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PRIVACY POLICY

THIS TEXT IS OF AN URGENT IMPORTANCE, READ IT CAREFULLY PRIOR USING THE SOFTWARE. YOU ARE FREE TO DECLINE THIS PRIVACY POLICY AND IF YOU DO SO, PLEASE, DO NOT USE THE SOFTWARE AS IT OTHERWISE WOULD MEAN THAT YOU ARE CONSENT TO THIS PRIVACY POLICY. WE MAY ASK YOUR EXPLICIT CONSENT FOR PROCESSING YOUR PERSONAL DATA IF IT IS NECESSARY IN YOUR DATA REGION, BUT MAKE SURE THAT YOU FULLY UNDERSTAND WHICH DATA WE PROCESS.

Privacy Policy
1. Introduction
    1.1. Cube Software Individual (private) entrepreneur Petrov Sergiy Vladimirovich, (“Cube Software”, “IP Petrov”, “We”) provides software applications, games and websites (Products). At Cube Software the privacy and security of our Users are of paramount importance. Cube Software is committed to protecting the data you share with us. This privacy policy explains how Cube Software processes information that can be used to indirectly identify an individual (“Personal Data”) collected through use of its Products.

    1.2. For the purposes of this policy, Cube Software defines the term “User” as an entity with which Cube Software has an established relationship, the term “Customer” as any User who makes purchases within our Products.

    1.3. Any information stored on Cube Software’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Cube Software implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. We encrypt that information using secure socket layer technology (SSL), and NaCl encryption to protect your stored data and data within our Products.

    1.4. We are a small company with less than five people work together, so please be patient if we do not respond immediately, your request may take some time up to 30 days before we may answer. We will try to do our best to provide you with a quality service.

2. Collection and use
    2.1. WHY DO WE COLLECT YOUR DATA
To make the Service work.
To perform the contract, we process data necessary to
    ● Create accounts and allow you to play our games and use our Service
    ● Operate the Service
    ● Verify and confirm payments
    ● Provide and deliver products and services you request
    ● Send you Service-related communications
To make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
    ● Update and develop player profiles
    ● Develop and improve the Service and player experience
    ● Manage our relationship with you
    ● Provide social features as part of the Service
    ● Customize your Service experience
    ● Respond to your comments and questions and provide player support
    ● Provide you Cube Software offers in the Service as well as in other websites and services, and by email
    ● Send you related information, such as updates, security alerts, and support messages
    ● Enable you to communicate with other players
To show personalized advertisements.
To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to
    ● Track the content you access in connection with the Service and your online behavior
    ● Deliver, target and improve our advertising and the Service
For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.
To keep the Service safe and fair.
Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the Cube Software Terms of Service.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
    ● Analyze and monitor use of the Service and its social features
    ● Moderate chats either automatically or manually
    ● Take action against fraudulent or misbehaving players
To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.

    2.2. PERSONALLY IDENTIFIABLE INFORMATION (PII)
        2.2.1. Cube Software collects personally identifiable information (“PII”) when you choose to provide it to us. PII is any information that specifically identifies or locates a particular person or entity. We receive and store any PII you provide to us. The types of PII collected may include your name, postal address, telephone number, and email address. For example, you may choose to send PII about yourself in an email, by completing an online form on the Websites, or by signing up for our service or e-newsletter. You may also provide us with PII in order to setup an account with us. Cube Software uses this information for our reasonable business purposes, including to contact you to respond to your inquiry, to provide the service requested. We may share Client PII with partners as necessary to improve the Service. Once obtained, Cube Software will store your PII for as long as needed to provide services and for a reasonable time thereafter for record keeping purposes.

        2.2.2. Cube Software may collect, record and analyze information of Users to its Products. We may record your IP address. Cube Software may add information collected by way of pageview activity. Furthermore, Cube Software may collect and process any Personal Data that you volunteer to us in our Products’s forms, such as when you sign up for information and newsletters. If you provide Cube Software with your social media details, Cube Software may retrieve publicly available information about you from social media. Such Personal Data may comprise your IP address, Geolocation data (based on your IP address), your email address, interest in Cube Software products, as well as information as to the type of relationship that exists between Cube Software and yourself.

        2.2.3. We DO NOT collect information about: age, gender, political thoughts, religious beliefs, phone number etc.

        2.2.4. We do not direct ours websites, games, or applications to children (usually considered to be under the age of 13, depending on the country where you reside). As we don’t process or operate information about age of users we may not been able to prevent processing of the other data, which may belong to person under the legal age. We also do not intentionally collect personal information about age through our websites, games, or applications. If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us and we will delete the information from our records.

    2.3. NON-PERSONALLY IDENTIFIABLE INFORMATION
        2.3.1. Cube Software also collects non-personally identifiable information (“Non-PII”) from our Products. Non-PII is pseudonymous information that cannot by itself be used to specifically identify a particular person or entity, and may include your purchases, numbers of Users, completed tasks or quests, your in-product achievement, ranking score, length of time spent using Products, actions performed within our Products, statistics, smartphone type and model, usage habits, the time/date of your visit to the Products and your device’s operating system and its version. We may use a third-party analytics provider to help us collect and manage this data. We use this information to help manage and improve the Products.

        2.3.2. By using our software, you consent to the collection and use of your non-personally identifiable information.

        2.3.3. If you don’t want us to keep and process such information, please contact us directly to delete your account and all the data we collected about you. You may not use our products after that.

    2.4. Behavioral Targeting / Re-Targeting:
        2.4.1. We partner with third parties to display advertising on our Sites and manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools (to learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org or if you are located in the European Union you may use the resources at http://www.youronlinechoices.eu/. If you access the Optimizely Service or Sites on your mobile device, you may not be able to control tracking technologies through the settings. Please contact or consult the respective privacy policies of such ad servers or ad networks for more information.

    2.5. Purpose of processing PII
        2.5.1. Cube Software uses the collected data to communicate with Users, to customize content for Users, to show ads on other Products to Users, to make special offers for specific Users based on performed actions of such Users, and to improve its Products by analyzing how Users navigate our Products.

    2.6. Sharing PII

    2.7. WHO CAN SEE YOUR DATA
        2.7.1. Apart from Us, your data can be accessed by others in the following situations:
        2.7.1.1. OTHER PLAYERS AND USERS.
        2.7.1.2. Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

    2.8. PARTNERS
        2.8.1. Cube has partners to perform services for us. These partners process your data only at and according to Cube´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
    2.9. Other companies and public authorities.

        2.9.1. In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

        2.9.2. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

    2.10. Advertising and Social Media partners.
        2.10.1. The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

        2.10.2. Cube Software may also share such information with third-parties in order to provide a requested service or transaction or in order to analyze the User behavior on its Products.

        2.10.3. We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Cube Software or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

    2.11. Ads
        2.11.1. Please be aware that while using our Products, Users can follow links to other sites and/or software applications that are beyond our sphere of influence. Cube Software is not responsible for the content or privacy policy of these other sites and/or software applications. For information on how our selected third parties may use your information, please see their privacy policies.
            2.11.1.1. Unity
            2.11.1.2. Ironsource
            2.11.1.3. Chartboost
            2.11.1.4. Applovin
            2.11.1.5. Google
            2.11.1.6. Facebook
            2.11.1.7. Adcolony
            2.12. Collection of User data

        2.12.1. During a User’s registration, you provide information such as an Identification Data (ID) collected from the service provider, such as Google Play or App Store and other platforms where our Products are located. This information is used by Cube Software to identify the User and provide them with support, services, mailings, sales and marketing actions and to meet User License agreement obligations.

        2.12.2. Please, pay attention, you cannot use our Products without having an authorised account in Google Play, App Store or any other platforms where our Products are located.

        2.12.3. Cube Software Users can at any time reach us out to with a request to edit, delete and update personal data. Cube Software. Cube Software will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

    2.13. Products Users
        2.13.1. If you are a user of our Products, then this section is relevant for you. By using our software, you consent to the collection and use of your PII as described herein. If required by applicable law, we will seek your explicit consent to process PII collected on this Products or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your PII, the use of the Products may be subject to restrictions.

3. What Happens In The Event Of A Change Of Control
    3.1. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Optimizely Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4. Geographical location
    4.1. Cube Software offers a number of data regions. A Cube Software “Data Region” is a set of data centers located within a defined geographical area where User data is stored. Personal Data is not transmitted between Data Regions. For Cube Software Users with accounts located in Cube Software’s European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in Data center in Canada. For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.

5. Processing and collection
    5.1. Processing in the European Economic Area (EEA)
        5.1.1. For Users with accounts located in Cube Software’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Cube Software’s processing will take place in accordance with the GDPR.

    5.2. Controller
        5.2.1. Cube Software processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR: The Cube Software entity which you as a User entered an agreement with when using Cube Software’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section. Cube Software adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, Cube Software processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by Cube Software Users through Products will be stored exclusively in secure hosting facilities provided by OVH, . Cube Software has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

        5.2.2. Processing in the United States Of America (US): For Users in the l US Data Region, Cube Software processes data solely in data centers located in Canada. Cube Software has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in Cube Software’s possession. Cube Software will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

        5.2.3. Processing in Canada: For Users with accounts in the Cube Software Canada Data Region, Cube Software processes data solely in data centers located in Canada. Cube Software has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in Cube Software’s possession. Cube Software will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

        5.2.4. Processing in other regions: For Users with accounts in our Asian Pacific Data Region, Cube Software processes data solely in data centers located in Singapore. Cube Software has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in Cube Software’s possession. Cube Software will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

6. Retention and deletion
    6.1. Cube Software will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Respondent data, Cube Software’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Respondent data, Users with an active account will therefore have the responsibility to delete data when required. When a user’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.

7. Acceptance of these Conditions
    7.1. We assume that all Users of our Products have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our Products and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of Cube Software Products and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

8. DPO and complaints
    8.1. Cube Software’s Data Protection Officer: Cube Software has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:
● Cube Software
● Attn: Data Protection Officer
● Optikov street. Home 52. Room 169
● Saint-Petersburg
● Russia
● dpo@cubesoftwaregames.com

9. For Further Information
If you have any further questions regarding the data Cube Software collects, or how we use it, then please feel free to contact us by email at: dpo@cubesoftwaregames.com, or in writing at: address - Optikov street. Home 52. Room 169. Saint-Petersburg, Russia.

Contacts:
support@cubesoftwaregames.com
info@cubesoftwaregames.com

© Copyright 2019 Cube Software - All Rights Reserved