This Privacy Policy explains how your personal data is collected and processed by Kusya Games (“Kusya Games”, “we”, “us”) when you use our mobile applications (the “App”) and our website kusya-games.site.
The App is a free-to-play game (with optional in-app purchases), and in order to maintain the high quality and a great game experience we process information from and about you, in particular to improve the entire experience in the App and to support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.
When you access or use the App, we automatically collect general information about you, including:
If you log into the App using a third-party site or platform such as Apple Game Center or Google Play Games, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third-party site or platform, provided that you have given the third party in question such consent.
You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:
If you log into the App using a third-party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) you are over the minimum age limit prescribed for such third-party site or platform by the legislation in your jurisdiction.
We use information about you for the following purposes in accordance with the legal bases described below.
Log, device, usage and consumption information and device identifiers are processed:
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
Our processing for the above purposes is justified by our legitimate interests in improving our services and keeping them safe, in accordance with Article 6(1)(f) of the GDPR (also known as “the balancing-of-interest rule”).
The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. On iOS this consent is collected through Apple’s App Tracking Transparency (ATT) framework.
We only process your information to the extent necessary to achieve the purposes for which the information has been collected.
Kusya Games will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data is deleted or anonymized as soon as it no longer serves one of the above-mentioned purposes and in any event no later than three (3) years after your interaction with Kusya Games has ceased.
We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your device identifiers with advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use, or may use, the following advertising network companies:
The recipients’ use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use the following data processors, including server hosting providers, technical service providers for supporting internal operations, and analytics service providers:
Use of the App is limited to users aged 13 years and above, except in the European Economic Area and the United Kingdom, where the App is limited to users aged 16 years and above (or the equivalent minimum age set by local law). If you are accepting this Privacy Policy and using the App, you warrant that you are 13 (or 16, depending on what is applicable) or more years old.
If you have additional questions about Kusya Games’s privacy practices related to children under the applicable minimum age, or if you believe that a child has provided us personal data without proper consent, please contact us at kusya.gaming@gmail.com and we will promptly delete such information.
In connection with our processing, we will in certain circumstances transfer your personal data to recipients outside the European Economic Area, the United Kingdom and Switzerland.
We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law. Such transfers will only occur on the basis of one of the following safeguards:
You can request a copy of the safeguards in place by contacting us at the address below.
Kusya Games takes reasonable administrative, technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. These measures include encryption in transit (TLS), restricted access to production systems and regular security reviews. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
We may send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications at any time by changing the notification settings on your device.
Kusya Games does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, Kusya Games does not sell your data. However, we have disclosed some categories of personal data we collect, as explained under “Sharing of information”, to third parties for the business purposes explained under “Use of information — purpose and legal basis”.
To the extent this practice is interpreted to constitute a “sale” or “sharing” under the California Consumer Privacy Act (CCPA/CPRA), please contact us at kusya.gaming@gmail.com to exercise your right to withdraw your consent on sharing your personal data with third parties.
We process and answer your requests without undue delay and in any event within one month of our receipt of the request, unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
You have the right to request access to the data that we are processing on you, see Article 15 of the GDPR, including information about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, and the envisaged period for which the personal data will be stored. You also have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data is processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
You have the right to request that we erase your personal data without undue delay when it is no longer necessary for us to retain it, see Article 17 of the GDPR.
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim, or to protect a person or important grounds of public interest.
If we have asked for your consent for our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to receive the personal data you have provided us with, which we process in a structured, commonly used and machine-readable format, and have the right to transmit that data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
You have the right to lodge a complaint with your local data protection supervisory authority if you consider that our processing of your personal data infringes applicable law.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Under the CCPA, each California resident can request that any business stop selling or sharing their personal information with third parties.
You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.
You can request us to disclose what personal data we have collected about you in the past 12 months. You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format. You can make this request for free, twice per year.
You can request us to delete the personal data we have collected on you. We fully recognize your right to deletion; however, in some cases we are obliged to keep your personal data for a certain period of time, for instance to provide services to you, to detect or resolve security or functionality-related issues, to comply with the law, or to carry out internal purposes that you might reasonably expect.
You have the right to request the correction of inaccurate personal information that we maintain about you.
California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights. We will not discriminate against you for exercising any of your CCPA rights.
If you are located in the Russian Federation, you have the rights provided by Federal Law No. 152-FZ “On Personal Data”, including the right to obtain information about the processing of your personal data, to request its rectification, blocking or deletion if it is incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purposes, and to withdraw your consent to the processing.
If you wish to use any of the rights described above, you may contact us at any time by emailing kusya.gaming@gmail.com.
Mandatory verification: we will need to verify your identity before processing your request. Because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, and we may use limited verification methods. To verify your identity, we will generally require matching the data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity — for example, if you have disabled tracking, changed the device you used to access the App, or already requested us to delete your personal data.
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:
Kusya Games
E-mail: kusya.gaming@gmail.com
Website: kusya-games.site
You may also contact your local data protection authority for unresolved complaints.