The privacy of your personal data is important to us. That’s why we’re preparing our privacy policy on Aug 6th, 2023.

This document provides a description of the privacy policy of SoftSecret with its registered office at Warsaw, ul. Światowida 51B, 03-144 Warsaw (“SoftSecret”, “we”, or “us”). The words “we”, “our”, “us” refer to SoftSecret and their affiliated companies.

This Privacy Policy (“Policy”) explains how personal information about you is collected, shared and used by SoftSecret and how you can exercise your privacy rights. This Policy applies to personal information that we collect when you use our website, mobile games (“Services”) or when you otherwise interact with us. Please read this Policy carefully.

We are committed to safeguarding your privacy. Our aim is to ensure you are kept up-to-date with any new regulations on personal data protection, including the General Data Protection Regulation 2016/679 (“GDPR”), California Consumer Privacy Act of 2018 (“CCPA”) and Brazilian Lei Geral de Proteção de Dados” or General Data Protection Law (“LGPD”). With this in mind, we want to make you aware of the legal basis for data processing, its collection, and use, as well as the rights of those who have their personal data processed.

If you have questions or concerns about this Policy you can contact us by email: softsecretgames@gmail.com.

Personal data is information about an identifiable or identified natural person. Processing personal data is, in essence, when any action is taken on personal data, regardless of whether this is an automatic or manual process, i.e., for the purposes of: collection, storage, organising, modification, reviewing, use, sharing access. Limited data may be deleted or shared. SoftSecret processes personal data for various reasons, depending on the reason, the application of the data will vary regarding how it is collected, what the legal basis is for its processing and use, as well as the terms for its storage. Our Services are not intended for children (under the age of 12 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data or target interest based advertising to children and we do not knowingly allow children to use the Services. Children should not use our Services or send us any personal data about themselves at any time. If you believe that we might have information from or about a child, please contact us at softsecretgames@gmail.com.

This policy tells you:

• what information we might collect about you
• how we might use that information
• when we might use your details to contact you
• what information of yours we might share with others
• your choices about the personal information you give us

We collect information about you directly from you and automatically through your use of our Services. We may combine information automatically collected with other information that we have collected about you or was provided to us by you directly.

Our services link to services run by other companies. Those companies have their own privacy and cookies policies, so remember that the information you give them will follow their rules and not ours.

1. Information that you give us

You may give us or we might ask for your name and contact details (e-mail address), your nick, your avatar or profile picture. 

2. Information provided by the User while using the Services (automatically collected):

• the unique identifier of the User’s mobile device (device ID) and device name,
• User preferences,
• data and analytics relating to your use of our Services, such as your overall progress on a level, virtual currency or completion of certain tasks during a game, making a purchase or viewing a video advertisement.

3. Information collected and used for the purpose of displaying advertisements:

• the model and operating system of your device,
• the characteristics of your device, such as screen size and orientation, volume and battery,
• the mobile network operator associated with your device,
• the games you play,
• the country, time zone and local settings on your device (i.e. country and preferred language),
• the type and speed of your network connection,
• IP address,
• Advertiser ID, which is your unique identifier if you are using an Apple or Android device.

4. Information collected for analysis purposes:

• User Device ID,
• User ID (generated by us and assigned to you when you first start our games),
• Your operating system and device version,
• the model of your device,
• number of game attempts, progress and results, the start, end and duration of your game session,
• the country in which your device is located,
• the time, date and source of installation of the first download (e.g. from a clicked advertisement),
• ads viewed and clicked on,
• identification of errors and faults.

5. Information on your activities outside the SoftSecret when you talk about us

For example if you’ve mentioned us in a social media post such as Twitter or Instagram post, we may collect your Twitter or Instagram profile data. 

We have to have a valid reason to use your personal information. It’s called the “lawful basis for processing“. 

We use your information for these types of things:

• to deliver our services and to provide you with information about them
• to enforce our usage policies
• to deal with your requests, complaints and enquiries
• to check if you’re using our services and to keep the licensing database accurate and up to date
• to personalise services and give you things more tailored to your tastes
• to communicate with you
• to understand and improve our services
• for legal Compliance. We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities
• to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
• as necessary or appropriate means to protect the rights, property, and safety of our users, us, and other third parties
  

Lawful bases include consent (where you have given a consent), performance of contract (where processing is necessary for the performance of a contract with you), legitimate interests (including complying with any applicable law, rule or regulation, investigation or remedy) and compliance with legal obligations and protection of individuals. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

We will share information we collect about you, including personal information, in the following ways:

• Third party service providers, agents or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyse and enhance data (including data about users’ interactions with our Services). These Service Providers may have access to your Personal Data or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services.
• Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy. 
• Aggregate or De-identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

• Unity – helps us to manage Third Party advertising and services – https://unity3d.com/legal/privacy-policy
• Google Play – through this platform we provide our services https://policies.google.com/privacy  
• AdMob – helps us analyse data by providing analytical tools – privacy policy: https://policies.google.com/privacy?hl=en

We’re strongly committed to keeping your data safe. 

At the same time, no service can be completely secure – if you have any concerns that your personal information has been put at risk, please get in touch straight away.

Some companies that provide services to us run their services from outside the European Economic Area. We only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information it could be being transferred, stored or processed in a location outside the EEA.

If you would like to delete or update your information, contact us by email: softsecretgames@gmail.com

Right for Personal Data that we have about you:

• Delete Data: You can ask us to erase or delete all or some of your Personal Data
• Change or Correct Data: You can ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your Personal Data
• Right to Access and/or Take Your Data: You can ask us for a copy of your Personal Data.

Our Services may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications.

This Notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100–1798.199, the California Privacy Rights Act, and the associated regulations (“CCPA”) and supplements the information contained in this Privacy Policy. 

You have the right to:

• request access to and receive the following information about the personal data we have held about you in the last 12 months
  • the categories of personal data we have collected about you
  • the categories of sources from which the personal data has been collected.
  • the business or commercial purpose of the collection of personal data
  • the categories of third parties to whom we sell or with whom we share your personal data
  • the specific personal data we have collected about you (e.g. data portability rights)
  • if we have sold or disclosed your personal data for business purposes, two separate disclosure lists: (i) the sale, identifying the categories of personal data that each category of recipients acquired, and (ii) the business purpose, identifying the categories of personal data that each category of recipients acquired.
• request deletion of your personal information
• opt-out of the sale of your personal information

You also have the right not to be discriminated against for exercising any of the above-mentioned rights.

You may appoint an authorised agent to make an application under the CCPA on your behalf. The authorised agent must submit a proxy that they have been authorised by you to act on your behalf and their proof of identity.

This Notice addresses the specific disclosure requirements under the  „Lei Geral de Proteção de Dados” or General Data Protection Law in English (“LGPD”) and supplements the information contained in this Privacy Policy. 

The information on the grounds on which we process your personal information, categories of personal information processed, transfer of personal information and how we can use your personal information you may find above. 

Additionally, under LGPD you have also rights to: 

• confirm the existence of data processing
• access to the data
• correction of incomplete, inaccurate or out-of-date data, 
• anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD
• portability of the data to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets;
• deletion of personal data processed with the consent of the data subject, except in the situations provided in art. 16 of the LGPD
• information about public and private entities with which we have shared data
• information about the possibility of denying consent and the consequences of such denial
• revocation of consent as provided in §5 of Art. 8 of the LGPD
  

We may change this Policy from time to time, and if we do, we will post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use SoftSecret after those changes are in effect, you agree to the revised Policy.