PRIVACY POLICY OF THE «WATT GAMES» PROJECT AND SERVICES PROVIDED

BY WATT GAMES LLC

(VERSION No2 DATED BY THE SEPTEMBER 20TH, 2021)


This personal data Privacy Policy (hereinafter referred to as the "Policy") applies to any information containing personal data provided by individuals to WATT GAMES LLC, OGRN 1207700447910, address of the location: ul. Podemnaya 9, basement, office 006, Moscow, Russian Federation, 109052 (hereinafter referred to as the WATT GAMES, when using a project «WATT GAMES» and Services including Internet resource http://wattstudio.ru (hereinafter referred to as the "Project and Services").


"Project" and/or "Project WATT GAMES" are game projects in the form of computer programs developed or administered by WATT GAMES

"Services" are services implemented through a Project, an Internet resource http://wattstudio.ru, as well as support services and forums.


Management and administration of Project and Services is carried out by WATT GAMES LLC in accordance with the requirements of the legislation of the Russian Federation.



This privacy policy of the Project follows generally accepted international industry standards is to protect the personal data. Please note that information that you voluntarily make public, or which you disclose by posting will be publicly available and viewable by others. WATT GAMES do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions, nevertheless, WATT GAMES are committed to protecting and respecting your privacy. This Policy describes how WATT GAMES treat information that you provide or that WATT GAMES collects about you.


By "Personal Data", refer to data that relates to you as an identified or identifiable natural person. The term "Personal Data" may include your name, your address, your telephone number, your e-mail address, your age, your gender, your preferences, social network ids for instance. Anonymous information, which we are not able to relate to you, does not qualify as Personal Data.



By accepting this Policy, you expressly agree to the provision, processing, and storage of Personal Data about you, subject to the scope and on terms specified in the Policy. By submitting your Personal Data to us, you consent to their storage, processing, transfer (including cross-border transfer, if required by the Project and Services).

1. DATA CONTROLLER (PERSONAL DATA PROCESSING OPERATOR) AND CONTACT DETAILS OF THE DATA PROTECTION OFFICER
   
   

The operator for the processing of Personal Data in the context of the legislation of the Russian Federation, as well as the Controller in the sense of the General Data Protection Regulation (EU) 2016/679 (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding Project and Services, is:

WATT GAMES LLC, address: ul. Podemnaya 9, basement, office 006, Moscow, Russian Federation, 109052

dpo@wattstudio.ru

1. FUNDAMENTALS OF THIS POLICY
   
   

a. Processing of user's personal data in the Project and Services is carried out solely for the purpose of fulfilling the WATT GAMES obligations to users of Project and Services.

b. Processing of personal data is a prerequisite for the possibility of providing users with access to Project and Services. When processing personal data, WATT GAMES follows principles of the legality and interests of the users of Project, as well as fully complies with international standards for the protection of personal data.

с. WATT GAMES provides each user of the Project and Services with protection of its personal data in the provision of access to the Project and Services.

1. THE RESTRICTION OF THIS POLICY
   
   

This Policy applies only to the Project and Services. WATT GAMES do not control and is not responsible for third-party resources to which users of the Project and Services can go to through Project and Services.

1. ENSURING INFORMATION SECURITY
   
   

WATT GAMES understands the importance of Personal Data privacy of the Project users. WATT GAMES maintains reasonable and appropriate security procedures to protect privacy information users of the Project and Services from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

1. DATA STORAGE
   
   

WATT GAMES in the process of processing carries out the storage of some of the Personal Data of users of the Project and Services for as long as users of the Project and Services continue to carry out the use of Project and Services. WATT GAMES will delete Personal Data users of the Project and Services s within 30 days after receiving the corresponding request of the user of Project and Services via e-mail dpo@wattstudio.ru specified in Section 1 of this Policy.

1. PROCESSING OF PERSONAL DATA OF PERSONS UNDER THE AGE OF MAJORITY
   
   

Processing of Personal Data of persons under the age of majority (under the age 18 years or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law, or with respect to the full age in the country of your residence) is impossible without the consent of a guardian or other legal representative. WATT GAMES believes that the Project and Services is used by persons who have reached the age of majority or under the age of majority in the presence of the above consent. If in the process of interaction with the user, the WATT GAMES will be revealed the fact of using the Project and Services by a person under the age of majority without the consent of a guardian or other legal representative, the Personal Data of such person will be immediately destroyed by WATT GAMES from all databases WATT GAMES in full.

1. TARGETED AND PERSONALIZED ADVERTISING
   
   

To show you personalized advertisements on the Project and Services as well as in other websites and services (including email) we have a legitimate interest to process necessary data to track the content you access in connection with the Project and Services and your online behavior deliver, target, and improve our advertising and the Project and Services.

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting:

• "limit ad tracking" - (Apple iOS) or
  
  
• "opt-out of interest-based ads" - (Android).
  
  

1. PROVIDING INFORMATION TO THIRD PARTIES
   
   

WATT GAMES has the right to provide the Personal Data of users of the Project and Services to its affiliates, subsidiaries, vendors, or agents working on its behalf for the purposes described in this Policy. Vendors or agents of WATT GAMES adhere to data privacy and security requirements and are not allowed to use the Personal Data they receive from WATT GAMES for any other purpose.

Since the list of WATT GAMES's partners can change over time, users of the Project and Services can always request an up-to-date list of partners to which data is provided. Users of the Project and Services may request this information via e-mail specified in Section 1 of this Policy. By giving WATT GAMES Personal Data, users of the Project and Services agree to such transfer, storage, or processing. WATT GAMES will take all reasonable steps necessary to ensure the security of the Personal Data of users of the Project and Services in accordance with this Policy. At the time of the release of this Policy the Project does use third party services that may collect information to identify you, exactly Google Play Services and Facebook.

Link to privacy policy of third-party service providers used by the Project:

- Google Play Services

- Facebook

1. THE LIST OF PROCESSED PERSONAL DATA
   
   

WATT GAMES processes only the information that was received directly from the users of the Project and Services including in accordance with the legislation of the Russian Federation and Article 6 (1) (f) of the GDPR Regulation, as well as any information, which is automatically handled by the technical methods when using Project and Services. WATT GAMES collects Personal Data and other information that users of Project and Services voluntarily provide, namely:

- Information provided by users of the Project and Services when request information or support from WATT GAMES.

- Information that the users of the Project and Services are placed on various forums and websites concerning the Project and Services.

- Access time on the Project and Services.

- Tracking Data and Cookies (specified in Section 10 of this Policy).

- Information sent through data transfer in Project and Services, including participating in competitions, contests, and tournaments, responding to surveys.

- Information relating profiles to users of the Project and Services on social networking sites for the purpose of ensuring integration with such social networking sites.

- Other information, namely, indirectly received information through users of the Project and Services and resources on the Internet using Project and Services. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information. Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. When combining such information with Personal Data, WATT GAMES will treat the combined information as Personal Data.

1. TRACKING DATA AND COOKIES
   
   

WATT GAMES and WATT GAMES's partners such as marketing and analytics partners may use Cookies, which are text files placed on the computers of users of the Project and Services to help WATT GAMES analyze how users use the Project and Services, and similar technologies (e.g. web beacons, pixels, ad tags, and device identifiers) to recognize the use of the Project and Services, marketing and analytics. The use of Cookies is standard on the internet. Although most web browsers automatically accept Cookies, the decision to accept them rests with users of the Project and Services. Users of the Project and Services may adjust their browser settings to prevent the reception of Cookies or to provide notification whenever a cookie is sent to users of the Project and Services.

WATT GAMES uses this cookie information for the following purposes:

- To improve the Project and Services content and performance.

- To analyze trends and estimate our audience size and usage pattern.

- To administer the Project and Services.

- To recognize you when will return to use Project and Services.

All major browsers offer advises and guidance for managing cookies to be available in your browser. To simplify the configuration of Cookies please find links to cookies instructions in some browsers and advertising agents below:

Internet Edge

https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Google Chrome

https://policies.google.com/technologies/cookies?hl=en

Safari

https://www.apple.com/legal/privacy/en-ww/cookies/

Yandex

https://yandex.com/support/metrica/general/opt-out.html

Facebook

https://www.facebook.com/help/499864970040521

Information pertaining to the Project and Services such as the number of users of Project and Services daily is typically referred to as "Tracking Data". This type of indirectly collected information is gathered through various means such as an IP address, which is a number that is automatically assigned to the computers of users of the Project and Services whenever you use the Project and Services.

1. LOCAL LEGISLATION
   
   

WATT GAMES complies with applicable territorial and international legislation. Please note that Project and Services are provided "as is" and you should get to know with applicable laws. By continuing your use of the Project and Services, you are warrant that your use of the Project and Services is not contrary to the applicable law.

WATT GAMES uses technical means to determine the region where you use the Project and Services (without accuracy, which means that we cannot determine the place of the user and identify him) to determine the applicable legislation. WATT GAMES process personal Data of Russian citizens in accordance with applicable Russian laws namely, FEDERAL LAW RUSSIAN FEDERATION ABOUT PERSONAL DATA (ed. Federal Laws of 25.11.2009 N 266-FZ, of 27.12.2009 N 363-FZ, of 28.06.2010 N 123-FZ, of 27.07.2010 N 204-FZ, of 27.07.2010 N 227-FZ, of 29.11.2010 N 313-FZ, of 23.12.2010 N 359-FZ, of 04.06.2011 N 123-FZ, of 25.07.2011 N 261-FZ, of 05.04.2013 N 43-FZ, from 23.07.2013 N 205-FZ, from 21.12.2013 N 363-FZ, from 04.06.2014 N 142-FZ, from 21.07.2014 N 216-FZ, from 21.07.2014 N 242-FZ, from 03.07.2016 N 231-FZ, from 22.02.2017 N 16-FZ, from 01.07.2017 N 148-FZ, from 29.07.2017 N 223-FZ, from 31.12.2017 N 498-FZ, from 27.12.2019 N 480-FZ, from 24.04.2020 N 123-FZ, from 08.12.2020 N 429-FZ, from 30.12.2020 N 515-FZ, from 30.12.2020 N 519-FZ).

Please pay your attention to the fact that there are several countries where any use of VPN-services and similar software products to disguise your region of residence, is not allowed. WATT GAMES INFORM YOU THAT BEFORE USING THE PROJECT AND SERVICES, IT IS IN YOUR INTERESTS TO READ YOUR LOCAL PERSONAL DATA LAWS.

1. FINAL PROVISIONS
   
   

WATT GAMES reserves the right to modify this Policy at any time, so please review it on a periodic basis.

This Policy is made in English language. WATT GAMES may provide you with a translation in other languages. In case of any inconsistency or discrepancies between a non-English translation of this Policy and the English version, the English version shall prevail.



FAITHFULLY YOURS

WATT GAMES LLC