third party) to access our Services, that third party, with your consent, may provide us with your personal information. These websites or apps are created by third parties that are not affiliated with or controlled by FROSTGATE. Please read the terms of service and privacy policies of third parties carefully to understand how they use your personal data and what data may be shared.
2. When you allow any interaction between our Services and any social network or platform owned by a third party, we may also share your personal data with your contacts in order for you to interact with other players (your name, your profile - avatar and your points / game achievements).
3. You can change the data that such third party social networks or platforms may share with us at any time by changing the settings for that provider, or you can prevent our Services from interacting with that provider. In this case, you will not be able to use our Services in full.
Data storage
1. Your personal data will be kept for as long as it is necessary to provide you with our Services or to complete any purpose for which it was originally intended. But please note that even after you close your account or stop using our Services, we may continue to store your data as necessary to comply with our legal obligations.
Data protection
1. We take the security of your personal data very seriously. We maintain technical and physical security measures to ensure that your personal information is protected from accidental or unlawful loss, destruction, alteration, unauthorized access or disclosure, or any other use or unlawful processing of the personal information you have provided to us. Our personal data security mechanisms data are similar to those of other game developers. But please keep in mind that the Internet is not 100% secure and we cannot guarantee that your personal data provided by you through our games will not be disclosed, altered or destroyed if security mechanisms are violated.
Links to Third Parties in Our Services
1. In our Services and on our websites, we may embed links to third-party websites. It should be understood that by clicking on any of these links, you will be taken to a third party site and therefore any personal information you provide will not be protected under this Privacy Policy, but by the third party. Of course, we care about the choice of authoritative links, but please note that we have no control over, and are not responsible for, the content, privacy policies, or practices of third party sites or services.
International data transfer
1. Our Services are global in nature, so your data can be transferred anywhere in the world. Because different countries may have different data protection laws than those in your country, we take steps to provide reasonable safeguards to protect your data as described in this Policy. These include the application of the European Commission's Standard Contractual Clauses for transfers of personal data between our group companies and third party service providers and partners, which require all group companies to protect personal data processed by them from the European Economic Area in accordance with European Union data protection law . It also includes the transfer of personal data to third party service providers and partners that are certified under the EU-US and Swiss-US Privacy Shield.
Legal basis for the processing of personal data
1. Whenever we process your personal data, we do so on a lawful basis in accordance with applicable law. The legal bases under which we operate are as follows:
  We need personal data to fulfill contractual obligations. This applies when the data is used by us to provide you with access to use the Services at your request, such as our games, customer support services, chat features and connection with third party social networks;
  legal obligations. This applies when the data is used by us in accordance with a legal obligation, such as crime or fraud prevention or tax reporting;
  Legitimate interests. This applies when the data is used for analytics, research and optimization of the Services and marketing purposes;
  Agreement. This applies when you voluntarily give us specific, informed and unambiguous consent, in accordance with which you consent to the processing of your personal data.
Rights to the protection of personal data
If you are located in the European Economic Area, you have the following data protection rights:
1. The right to access personal data.
  You have the right to know what personal data we hold about you and how and why we process your personal data. You can ask us for a copy of your personal data and in some cases we can provide you with the requested information. If you would like to exercise your right, please contact us as described below and let us know what information you would like to receive. We reserve the right to request reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you request, for example if the information contains personal information about another person. If we cannot provide you with all the information you requested, we will try to explain why.
2. The right to correct or update your personal data.
  You have the right to request an update or correction of your personal data that is out of date, incomplete or incorrect.
3. Right to erasure of your personal data.
  Under certain circumstances, you have the right to ask us to delete your personal data that we hold about you. We will pass on your request to other recipients of your personal information, unless it is impossible or requires a disproportionate effort. If you would like to ask us for more information about specific circumstances and other recipients and/or exercise your right to erasure, please contact us using the contact details described in section 12 below. Please note that some of the information can only be deleted by deleting our games from mobile devices and by deleting our cookies from any the device you used to use our Services. In this case, you will permanently lose all your game achievements, virtual currency and virtual goods without the right to data recovery or refund. If we delete personal data about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights and interests, maintaining marketing suppression lists, or for technical reasons such as maintaining technical the security or integrity of our database. We may also store your information in an anonymous form. In some cases, personal information about you that is visible through gameplay, such as your username, avatar, your high scores and any chat messages, may be cached on other players' devices and we will not be able to remove or update this data from these devices , for example, if this device is not connected to a network. You can ask us for more information about specific circumstances and other recipients using the contact details described below in section 12.
4. The right to restrict the processing of your personal data
  Under certain specific circumstances, you have the right to restrict the processing of your personal data that is processed on legitimate grounds. You can ask us for more information about specific circumstances using the contact details described below in Section 12.
5. The right to object to the processing of your personal data.
  You have the right to object to the processing of your personal data where the processing is necessary for purposes arising from legitimate interests pursued by the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data, in particular when the data subject is a child.
6. The right to portability of your personal data. In some cases, you have the right to request that we provide you with personal data that you have provided to us so that you can transfer it to another data controller.
7. The right to withdraw your consent at any time.
  You can withdraw your consent to the processing of your personal data if we process your personal data with your consent.
8. The right to complain to the data protection authority about your personal data collected by us and about their use.
  For more information, please contact your local data protection authority.
9. In some cases, our use of your personal data may lead to automated decisions (including profiling). Automated decisions mean that a decision concerning you is made automatically based on computer determination (using software algorithms), without our human review.
How to contact us
1. If you have any questions regarding this Privacy Policy or would like to exercise the privacy rights described above, please contact us by email: legal@frostgate.studio.
2. Data controller: Medialed LLC, a Russian company with its registered office at: 630090, Russia, Novosibirsk, st. Kutateladze, 4G, of. 253
3. Contact information of representatives 630090, Russia, Novosibirsk, st. Kutateladze, 4G, of. 253
Changes to the privacy policy
1. In the event that our Privacy Policy is changed or updated, any changes or updates will be posted so that you are aware of what personal data we collect, how it is used, stored and in what cases we have the right to disclose it.
2. We reserve the right to make any necessary changes to this Privacy Policy at any time, so please review it often.