Last Updated : September 5, 2020
WHO WE ARE
Logisk Studio Inc. is a company under the laws of Canada ("Logisk" or "Logisk Studio" or "we"), a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store.
INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publisher’s Games. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games and may include information that you submit to us when you voluntarily contact us.
In the course of providing you with our Services, the information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit inquiries to us, such as:
your name, email address or other details, necessary to process your inquiries;
any information you submit to our support team via email.
Information that we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:
Your anonymized IP address, browser type, device type, broad geographic location (e.g. country or city-level location) based on your IP address, and information about your game play and activities on our Services (e.g. in-game play progress, levels, games played, session length, user actions) are collected automatically while you use our Services (your “Analytic Information”). The legal basis for collecting this information is to fulfill a contract with you, under GDPR Art. 6 (1) (b).
Device identifiers such as your Advertising ID, Device ID numbers. The legal basis for collecting this information is our legitimate interest, under GDPR Art. 6 (1) (f).
Your name and email address, if you sign up for our newsletter (your “Contact Information”). The legal basis for collecting this information is your consent and our legitimate interest, under GDPR Art. 6 (1) (a) and (f).
HOW WE USE YOUR INFORMATION
We use your information for the following purposes:
Delivering and improving our services. Your Analytic Information is gathered and pooled with other users’ information, and used for the purposes of delivering and improving our Games and other products, such as tracking the total number of users of our Services, their aggregate activities and actions, game play data and other game play analytics, potential problems or trends with our Games and services.
Cross-promotion.We use your information for cross-promoting our Games and services, meaning to promote one of our Games while you are playing a different Game of ours.
Tracking and fraud prevention for advertising purposes.We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.
Security. We use your information for enhancing the safety and security of our Games, products and services.
Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.
Our Games enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.
HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Games by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. Those partners usually collect data via their own tools (Software Development Kits or “SDK”). We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
Our third party partners, and their privacy policies are as follows:
Allow us to monetize the ad inventory of our apps and provide users with free products and services.
Provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it.
Allows us to notify you about updates and releases of new Games.
We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Logisk, its employees, clients, or users of our Services.
Links to Other Sites
Please note that some data may be retained if necessary to resolve disputes, enforce Logisk user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of our Services. If you request us to delete your data will delete your data as described below in “Your Rights” Section.
We use advertising to fund our Services and to make our games available for free. We offer our Games for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base.
If you are an European Economic Area (EEA) – based user be aware that:
(i) When you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR .We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.
(ii) Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at relevant button at loading of the Game. We allow our advertising partners to show personalized ads to you only if you explicitly give consent in the relevant pop-up window. We may decide to not display any pop-up window requesting for consent to display personalized ads. In such case, we will display non-personalized ads by default. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you consent to show you personalized ads at loading of the Game. The legal basis to show personalized ads to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve our Games and provide the player with more relevant ads. You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Game settings and you will be able to manage your preferences by choosing to which advertising you would like to get. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.
To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads.
Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed above) including:
limit the number of times you see the same ad;
ensure they are dealing with humans with real devices and not ‘automated’ bots;
serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;
keep track what games you have used to market you similar kind of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).
How to turn off personalized ads
Besides specific instruments available to EEA-based users via the Game you can use your device settings.
Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.
Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.
EU RESIDENTS - YOUR RIGHTS
If you are EEA-based user you have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests using the contact channels provided in the "Contact Us" section below.
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
CALIFORNIA RESIDENTS - YOUR RIGHTS
If you are a California resident, beginning on January 1, 2020, the California Consumer Privacy Act (CCPA) gives you the following rights:
Right to Know: You can ask us what personal data we hold about you and request a copy of the information. This information includes:
The categories of personal information we have collected about you.
The categories of sources from which we collect the personal information.
The business or commercial purpose for collecting your personal information.
The categories of third parties with whom we share that information.
The specific pieces of personal information we have collected about you.
Right to Delete: You can request that your personal information be erased. However, there are some exceptions to this right, in situations where we:
Need to complete the transaction for which the personal information was collected, provide a good or service that you requested, or that is reasonably anticipated within our ongoing business relationship with the consumer, or to otherwise perform a contract between us.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
Need to comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us.
Need to comply with a legal obligation.
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt Out: Logisk does not sell any of your personal information for any purposes.
Other Rights: In addition to the rights above, you also have the right to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the calendar year preceding your request. This request is free and may be made only once a year.
You also have the right not to be discriminated against for exercising any of the rights of California residents listed in this section.
If you would like to exercise any of the rights listed above, please follow the instructions in the section "Data Requests" below and contact us at the addresses below in the section entitled “Contact Us".
Whether you’re making a data request under GDPR or CCPA, we will need certain information in order to verify your identity and process a data request. Please provide your unique Advertising IDs for any device you’re using to play the Game, along with the device type (Android or iOS) associated with each Advertising ID.
Logisk is based in the Canada. Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Some of the partners and processors referred to in this policy are located outside of the European Union.
In such case, we ensure that:
the personal data is transferred to countries recognized as offering an equivalent level of protection or,
Personal data is transferred to certified entities under the Privacy Shield or,
For personal data transferred outside of countries recognized by the European Commission as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of the standard contractual clauses of the European Commission.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.
For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We do not store any of your personal information .
We do not knowingly collect any personal information from children under the age of 13, allow them to sign up for newsletters, make purchases, or use the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. Logisk takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online.
This Policy may change from time to time. We will always keep this up to date so that you know what information we will collect from you, how we may use it, and when we may disclose it.