PRIVACY AND DATA POLICY
ISSUED BY Free for VTN Global
1. AN OVERVIEW ON DATA PROTECTION
1.1 General information about this privacy policy
We take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy. Whenever you use our games, various personal data will be collected.
The following information will provide you with an easy to navigate overview of which data we collect how as well as the purposes we use this data for when you play our games.
The term „personal data” comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as your phone ID, cookie identifier or game data).
For detailed information about the subject matter of data protection, please consult our Privacy Policy below.
1.2 Data Recording
How do we collect your data?
On the one hand, your data is collected by you communicating it to us. This may be data that you enter in a contact form or if you connect your game to third-party accounts, such as Facebook or Google. Other data is automatically collected when you download and use our games. We also collect information about the advertisements served and how often you have viewed them, their location in the game and the identifier of your terminal device. We also collect information about your actions in relation to the advertisements, such as the page views, the time and the duration of the view.
What are the purposes we use your data for?
We use this data to provide our games to you, including for the purposes of optimization, processing support requests, preventing fraud, customizing and/or personalizing your game experience and in-game offers, verifying purchases and provide you with supplementary services. We may also use the data to provide you with advertisements, products, services or personalized content through our services or those of our partners. We may link the data we collect with our partners when you use our services. We may also link this data to demographic, advertising or market research or other analytical surveys.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. Please do not hesitate to contact us at any time under the address disclosed on the imprint of this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.
Moreover, you have the right to demand the restriction of the processing of your personal data.
Details of how to exercise your rights can be found in this Privacy Policy under “Your Rights”.
Analysis tools and tools provided by third parties
If you download and use our games, your usage data may be statistically analyzed.
Such analyses are performed primarily with what we refer to as analysis programs. The analyses of your usage data are usually conducted anonymously; i.e. the patterns cannot be traced back to you.
For detailed information about the tools and about your options to object, please consult our Privacy Policy below.
2. GENERAL INFORMATION
The responsible party (referred to as the „controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).
The controller according to data protection laws is:
VTN Global
If you have any questions or suggestions about data protection, you can send us an email to support@vtn-global.com
3. COLLECTION AND USE OF YOUR DATA
3.1. Player ID
When you first play our games, we may automatically create a pseudonymized user ID. We collect this data in order to provide you with access to our games, for example to your saved game and unlocked or purchased content, Article 6(1)(b) GDPR.
3.2. Social Features, Game Center
In some of our games you may also connect your player to third-party accounts such as your Facebook or Google account in order to participate in the Social Features and Highscores. You may also connect your game to your Game Center account.
If you connect your Facebook account with our games, the following data is shared with us:
- Name
- Profile picture
- Facebook ID
- Place of residence (if indicated by Facebook)
If you connect your account to your Game Center account or other third-party accounts such as Google, we may collect a pseudonymized unique identifier per connected third party provider.
Some of our games allow you to create a pseudonymized invitation link that you may send to your friends to connect directly via the Social Feature.
Please note: If you participate in the Social Features, your friends and contacts that also participate in the Social Feature of the same game may also see that you play this game and you will also be displayed in the Highscore of your friends. In addition, when your account is connected to a third-party account, a list of your friends who also participate in in the same game and who have connected their same third-party account(s) with their game is shared with you.
You can cancel the connection with your Facebook account at any time by logging into Facebook and selecting the “Settings” option. The connection between Facebook and the app can be deleted under “Apps and Websites.”
You can cancel the connection with your Game Center account at any time in the settings menu of our games.
You can cancel the connection with your other third-party accounts at any time by sending a message to our Player Support Team via in-game chat or via email to support@vtn-global.com.
We collect this data to fulfil our contract by providing our app to you and to be able to connect your account if desired. We may also use this information on our legitimate interest to re-identify your player profile, for example when you lose access to your save game.
To the extent that we, as described above, process your data for the purposes of providing the functions of our app (e.g. player ID), we require these information to provide you with our games and their functions. Without this data, we are not able to provide these functions to you.
You are, however, not required to provide data of your third-party accounts and connect our games to them. Without this data, however, we are not able to provide the corresponding functions of our app to you.
3.3. Support requests
If you send support requests to us by email, via integrated HelpShift chat within the games or via messages within social media platforms, we collect and process the data from your request and data from your account, such as username and country.
We only collect this data in order to appropriately respond to your questions, to provide our app to you and to be able to process your request based on the contract we passed when you accepted the Terms and Conditions.
When you send support requests directly via the chat system integrated into our games, your provided personal data will be transmitted to our help desk provider HelpShift. By sending support requests via the chat system, you understand and agree with the transmission of the personal data required to process your support request.
The data sent by you to us via contact requests remains with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions in particular statutory retention periods remain unaffected.
4. PERMISSIONS
Our app uses the following permissions:
| Permission | Purpose |
| Autostart | Necessary for sending notifications to the user |
| Network connection display | Receives information regarding the existence of and connection to networks. |
| Google Play billing service (Android) | Allows the user to purchase in-game products. |
| Full access to the network | Necessary for sending data to the Internet. |
| Location | Necessary to provide contextually relevant and/or personalized customer experiences |
| Search & Siri suggestions (iOS) | If this function is enabled, information from the game can be displayed when searching, looking things up, and when keyboards are displayed, and Siri can learn from use of the app and make suggestions. |
| Notifications (symbols, tones, banners, control of vibration) | If notifications are enabled in the settings, these can be sent to the player in order to display important events over the course of the game. |
| Background updates | If this function is enabled, background updates can take place. |
| Mobile data | The player can allow access to mobile data so that it can use all the functions of the game without being connected to Wi-Fi. |
| Access to local storage | The app characterizes the local storage and accesses it in order to be able to execute the services. |
5. STATISTICS AND ANALYTICS
For the needs-oriented design and statistical analysis of usage of our app, we collect pseudonymized data about how our apps are used, and we evaluate this data statistically.
Specifically, we use third-party analytical tools in connection with our own Services. These partners process your data only at and according to our specific instructions and may use cookies and other tracking technologies to collect information about your use of our Apps.
We collect this data on the basis of a legitimate interest in needs-oriented design.
6. ADVERTISING NETWORKS
We use third-party analytical tools to deliver advertising and content relevant to your interests.
These partners process your data only at and according to our specific instruc-tions and may use cookies and other tracking technologies to collect information about your use of our Apps.
This collected information includes, but is not limited to installation data, in-app events, language, platform, device type, operating system version or device IDs such as advertising IDs and usage information.
We use the following advertising networks in order to be able to integrate advertising within our free-of-charge apps. These collect the data described below for the purpose of providing personalized advertising:
| Advertising network | Provider | Type of data |
| AppLovin | AppLovin Corporation, 1100 Page Mill Road, Palo Alto CA 94304, USA | Device make, model and operating system; Device properties related to screen size & orientation, audio volume and battery, device memory usage; Carrier;
Operating system; Country, time zone and locale settings (country and preferred language); Network connection type and speed; IP Address; Internet browser user-agent used to access the Services; and Identifier for advertisers (Privacy policy) |
| AdMob/Google | Google Corporation, 1600 Amphitheatre Parkway in Mountain View, California, USA | Online identifiers, including cookie identifiers, internet protocol addresses and device identifiers; client identifiers (Privacy Policy) |
| AdColony | AdColony Inc. 1888 Century Park East, Suite 1450, Century City, CA 90067, USA | IP address, device advertising identifiers, the type of phone or other mobile device used, the operating system, the date and time a particular ad is served, whether one of the ads facilitated by them was delivered and, if applicable, a record if that ad was “clicked” or if it originated from a follow-up action to a third party such as a “conversion” event, combined with personal data to help AdColony optimize and/or refrain from advertising for a mobile application that has already been downloaded onto a device. |
| Chartboost | Chartboost One Sansome Street Floor 21 San Francisco, CA 94104, USA | Language, operating system, device type, IP address, MAC address, device ID, Advertising ID, Android ID, statistics on video ads that have been viewed, length of use of an app, data regarding in-app purchases |
| Facebook Ads | Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA | Device attributes (operating system, hardware, software versions, etc.), processes on the device, identifiers (unique identifiers, device IDs, and other identifiers), device signal (Bluetooth, WLAN, etc.), device settings data (GPS, camera, photos), network and connections (mobile radio or Internet provider, language, time zone, IP address, etc.), cookie data. (Privacy policy) |
| Unity Ads | Unity Technologies 30rd Street, San Francisco, CA 94103, USA | Device information, IP addresses, device identifiers, combined with Unity Analytics to personalize advertising. |
| IronSource | IronSource, 17 Bluxome St, San Francisco CA 94107, USA | Device type (manufacturer and model), operating system, IP address, Advertising Identifier, and/or, time zone, language settings, type of internet connection, geographic information on the device, type of advertising, content of advertising, post-click information related to advertising. |
| Ogury | Ogury Ltd., 3rd floor, Classic House, 174-180 Old Street, London EC1V 9BP. | The type of Device being used (including manufacturer and model).
The version number of the Ogury Technologies used by the App. A User’s network status (limited to connection type; gsm, 3G, 4G/wifi etc). the User’s email address & other mobile advertising identifiers on the Device. your Device’s unique Advertising ID. IP Address. |
| Vungle | Vungle Inc., 185 Clara Street San Francisco, CA 94107, USA | IP address, Android ID, MAC address, Advertising ID, activity and page visits, language, device information, time zone and city, geographic information, operating system, information about installed apps, and already viewed advertising. (Privacy policy) |
| TikTok/Bytedance | Beijing Bytedance Technology Co., Ltd. No. A48, Zhichun Road, Haidian District Beijing, Beijing, 100000 China | IP address, device information including, but not limited to, identifier, name, and type of operating system, information obtained from Cookies (as defined below) and other tracking technologies, time zone and locale setting, and server logs (which can include information like access dates and times). (Privacy policy) |
| Tapjoy | Tapjoy Inc, 353 Sacramento Street, San Francisco CA 94111, USA | Device identifiers, information about the device itself, information about the internet connection used to access our services, information about the app and the SDK, location-related information, ad-related information, survey information, information from advertisers or publishers. |
| Mintegral | Mintegral International Limited, 31F Radiance (Jinhui) Qiyang Rd., Wanging, Chaoyang District, Beijing, China | Personal information including the following: device make, device model, operating system (e.g.iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name and properties of mobile application through which a consumer interacts with the Mintegral Services or services provided by Mintegral’s business partners, country, time zone and locale settings (country and preferred language), network connection type, IP address, Internet browser user-agent used to access the Advertising Services, , network provider, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for advertising, OS version of device, network status such as WiFi, the geo-location of the device, Advertising ID, international mobile equipment identity (IMEI), , the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news), the ad type (e.g. whether the ad is a text, image, or video based ad), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. |
| HyprMX | HyprMX Mobile, LLC, 28 W 44th Street, NY 10036, USA | Registration and survey information, consisting of information you choose to submit
Activity and device information, device, operating system and browser, IP address ads or engagements viewed and interacted with, advertising identifier, geolocation data, wireless service provider. |
You can object to the use of personalized advertising by making the following settings depending on your device type: On iPhone or iPad, first open “Settings,” tap on “Privacy,” and open “Advertising.” Here you can enable “Limit Ad Tracking.” If you use devices with Android and Google Play Services, first open “Google Settings,” tap on “Advertising,” then open “Disable interest-related ads,” then tap on “OK.”
Use of the aforementioned advertising networks and the transmission of the data mentioned is based on our legitimate interest in recouping our investments for operation of our app through advertising.
7. DISCLOSURE OF DATA
We may share your data with:
- The technical service providers involved in the supply of the services. As subcontractors, these service providers are under the same obligations as VTN Global to comply with applicable personal data protection laws.
- Other companies, only in the event of a transfer of VTN Global activities.
- Administrative or judicial authorities to verify the proper use of our services or for the purposes of an investigation, in compliance with applicable law. VTN Global always verifies the legitimacy of the request.
In such cases, your data may be transferred to countries located outside of the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of your data is especially ensured by the signature of standard contractual clauses approved by the European Commission.
8. DELETION OF YOUR DATA
Unless the law specifies a different retention period, we will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs, unless the data must be kept longer for legal purposes.
If data must be kept for legal reasons, they are blocked. In that case they are no longer available for further use.
9. AGE LIMITS
To use our services you must confirm full legal capacity or, in case of restricted legal capacity, obtain the consent of your legal guardian. We do not knowingly collect or ask for personal information from children. In case you can’t confirm full legal capacity, please do not send us any data about yourself, including name, address or email address. If we learn that we have collected personal data of a child, we will delete these as soon as possible. If you think that we might have data from a child, please contact us at support@vtn-global.com.
10. YOUR RIGHTS
In case you have questions about this Privacy Policy or want to exercise your rights as described below, please contact us via email at support@vtn-global.com.
10.1 Obtain a copy of your Data – “Right of access and data portability”:
At any time, you can request a copy of your Data. You may also consult the Data, use it yourself or transfer it to another service provider.
10.2 Correct your Data – “Right to rectification”
You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).
10.3 Delete your Account – “Right to erasure (right to be forgotten)”
You can request the closure of your Account and the deletion of the associated Data.
10.4 Limit the use of your Data – “Right to restriction of processing”
You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.
10.5 Give and withdraw your consent – “Right to object and withdraw your consent”:
At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers) by email request to support@vtn-global.com.
We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority.
11. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy, if necessary, in compliance with the applicable data protection regulations. This way, we can adapt it to the current legal requirements and take changes in our services into account, e.g. when introducing new services. The most current version always applies to your visit.
The current version of this Privacy Policy is always available at support@vtn-global.com