stub June 2023 – Kosmos

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TU v1

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING OUR SERVICES. USE OF ANY OF OUR PRODUCTS OR SERVICES INDICATES THAT YOU AGREE TO ABIDE BY ALL THE TERMS AND CONDITIONS OF THIS AGREEMENT. IF YOU DO NOT AGREE TO THESE TERMS OF USE, YOU MUST NOT INSTALL, USE, OR OTHERWISE ACCESS THE SERVICES. USE OF THE SERVICES IS VOID WHERE PROHIBITED.

These terms of use (“Terms of Use”) are a legal agreement between Kosmos Games (Cyprus) Ltd. (“Kosmos Games”, “we”, “us”, or “our”) performing on behalf of Kosmos Games (Cyprus) Ltd. and our users (“Users”, “your”, or “you”) regarding your use of social and mobile games controlled by Kosmos Games (Cyprus) Ltd. that are available on social network sites and mobile phone stores (“Applications”) and the related services (“Services”). Please read these Terms of Use AND our Privacy Policy before using any part of the Services. By using the Services, you agree to be bound by these Terms of Use including, without limitation, disclaimers of warranties, limitations of liability, and a requirement that you meet specified age requirements.

The term “Services” means the online, mobile, PC or other video games including, but not limited to, Golden Prairies, Merge Tales, Solitaire Social, Mahjong and other, and other related services, including the Kosmos Games (Cyprus) Ltd. website (https://kosmos.games/), on which these Terms of Use are published.

1. Service changes and limitations:

The Service is evolving and we may require that you accept updates to the Service as well as to the Terms and Community Rules. From time to time we may make you update the game or your software to continue to use our Services. We may perform these updates remotely, including to Kosmos Games (Cyprus) Ltd. software residing on your computer or mobile device, without notifying you.

Kosmos Games reserves the right to stop offering and/or supporting the Service or a particular game or part of the Service at any time, either permanently or temporarily, at which point your license to use the Service or any part of it will be automatically terminated or suspended. If that happens, Kosmos Games is not required to provide refunds, benefits, or other compensation to players in connection with discontinued elements of the Service or for virtual goods previously earned or purchased.

KOSMOS GAMES MAY, AT ITS SOLE DISCRETION LIMIT, SUSPEND, TERMINATE, MODIFY, OR DELETE ACCOUNTS OR ACCESS TO THE SERVICE OR ANY PORTION OF IT, AND PROHIBIT ACCESS TO OUR GAMES AND SITES, AND THEIR CONTENT, SERVICES AND TOOLS, DELAY OR REMOVE HOSTED CONTENT, AND KOSMOS GAMES. IS UNDER NO OBLIGATION TO COMPENSATE YOU FOR ANY SUCH LOSSES.

Deleting your account: Service updates

The Service is an evolving one, and we reserve the right to change the Terms of Use from time to time, so make sure to check it periodically.

2. Account

You must have an account on the corresponding social networking site or accounts in mobile phone stores through which you access the Services. You agree to provide, maintain, and update true, accurate, current, and complete information about yourself as prompted by the registration processes. Kosmos Games will observe the accuracy of the information about you and will update it when necessary. The user has the right to require Kosmos Games to rectify any inaccurate personal data.

When you access our Services, your username and your profile photo may become publicly visible by other users.

You agree to promptly notify Kosmos Games of any unauthorized use of your username, password, other account information, or any other breach of security that you become aware of involving or related to the use of the Services under your account. You are entirely responsible for any and all activities that occur under your account. We will not be liable for any loss that you may incur as a result of someone else using your password or account, either with or without your knowledge.

3. Access to the Service; limited license

Subject to your acceptance of these Terms of Use, you are granted a non-exclusive, revocable, limited, non-transferable, and non-sublicensable license to use the Services solely for personal, non-commercial entertainment purposes (“License”).

You acknowledge and agree that your License does not include:

  • any resale or commercial use of the Services;
  • the distribution, public performance, or public display of the Services;
  • the modification, revision, creation of derivative works, or otherwise making any derivative uses of the Services or any information or content therein;
  • decompilation, reverse engineering, or any other attempts to derive the source code for the Services (except to the extent applicable laws specifically prohibit restriction of such activities); or
  • any use of the Services other than for their intended purposes as expressly stated in these Terms of Use.

Unless explicitly stated herein, nothing in these Terms of Use shall be construed as conferring any license to intellectual property or other proprietary rights, whether by estoppels, implication, or otherwise.

Your use of and access to the Services is subject to all applicable local, state, national, and international laws and regulations, and you agree not to violate such laws and regulations in your use of and access to the Services. In addition, you agree that:

  • you will not interfere with another user’s use and enjoyment of the Services;
  • you will not disguise, anonymize, or hide your IP address or the source of any Content that you may upload;
  • you will not interfere with or disrupt our Services or servers, or networks that provide our Services;
  • you will not attempt to decompile, reverse engineer, disassemble, or hack any of our Services, or to defeat or overcome any of our encryption technologies or security measures, or modify the data transmitted, processed, or stored by us;
  • you will not “harvest”, “scrape”, or collect any information about or regarding other people that use our Services, including, but not limited to any personal data or information (including by uploading anything that collects information including, but not limited to “pixel tags”, cookies, graphics interchange formats (“gifs”), or similar items that are sometimes also referred to as “spyware” or “PCMs” (passive collection mechanisms);
  • you will not sell, transfer, or try to sell or transfer an account with us or any part of an account including any Virtual Currency or Virtual Goods;
  • you will not disrupt the normal flow of a Service or otherwise act in a manner that is likely to negatively affect other players’ ability to compete fairly when using our Services or engaging in real-time exchanges;
  • you will not disobey any requirements or regulations of networks connected to our Services;
  • you will not use our Services to cheat, or design or assist in cheating (for example, by using automated means or third-party software to play), or to otherwise circumvent technological measures designed to control access to our Services, or elements thereof, or to do anything else that a reasonable person is likely to believe is not within the spirit of fair play or these terms;
  • you will not use our Services in any other way not permitted by these terms;
  • you will comply with U.S. and other applicable laws regarding the transmission of technical data exported from the United States with respect to or relating to any of your dealings with the Services.

You also agree to defend, indemnify, and hold harmless Kosmos Games, as well as its parents, subsidiaries, affiliates, officers, shareholders, employees, and independent contractors from any loss, liability, damages, and expenses (including without limitation reasonable attorneys’ fees) resulting from any claim or demand made by any third party arising out of or in connection with your use of the Services, any User Content (defined below), your violation of these Terms of Use, or your violation of the rights of any third party.

Any use of the Services other than as specifically authorized herein, without the prior written permission of Kosmos Games, is strictly prohibited and will terminate the License granted herein, and may subject Users to liability for violations of law.

4. Children

We acknowledge our responsibility to protect children’s data and do not deliberately collect data from individuals younger than 18 years of age. If it comes to your knowledge that children’s rights have been infringed when using our Services, please contact us immediately so we can take all the reasonable steps to amend the situation.

If you are older than 13 but younger than 18 years old, we reserve the right to collect your personal data only if your parent or legal guardian has explicitly agreed that you can use our Services, and Kosmos Games can collect and process your personal data. We strongly recommend that the underage users older than 13 but younger than 18 years of age receive a permission from a parent or legal guardian before accessing and/or using our Services and submitting their personal data.

By using our Services, you explicitly confirm that your parent or legal guardian gave the permission to collect and process your personal data when you use our Services. Children younger than 13 years of age cannot submit any personal data, such as name, address, telephone number or email. If you discover that we have received personal data from individuals younger than 13 years old, please contact us immediately.

5. Suspension and termination of Services

You have the right to stop using the Services or any part thereof at any time. If you do not agree with these Terms of Use, your sole remedy is not to use the Services. You understand and agree that it is your sole and exclusive remedy with respect to any dispute with Kosmos Games

You are also entitled to withdraw your consent to process your personal data in accordance with these Terms of Use and the Privacy Policy and erase your personal data. The withdrawal of your consent means that you do not agree with the Terms of Use and stop using the Services. After the withdrawal of your consent, you lose the opportunity to use Services, since it is impossible not to process your personal data while you use the Services.

Kosmos Games reserves the right to stop offering and/or supporting the Services or any part thereof at any time, either permanently or temporarily. In such an event, your License to use the Services or a part thereof will be automatically terminated or suspended.

Kosmos Games may also terminate your access to Services, with or without notice to you, if Kosmos Games (at its sole discretion) deems that you have violated these Terms of Use or have otherwise caused or may cause damage to any third party.

You acknowledge and agree that, in the event of your access to the Services being terminated, you will forfeit any benefits, including without limitation any earned or purchased virtual items (defined below), and Kosmos Games shall be under no obligation to compensate you for any such losses.

6. Fees and payment

The Services may include games and/or applications where you will have an option to buy or purchase

  • “war bonds”, “qrystals”, or any other online currency (“Virtual Currency”); or
  • a variety of virtual in-game items and goods (“Virtual Goods”) that can be used to enhance your gaming experience (Virtual Currency and Virtual Goods collectively, “Virtual Items”).

You acknowledge that you do not in fact “own” the Virtual Items and you only will have a limited license to use such Virtual Items in the Services. No Virtual Item or any part thereof refers to or has any real-world currency value.

You may be required to pay a fee with real world currency in order to obtain Virtual Items by using payment methods disclosed in the game.

You agree to pay all fees and applicable taxes incurred by you or anyone using the Services under your Account.

Kosmos Games shall have no liability for hacking or loss of Virtual Items from your account. However, Kosmos Games will use reasonable efforts to replace such items under certain circumstances, at our reasonable discretion. Kosmos Games has no obligation or responsibility to and will not reimburse you for any Virtual Items lost due to your violations of these Terms of Use. Kosmos Games reserves the right, without prior notification, to limit the order quantity on any Virtual Items and/or to refuse to provide you with any Virtual Items. Verification of certain information applicable to a transaction involving a Virtual Item may be required prior to our acceptance thereof. Kosmos Games may revise the pricing for the Services including the Virtual Items offered through the Services at any time for any reason.

You acknowledge that Kosmos Games is not required to refund the fees or your purchases for any reason, and your purchase of virtual items is final and shall under no circumstances be refundable, transferable, or exchangeable (except where expressly specified otherwise within the Services) including, without limitation, upon termination of your access to the Services by Kosmos Games for any reason, termination of these terms and conditions, and/or the discontinuation of the Services. Regardless of the consideration offered or paid in exchange for Virtual Items, you do not have any ownership rights in the Virtual Items and you receive only a limited right to use the Virtual Items as described in these Terms of Use. All Virtual Items are forfeited if your access to the Services is terminated or suspended by Kosmos Games for any reason, at Kosmos Games’s sole and absolute discretion, or if Kosmos Games discontinues providing the Services.

7. Intellectual property

The Service is comprised of works owned by Kosmos Games, and it is protected by copyright, trademark, trade dress, patent and intellectual property, and other applicable laws, rules, or regulations. Kosmos Games owns, has licensed, or otherwise has rights to use all of the content that appears in the Service. These Terms do not grant you or any other party any right, title, or interest in the Service or any content in the Service.

So long as you abide by these Terms, Kosmos Games grants you a non-exclusive, non-transferable, revocable limited license subject to the limitations in these Terms, to access and use the Service using a Kosmos Games supported web browser or mobile device solely for your own non-commercial entertainment purposes. You agree not to use the Service for any other purpose.

If you violate these Terms, or any of our other terms that apply to you, we may take action against you, up to and including permanently suspending your account. In addition, you may be breaking the law, including violations of Kosmos Games intellectual property rights.

ANY ATTEMPT TO DISRUPT OR INTERFERE WITH THE SERVICE, INCLUDING, WITHOUT LIMITATION, UNDERMINING OR MANIPULATING THE LEGITIMATE OPERATION OF ANY KOSMOS GAMES SERVICE, IS A VIOLATION OF KOSMOS GAMES (CYPRUS) LTD PLAYKOT POLICY AND MAY BE A VIOLATION OF CRIMINAL AND CIVIL LAWS.

8. Conduct requirements

The Services may include features or functionality that may be used to communicate with other users of the Services or to otherwise post or transmit information or content (the “User Content”). You agree to use the Services in accordance with the following conduct requirements:

  • you may not transmit or post any User Content that is unlawful, libelous, defamatory, obscene, pornographic, indecent, lewd, suggestive, harassing, threatening, invasive of privacy or publicity rights, abusive, inflammatory, fraudulent, or racially, ethnically or otherwise objectionable;
  • you may not transmit or post any User Content that would constitute, encourage, or provide instructions for a criminal offense, violate any party’s rights, or that would otherwise create liability or violate any law or regulation in any jurisdiction worldwide;
  • you may not transmit or post any User Content that may breach any contractual or fiduciary relationship or that may infringe any patent, trademark, trade secret, copyright, or other intellectual property or proprietary right of any party;
  • you may not impersonate any person or entity, or otherwise misrepresent your affiliation with any person or entity;
  • you will comply with all applicable laws regarding the transmission of technical data exported from, or imported into, the United States or the country in which you reside;
  • you may not forge message headers or otherwise disguise, or attempt to disguise, the existence, source, or destination of any User Content that you transmit or post;
  • you may not engage in unsolicited promotions, political campaigning, advertising, or solicitations;
  • you may not transmit or post private information of any third party, including, without limitation, addresses, telephone numbers, credit card numbers, email addresses, and any unique identifier such as a Social Security number;
  • you may not transmit or post any viruses, corrupted data, or other files;
  • you may not transmit or post any User Content that, in the sole judgment of Kosmos Games, is objectionable or which restricts or inhibits any other person from using or enjoying the Services or any related features or services;
  • you may not transmit, post, or otherwise cause, instigate, or assist in the distribution of spam.

Kosmos Games takes no responsibility and assumes no liability for any User Content transmitted or posted by you or any third party, or for any loss thereof or damage thereto. Kosmos Games is not liable for any mistakes, defamation, slander, libel, omissions, falsehoods, obscenity, pornography, or profanity you may encounter. Your use of the Services and the Applications and any related features or services is at your own risk. As a provider of interactive services, Kosmos Games is not liable for any statements, representations, information, or content provided by its users on any public forum, personal homepage, or other location.

Although Kosmos Games has no obligation to screen, edit, or monitor any information or content transmitted or posted by the Services users, Kosmos Games reserves the right, and has absolute discretion, to remove, screen, or edit any information or content transmitted or posted on or through the Services and any related features or services at any time and for any reason without notice.

You are solely responsible for creating backup copies of and replacing any information or content that you post or store on or through the Services or any related features or services at your sole cost and expense. You represent and warrant that:

  • you own and control all of the rights to, or otherwise have the right to transmit or post, the information and content that you transmit or post on or through the Services and any related features or services;
  • such information and content is accurate and not misleading; and
  • the use and posting of the information and content you supply does not violate these Terms of Use and will not violate any rights of or cause injury to any person or entity.

If you have a dispute with any other user or users, you hereby release Kosmos Games and hereby agree to indemnify Kosmos Games from any and all claims, demands, and damages including direct, consequential, and indirect of every kind and nature, known and unknown, arising out of or in any way connected with such a dispute.

9. Monitoring use of service

We have no obligation to monitor User Content and we are not responsible for monitoring the Service for inappropriate or illegal User Content or conduct by other players. That said, we have the right, at our sole discretion, to edit, refuse to post, or remove any User Content.

We may also, at our discretion, choose to monitor and/or record your interaction with the Service or your communications with Kosmos Games or other players (including, without limitation, chat text and voice communications) when you are using the Service in order to provide you with personalized advertising offers, improve our Service, and provide security measures during the use of the Service.

We are not responsible for information, materials, products, or services provided by other players (for instance, in their profiles). However, if someone is violating these Terms or misusing the Service, please let us know by using a “Report Abuse” link provided in the Service or contact us at Customer Support.

10. Warranties

Neither Kosmos Games nor any Kosmos Games affiliate makes any promise or guarantee that the Service will be uninterrupted or error-free.

We take all the necessary and possible measures in terms of technology in order to guarantee the protection of your personal data from data breach and we will immediately inform you about such a breach.

USE OF THE SERVICE IS AT YOUR SOLE RISK. IT IS PROVIDED ON AN “AS IS” BASIS. TO THE EXTENT PERMITTED BY APPLICABLE LAW, KOSMOS GAMES AND ALL AFFILIATES MAKE NO WARRANTIES, CONDITIONS, OR OTHER TERMS OF ANY KIND, EITHER EXPRESS OR IMPLIED, ABOUT THE SERVICES. KOSMOS GAMES AND ALL KOSMOS GAMES AFFILIATES DISCLAIM ANY WARRANTIES OF TITLE OR IMPLIED WARRANTIES, CONDITIONS OR OTHER TERMS OF NON-INFRINGEMENT, MERCHANTABILITY, QUIET ENJOYMENT, OR FITNESS FOR A PARTICULAR PURPOSE.

If your state or country does not allow these disclaimers, they do not apply to you. If your state or country requires a certain period for which a warranty applies, it will be either the shorter of 30 days from your first use of the Service or the shortest period required by law.

11. Limitations of liability

YOU ACKNOWLEDGE THAT KOSMOS GAMES AND KOSMOS GAMES AFFILIATES SHALL NOT BE LIABLE FOR:

(1) ANY INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, OR CONSEQUENTIAL DAMAGES, INCLUDING FOR THE LOSS OF PROFITS, GOODWILL, OR DATA, IN ANY WAY WHATSOEVER ARISING OUT OF THE USE OF, OR INABILITY TO USE, THE SERVICE; OR

(2) THE CONDUCT OF THIRD PARTIES, INCLUDING OTHER USERS OF THE SERVICE AND OPERATORS OF EXTERNAL SITES.

However, Kosmos Games shall be responsible for any personal data breach, where it is caused by an event which is in the control of Kosmos Games This provision includes the activities of Kosmos Games and its processors, who process personal data on behalf of Kosmos Games

An event that is in the control of Kosmos Games is an event which was caused by the actions of Kosmos Games

An event that is not under the control of Kosmos Games is an event which was caused by a third party’s actions or where its emergence is mainly dependent on the actions of a third party (including, but not limited to third-party offenses, hacker attacks, unauthorized access by third parties, and/or disabling of the software and/or hardware, and the actions and acts of state bodies) or which was caused by force majeure circumstances (including, but not limited to fire, faults and errors in communication networks, and actions of malicious programs [viruses]).

THE RISK OF USING THE SERVICE AND EXTERNAL SITES RESTS ENTIRELY WITH YOU, AS DOES THE RISK OF INJURY FROM THE SERVICE AND EXTERNAL SITES.

TO THE FULLEST EXTENT ALLOWED BY ANY APPLICABLE LAW, THE DISCLAIMERS OF LIABILITY IN THESE TERMS APPLY TO ALL DAMAGES OR INJURY CAUSED BY THE SERVICE, OR RELATED TO USE OF, OR INABILITY TO USE, THE SERVICE, UNDER ANY CAUSE OF ACTION IN ANY JURISDICTION, INCLUDING, WITHOUT LIMITATION, ACTIONS FOR BREACH OF WARRANTY, BREACH OF CONTRACT, OR TORT (INCLUDING NEGLIGENCE).

TO THE MAXIMUM EXTENT PERMISSIBLE UNDER APPLICABLE LAWS, THE TOTAL LIABILITY OF KOSMOS GAMES AND/OR THE KOSMOS GAMES AFFILIATES IS LIMITED TO THE TOTAL AMOUNT YOU HAVE PAID KOSMOS GAMES AND/OR THE KOSMOS GAMES AFFILIATE IN THE ONE HUNDRED AND EIGHTY DAYS (180) DAYS IMMEDIATELY PRECEDING THE DATE ON WHICH YOU FIRST ASSERT ANY SUCH CLAIM.

Some states or countries do not allow the exclusion of certain warranties or the limitations/exclusions of liability described above. So these limitations/exclusions may not apply to you if you reside in one of those states or countries.

12. Indemnity

If you use or misuse the Service, or if you violate these Terms or any other applicable rules, and that results in loss or damage or in a claim or liability against Kosmos Games or any Kosmos Games Affiliate, you agree to indemnify, defend, and hold harmless Kosmos Games and/or the Kosmos Games Affiliate. You also have to cooperate in Kosmos Games and/or the Kosmos Games Affiliate’s defense of these cases. Kosmos Games and/or the Kosmos Games Affiliate will use reasonable efforts to let you know if they learn of any claim on which you have to compensate or reimburse them. This will apply even if you stop using the Services or your account is deleted.

13. Miscellaneous

If you violate these Terms of Use or if you engage in any conduct that we, at our sole discretion, believe is in violation of any applicable law or is otherwise harmful to the interests of Kosmos Games or any third party, we may issue you a warning about the violation, or we may choose to immediately terminate or suspend your access to the Services. You acknowledge that Kosmos Games is not required to provide you with a notice before terminating or suspending your access to the Services or any portion thereof, but it may choose to do so.

If your access is terminated, we may, but are not required to, remove some or all of your content from our servers. Furthermore, you understand that you shall not be entitled to any refund of fees for such termination of your access to all or part of the Services.

If any provision of these Terms of Use is held to be unlawful, void, or for any reason unenforceable, that provision shall be deemed severable from this agreement and shall not affect the validity and enforceability of the remaining provisions. These Terms of Use constitute your entire agreement with Kosmos Games with respect to their subject matter, and supersede any other previous written terms and any oral or promotional statements regarding such subject matter. Any waiver of enforcement of any provision of these Terms of Use or any breach thereof, in any one instance, shall not constitute a waiver of such term or condition or any subsequent breach thereof. If any dispute arises under these Terms of Use, the prevailing party shall be reimbursed by the other party for any and all legal fees and costs associated therewith.

These Terms shall be construed and governed by the law of Cyprus and arbitrated by the arbitration court in Stockholm.

14. Questions/contact information

If you have any questions about these Terms of Use, please feel free to contact us online using the contact information on our website or by mail at privacy@kosmos.games. Our mail address is: Kosmos Games (Cyprus) Ltd., 28 Oktovriou str. 357, Office A5, Mediterranean Court, 3107, Limassol, Cyprus.

 

PP v1

Overview

This document explains what data is collected in connection with our games and services. It also explains how we use that data, how it is collected, stored and used as well as how we protect it.

In short:

  • in order for you to play our games or use our services, we need to process some of your data (your game experience, technical and payment data)
  • we may use it to improve the user experience
  • we ask for your consent in order to process your data for personalized advertising and sending you newsletters.

This document also explains your rights in relation to your personal data.

How can you contact us?

This privacy notice aims at giving you information on how your personal data are processed by Kosmos Games (Cyprus) LTD. In this notice, we refer to ourselves as ‘we’, ‘us’, and ‘our’.

At Kosmos Games (Cyprus) LTD we handle your data so that neither we nor anyone else can use them to harm your interests and rights, such as your right to privacy.

If this Policy doesn’t contain the information you need or if you encounter issues related to your personal data, please do not hesitate to contact us.

  • The fastest way to do so is to use the in-game support menu “Help”. In the “Personal data” section you can select an item you are interested in and make a request.
  • In case you have trouble in finding this section, make a general request about the problem, and include “personal data request” in the description.

Our Support team uses Helpshift(Helpshift Privacy Policy) or Zendesk(Zendesk Privacy Policy) services to ensure that your request is promptly processed

The policy extends to:

  • Our games published in App Store, Google Play, MS Store and Amazon
  • Our games published in Our portals, solitairesocial.com, and our games published on Facebook, ok.ru, vk.com, mail.ru, fotostrana.ru
  • Our website
  • Our activities on social media

Where did we get your data from?

Directly from you

We may obtain personal data directly from you.

Advertisers and promotional partners

We receive information from our advertisers and promotional partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us.

Social media networks

If you access or log through a social media service, the information we collect may include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service.

Device Information

We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

Authentication partners

If you register for or log in to our services using third-party credentials (e.g. Facebook), we will import your information from that third party to help create your account with us.

Publishing platforms

We also receive information from the marketplaces (app stores) where our applications are published. For example, we receive information about your in-app purchases from Apple.

Analytics

We receive technical information on the performance of our apps from mobile analytics software applications. It allows us to better understand the functionality of our mobile software on your device.

 

1. Our games published in App Store, Google Play, MS Store, Amazon and Huawei AppGallery

What data, for what purposes, and based on what grounds do we process?

Purpose Legal ground Data
To create user accounts and allow you to play our games (to save your score, send you notifications related to the game, enable you with full functionality of the game, allow you to communicate with other users) Contract Platform game ID

Platform ID

Game experience (Nickname and history of its changes, Game Profile, Registration date, Consent to the ToU, Data from messages (chat), Game progress, Last Active, Status (online/offline), Last exit, Ban in the game, Logs for the previous and current game sessions, Interaction with other users, History of support requests)

Technical data (Device configuration, Device model, Operational memory device (RAM), Operating system (and its version), Language of the device, Device ID, Device token, Video card, Time zone, Battery level at the time of contact, and status (charging/not charging), Amount of free internal memory, Total internal memory capacity, Type of connection (mobile internet/wifi), Mobile operator/country code, Game version)

Payments data (History of accruals of bonuses/compensation, History of campaigns and offers that were available in the profile, Payments (In-app purchases), Date of payment, Amount of payment)

Email (when you register via Google account)

To enable in-app purchases Contract Payments data

Game experience

Platform game ID

To improve our applications and user experience by analysing users’ behavior Legitimate interest to improve our services and customer experiences Platform game ID

Game experience

Technical data

Payments data

To provide technical support to the users Contract Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To maintain the security of our applications Legitimate interest to safeguard the quality of our services Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To display advertising of our services to users based on their interests in social media, other websites, and applications Consent Platform Advertising ID

User’s email

To display advertising from our partners Legitimate interest to provide you with relevant ads in our games and to fund our services so that we can keep providing them to you Platform Advertising ID

Game experience

Technical data

To communicate our special offers, future events, promotions, or news on request via email Consent Email

Full name

 

2. Our games published on solitairesocial.com, and our games Facebook, ok.ru, vk.com and My.com, fotostrana.ru

What data, for what purposes, and based on what grounds do we process?

Purpose Legal ground Data
To create user accounts and allow you to play our games (to save your score, send you notifications related to the game, enable you with full functionality of the game, allow you to communicate with other users) Contract Platform ID

Platform Profile (First name, last name, gender, thumb_url, language, birthday, timezone, currency, friends list [in case when you connected to your social media accounts])

Game experience

Technical data

Payments data

Email

To enable in-app purchases Contract Payments data

Game experience

Platform game ID

To improve our applications and user experience by analysing users’ behavior Legitimate interest to improve our services and customer experiences Platform game ID

Game experience

Technical data

Payments data

To provide technical support to the users Contract Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To maintain the security of our applications Legitimate interest to safeguard the quality of our services Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To display advertising of our services to users based on their interests in social media, other websites, and applications Consent Platform Advertising ID

User’s email

To display advertising from our partners Legitimate interest to provide you with relevant ads in our games and to fund our services so that we can keep providing them to you Platform Advertising ID

Game experience

Technical data

To communicate our special offers, future events, promotions, or news on request via email Consent Email

Full name

 

3. Our website

What data, for what purposes, and based on what grounds do we process?

Purpose Legal ground Data
To provide technical support to the users Contract Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To answer general questions sent to our emails (privacy@kosmos.games, hr@kosmos.games, or other public e-mails) Legitimate interest to maintain and prove our relations with users Email

Additional information provided by you in the message

To consider an application for a vacancy submitted through the website Consent Potential employee’s data (Full name, Link to a social profile or portfolio, E-mail, Other information)

Potential referral’s data (Full referrer’s name, Full referral’s name, Link to a social profile or portfolio, Contact information of referral, E-mail of referrer)

To learn about our website visitors’ browsing patterns and the performance of our website. For more information on the use of cookies please refer to our Cookie Policy Consent User ID

Online behaviour

Technical data

To communicate our special offers, future events, promotions, or news on request via email Consent Email

Full name

 

4. Our activities on social media

What data, for what purposes, and based on what grounds do we process?

Purpose Legal ground Data
To conduct activities of the gaming community in social media Contract Additional information from the user
To manage relationships with members of the community, visitors of our pages in social media(to answer comments, requests) Legitimate interest to improve our services and customer experiences Social media profile

Additional information from the user

How long do we process your data?

We process your data for as long as required to satisfy the purpose for which they were collected and used, or as long as is needed for us to be able to provide the services.

When the processing of your personal data is based on your consent, we process your data until you withdraw your permission for us to process your personal details at any time.

The possible consequences of failure to provide personal data

Personal data that we process to enter into a contract are necessary to provide you with our services. So, you may face the following consequences if you choose not to give your data:

  • When the data is processed to create user accounts and allow you to play our games – you would not be able to authorise and use our application.
  • When the data is processed to enable in-app purchases – we would not be able to provide you with the paid service.
  • When the data is processed to provide technical support to the users – we would not be able to solve technical problems.
  • When the data is processed to conduct activities of the gaming community in social media you would not be able to take part in the activities.

Who do we share your personal data with?

In this section, we will provide you with information about the categories of companies to which your data is committed, as well as their data protection practices. In addition, some of the companies to which we provide data are listed as examples:

Our developers

In order to operate the services, your personal information may be transferred to other entities outside the EU. We share your personal information with the developers’ company when it is necessary to give you access to our services, provide technical support and make decisions about improving our services. Standard Contractual Clauses are used to transfer your data to ensure that they are properly protected.

Payment services

We may share payment data with banks and other entities that process payment transactions or provide other financial services and for fraud prevention and credit risk reduction.

  • Apple Pay
    The service is used when the application is installed from the App Store. The services are provided by Apple Inc. Address: One Apple Park Way, Cupertino, California, USA, 95014. Relevant privacy policy of Apple. Standard Contractual Clauses are used to transfer your data to Apple to ensure that they are properly protected.
  • Google Play In-App Payments
    The service is used when the application is installed from Google Play. The service is provided by Google LLC. Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Relevant privacy policy of Google. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link.
  • Xsolla
    The service is used for in-app purchases on solitairesocial.com is provided by Xsolla Inc., USA. Relevant privacy policy of Xsolla. Standard Contractual Clauses are used to transfer your data to Xsolla Inc.

Social media

We may share the information in your account profile with the social networking service you have linked to your account to provide you with enhanced services.

  • Facebook
    The services are provided by Meta Platforms, Inc. Address: 1601 South California Avenue, Palo Alto, CA 94304, USA. Relevant privacy policy of Facebook. Standard Contractual Clauses are used to transfer your data to Facebook to ensure that they are properly protected. For more information: click on this link.

Cloud

  • Amazon Web Services
    Our applications are hosted by aws.amazon.com. The service is provided by Amazon Web Services, Inc. Address: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA. Relevant privacy policy of Amazon Web Services. Standard Contractual Clauses are used to transfer your data to Amazon Web Services to ensure that they are properly protected. For more information: click on this link.

Analytics

We use analytics services to evaluate the usage of our applications and frequently improve it. By using generated statistics, we are able to perfect our services and make them more appealing to you as a user.

  • Appsflyer
    The service is provided by AppsFlyer Inc. Address: AppsFlyer Inc., 111 New Montgomery Street, San Francisco, California 94105, USA. Various session and interaction data are collected from you and stored for this purpose. We need this information to improve the content and usability of our games and to optimize the user experience for you. The session and interaction data are at no time processed in personalized form. For more information on data processing by AppsFlyer, please refer to the Relevant privacy policy. Standard Contractual Clauses are used to transfer your data to Apple Pay to ensure that they are properly protected.
  • Google Play Console
    The service is used only for applications installed via Google Play and provided by Google LLC. Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Relevant privacy policy of Google. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link.
  • App Annie
    The service is provided by App Annie Inc. Address: App Annie Inc, 23 Geary Street, Suite 400/800, San Francisco, CA 94108, USA. Relevant privacy policy of App Annie Inc. Standard Contractual Clauses are used to transfer your data to App Annie Inc. to ensure that they are properly protected. For more information: click on this link.

Managing support and contact requests

This type of service allows us to manage support and contact requests received via email or by other means, such as the contact form. The categories of personal data processed depend on the information provided by the user in the messages and the means used for communication.

  • Helpshift
    We work with Helpshift for customer service. Helpshift does not collect and store user data. The service is provided by Helpshift, Inc. Address: Helpshift, Inc, 1 Embarcadero Center, Suite SL12, No. 2048, San Francisco, CA 94111, USA. Relevant privacy policy of Helpshift, Inc. Standard Contractual Clauses are used to transfer your data to Helpshift, Inc. to ensure that they are properly protected.
  • Zendesk
    Zendesk is a support and contact request management service provided by Zendesk Inc. Address: 989 Market Street, San Francisco, CA 94103, USA. Relevant privacy policy of Zendesk Inc. Standard Contractual Clauses are used to transfer your data to Zendesk Inc. to ensure that they are properly protected.

Marketing analytics

We use these services to facilitate the sharing of information that may be useful, relevant, or interesting to you, such as allowing you to earn rewards for viewing in-game ads as well as to evaluate the effectiveness of our marketing campaigns. These entities may act as our data processors or, in certain cases, decide for themselves how to process your information.

  • Appsflyer
    The service is provided by AppsFlyer Inc. Address: AppsFlyer Inc., 111 New Montgomery Street, San Francisco, California 94105). Various session and interaction data are collected from you and stored for this purpose. We need this information to improve the content and usability of our games and to optimize the user experience for you. The session and interaction data are at no time processed in personalized form. For more information on data processing by AppsFlyer, please refer to the Relevant privacy policy Standard Contractual Clauses are used to transfer your data to Apple Pay to ensure that they are properly protected.

Advertising partners

We may feature advertising in our services via showing third party advertisements in our Services, as well as advertise our own services via third parties. We work with advertising partners to enable us to customize the advertising content you may receive on the service. These partners help us deliver ads and promotional messages that are more relevant to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the service.

  • Google Ads
    Google Ads (AdWords) remarketing service is provided by Google Inc.Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. For more information on data processing by Google, please, refer to the Relevant privacy policy of Google and Google’s page, explaining how Google uses data from websites or apps that use one of its platforms. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link. You can opt out of the Google Ads service by following the instructions, described by Google.

Email services

We may share your data with email services that provide us with tools to send bulk emails and implement email marketing.

  • Gmail
    The service is provided by Google LLC. Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Relevant privacy policy of Google. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link.
  • Pushwoosh
    Pushwoosh is an email marketing sending service provided by Pushwoosh, Inc. Address: 1224 M St NW, Suite 101, Washington, DC 20005, USA. For more information on data processing by Pushwoosh, please, refer to the Relevant privacy policy. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected.

Tasks and project management tools

We use tasks and project management tools that help us effectively organize work and manage projects and tasks.

Compliance with laws

We may share your personal data when we believe in good faith that it is necessary for us to do so in order to comply with a legal obligation under applicable laws.

Automated decisions

We neither use automated decision-making nor your personal data to automatically assess aspects of your personality (automated profiling).

Your rights

Any user of our services can:

  • obtain information about the processing of your personal data
  • obtain access to the personal data held about you
    Under Article 15 of the GDPR, individuals have a right of access that gives them the right to obtain a copy of their personal data, as well as other supplementary information. It helps individuals to understand how and why companies are using their data, and check the lawfulness of the processing.
  • ask for incorrect, inaccurate, or incomplete personal data to be correctedх
    Under Article 16 of the GDPR, individuals have the right to have inaccurate personal data rectified. An individual may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing.
  • request that personal data be erased when they are no longer needed or if processing is unlawful
    Under Article 17 of the GDPR, individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.
  • request the restriction of the processing of your personal data in specific cases
    Article 18 of the GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data. This is an alternative to requesting the erasure of their data.
  • receive your personal data in a machine-readable format and send them to another controller (‘data portability’)
    Under Article 20 of the GDPR, individuals have the right to data portability that gives individuals the right to receive personal data they have provided to a controller in a structured, commonly used and machine readable format. It also gives them the right to request that a controller transmits those data directly to another controller.
  • вobject to the processing of your personal data for marketing purposes or on grounds relating to your particular situation
    Article 21 of the GDPR gives individuals the right to object to the processing of their personal data at any time. This effectively allows individuals to stop or prevent you from processing their personal data.
  • withdraw your consent at any time
  • lodge a complaint with a supervisory authority
    In accordance with Article 77 of the GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

Exercise your rights

You can send a request to retrieve, delete or change data as follows:

  • The fastest way to do so is to use the in-game support menu “Help”. In the “Personal data” section you can select an item you are interested in and make a request. In case you have trouble in finding this section, make a general request about the problem, and include “personal data request” in the description. Our Support team uses Helpshift (Helpshift Privacy Policy) or Zendesk (Zendesk Privacy Policy) services to ensure that your request is promptly processed.
  • The other way to send a general request about the problem, and include “personal data request” in the description and send it on our e-mail privacy@kosmos.games

How we can delete your data

We can delete your data in several cases:

  • Whenever data is no longer necessary to provide an app experience or service to users (if the user has not accessed the profile for more than 3 years, we assume that the data is no longer needed and delete it)
  • When requested by a user (you can learn more about it in the section “Exercise your rights”),
  • When a user deletes their account associated with your app,
  • When it is requested by platform where our app is published,
  • When required by law or regulation.

You can send a request to delete data as follows:

  • The fastest way to do so is to use the in-game support menu “Help”. In the “Personal data” section you can select an item you are interested in and make a request. In case you have trouble in finding this section, make a general request about the problem, and include “personal data request” in the description. Our Support team uses Helpshift (Helpshift Privacy Policy) or Zendesk (Zendesk Privacy Policy) services to ensure that your request is promptly processed
  • The other way to send a general request about the problem, and include “personal data request” in the description and send it on our e-mail privacy@kosmos.games

Children

We recognize that we have a special obligation to protect children’s data. We will not knowingly collect or process children’s data without parental consent. By providing consent to this Policy, the User certifies that he or she is of sufficient age to give such consent. If you are a parent or guardian and you believe that we have collected your child’s data in violation of the law, contact us at privacy@kosmos.games. We will delete this data in accordance with applicable law.

COOKIE FILES

We, our marketing partners, analytics service providers use cookies (text files placed on your computer to analyze your use of our Products) and similar technologies (such as pixels, tags and device identifiers) to recognize you and/or your devices and our products and to enhance the products, marketing, analytics or website features we offer. The use of cookies is standard on the Internet.

How to delete cookies and opt out of targeted advertising and analytics

You can configure your browser settings to refuse cookies or to notify you when a cookie is sent. You may refuse the use of cookies by adjusting the appropriate settings on your browser. However, please note that this may limit your access to the full functionality of our website and portal supercitygame.com and solitairesocial.com.

  • If you wish to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out choice will take effect.
  • For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).
  • For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies (e.g. for Chrome), and by visiting the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.

Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

Privacy Policy in Other Languages

This Policy was originally written in English and may be translated to other languages. In the event of an inconsistency, the English version has the precedence.

Contact us

For official requests, please use email – privacy@kosmos.games.

Company name: Kosmos Games (Cyprus) Ltd

Address: 28 Oktovriou str. 367, Office A5, Mediterranean Court, 3107, Limassol, Cyprus