Last updated on 24 May 2018
Our approach to Privacy
Your privacy is important to us.
As an Ukrainian company operating globally, we strictly comply with Ukrainian privacy laws but we also strive for global best practice.
Children: Remember to be smart and safe online. Never give someone your information without first asking your parent/guardian if it is OK. Don't give anyone your photo, or tell anyone your name, email, home address, telephone, your school or any other information about you that they could use to contact you either online or in the real world.
If you want to enter one of our competitions, make sure you ask permission from your parent/guardian before you enter.
Parents: We are committed to the safety and privacy of the children who use our Services. We encourage parents/guardians to actively monitor their children's online activities. See more information below about children's privacy and our Child Safe Apps.
1.1 Information You Give To Us
We receive and store any information you give to us, such as when you:
1.2 Information Collected Automatically
We receive and store certain types of information automatically when you interact with us, such as:
1.3 Information From Third Parties
Sometimes we collect information about you from third parties, such as Apple, Amazon, Facebook, or Google. We collect this information so that we can deliver Services you have requested. We collect this information:
2. How Do We Use Your Information?
We use the information we collect about you:
We may combine information about you that we have collected from multiple sources.
2.1 When Do We Disclose Information
We may disclose the personal information we hold about you in the following circumstances:
2.2 Childrens' Privacy
Child Safe Apps
If your ALMA Games game is labelled a Child Safe App, it was built with child safety as a priority. Our Child Safe Apps have no advertising, no data collection, no in-app purchases and no links to external sites or apps.
We do not knowingly contact or collect information from children under 13 without the permission of their parent/guardians. If you believe that we have inadvertently collected such information, please contact us so we can promptly obtain parental/guardian consent or delete the information.
2.3 Third Party Services
We encourage you to be careful about the protection of your own personal information when using third party services such as social media platforms.
We also work with certain business partners, such as other game developers and advertising partners, and information collected from you may be shared through these partnerships.
Some of our business partners are outside Ukraine. Below is a list of some, but not all, business partners that we actively share user information and site usage data with (this list is subject to change):
2.4 Marketing, In-app Purchases & Opting-Out
2.4.1 Direct Marketing
Sometimes we will use your information to tell you about our Services and our news, such as new games we are launching, events we are running, or merchandise we sell. You can opt-out if you don’t want to receive this information.
2.4.2 In-app Purchase
Some of our games offer in-app purchases. Examples of in-app purchases are items you can purchase (for real or in-game currency) or other additional features. If you don’t want to make in-app purchases, don’t use these paid-for options and consider disabling in-app purchases on your device.
Ways to opt-out of our Services:
If you need help opting-out please contact us at firstname.lastname@example.org
2.5 Storage & Security
We store information on servers in Australia and in the United States.
Security is important to us and we strive to protect both your information and our information in the best possible ways. But there are inherent risks in transmitting information over the Internet and it is possible that we could be hacked. You should feel comfortable with this level of risk before you provide information to us, or use our Services. If you are not comfortable with this risk, please do not use our Services.
2.6 Access & Correction
You may request access to your personal information at any time by sending a written request to our Privacy Officer by mail at ALMA Games,Telephonny, Ln. 4, app. 3, Poltava 36002, Ukraine, by email to email@example.com.
We may charge a small fee for providing access if it requires a significant amount of time to locate your information or to collect or present it in an appropriate form. We may decline your access if there are reasonable grounds for us to do so.
If your information changes, let us know so that we can update our records. If you would like us to de-activate your records that we hold, please tell us. Once de-activated your data will not be accessible. However, due to system backups to various types of data storage media, your data may in some circumstances remain on these types of data storage media. There may be circumstances where we decline to de-activate your records.
3. For users in the european union
3.1 Legal Basis for Processing
Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information. Typically, we will rely on the following legal bases for processing your personal information: your consent; where our processing is in our legitimate interest or in the legitimate interest of our Ad Partners or Service Providers; or where our processing is necessary to perform a contract with you (e.g. to make the Games or Websites accessible to you). If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
3.2 Transfer of Personal Information Outside of the EU
Because our Service Providers are located in countries outside of the European Union, your personal information may be transferred to other countries that may not offer the same level of data protection as the laws of your country of residence. We rely on model contractual clauses and/or the Privacy Shield certification for such transfers.
3.3 How to File Complaints
If you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence. For contact information for your supervisory authority, please visit here.
If you have any concerns or complaints about your privacy please contact us by:
Our Privacy Officer will respond to your complaint within a reasonable time after we receive it, provided you supply return contact details. If you do not provide return contact details, we will be unable to respond to your complaint, although we will consider its content.
5. Updates to this Policy
A unique ID that is generated for your device to track activity by advertising companies to improve their service in game. This is also known as Interest Based Advertising. You may be able to opt-out of this feature on some platforms. You may also be able to reset your advertising ID on your device.
Interpretation and interpolation of unidentified data to predict and isolate trends relating to game play and app use.
Child Safe App
An in-game system that allows exchanging real money for virtual goods or in-game currency.
IP Address (Internet Protocol Address)
A unique string of numbers separated by full stops or commas that identifies each computer using the Internet Protocol to communicate over a network. These numbers are usually assigned in geographic blocks.
ALMA Games ("us")
ALMA Games its assignees, licensees, successors in title and subsidiaries.
Services offered by us and includes our games, websites and related services.
An online business presence for sales. We work with Apple's App Store, Google Play and Amazon Appstore storefronts as our primary storefronts for sales but our games are also available on Windows Store, Xbox Marketplace and many others.
Terms of Service
Rules and conduct standards that are defined that one must comply with to use the service.
third party services
Services provided by a provider that is not owned or controlled by ALMA Games.