Privacy Policy

Privacy Policy of Chinazes OÜ Last updated: June 21, 2025 1. GENERAL PROVISIONS 1.1. This Privacy Policy (hereinafter referred to as the “Policy”) outlines how Chinazes OÜ (hereinafter referred to as “Chinazes OÜ,” “we,” “us”) collects, uses, stores, and protects the personal data of users (hereinafter referred to as the “User,” “you”) in the course of providing our gaming applications, company website, and related services. 1.2. This Policy applies to all Chinazes OÜ products, including but not limited to: games, the chinazes.games website, store pages, and third-party services that use our game or reference this Policy. 1.3. By using our Services, you agree to the terms of this Policy and provide informed consent to the processing of your personal data to the extent necessary to deliver the services described in this document, including explicit consent where required by law (e.g., Canada), such as when installing or logging into the game. If you do not agree with it, please do not use our products or websites. 2. PERSONAL DATA WE COLLECT 2.1. We may collect the following data: - Name, email, phone number, user identifiers from third-party services (e.g., Google Play, App Store, Steam, etc.); - Information about your device: IP address, operating system, device type, language, country, unique ID; - Usage data: in-game actions, in-app purchases, analytics, action logs; - Geolocation (if permitted); - Profiles created when logging in through social networks; - Payment data related to transactions via Google Play / App Store (e.g., purchase ID, payment status); - Feedback, messages, and support requests. 3. PURPOSES AND LEGAL BASES FOR DATA PROCESSING 3.1. We process your personal data for the following purposes: - To provide and improve our products and services; - To support users and handle inquiries; - To verify identity and protect against fraud, including verifying user authenticity upon login, identifying and blocking suspicious activity, preventing automated or fraudulent behavior (e.g., bots, in-game abuse, transaction manipulation), and ensuring the security of accounts and in-game assets; - Analytics, statistics, testing, and research; - Sending notifications and updates (where consent is given); - Legal compliance and contract enforcement. 3.2. Legal grounds for processing: - Your consent (Art. 6(1)(a) GDPR); - Contract performance (Art. 6(1)(b) GDPR); - Legal obligation (Art. 6(1)(c)); - Legitimate interests pursued by Chinazes OÜ (Art. 6(1)(f)). 4. COOKIES AND OTHER TECHNOLOGIES 4.1. We use cookies, SDKs, and similar technologies for: - Enabling service functionality; - Personalizing content; - Analytics and statistics; - Security and fraud prevention. 4.2. Our website does not use its own cookies. However, when following external links (e.g., to Google Play or App Store), third-party platforms may use their own cookies. We recommend reviewing their respective privacy policies. 4.3. We use Google Analytics and other tools for analytics and diagnostics, which may transmit information to third-party servers located in the USA, EU countries, or other regions where applicable data protection laws are observed. When entering Asian markets, including China, we adhere to local requirements, including potential restrictions on cross-border data transfers and data localization obligations. 5. USER RIGHTS 5.1. You have the following rights with regard to the personal data actually held by Chinazes OÜ: - The right to request access to the personal data we process (e.g., device ID, in-game activity, technical logs); - The right to correct technically accessible data if it contains errors or inaccuracies; - The right to request deletion of data held by Chinazes OÜ if it is no longer necessary or infringes your rights; - The right to restrict processing or object to it — within the scope of data available to Chinazes OÜ; - The right to withdraw previously given consent, where applicable; - The right to lodge a complaint with the relevant data protection authority in your jurisdiction. 6. CHILDREN 6.1. Our Services are intended for a general audience and not directed at children under 13 years of age (or other minimum age as defined by your country’s laws). 6.2. We do not knowingly collect personal data from underage users. If you believe a child has provided us with information, please contact us and we will delete such data. 7. SHARING INFORMATION WITH THIRD PARTIES We do not sell your personal data to third parties. Data is only shared in accordance with this Privacy Policy and for the purposes described herein. 7.1. We may share data with: - Analytics partners (e.g., Google, Firebase); - Hosting providers (e.g., AWS, Google Cloud); - Marketing partners (with the user’s consent expressed when accepting this Privacy Policy); - User support platforms (e.g., customer service systems, in-app chat tools, ticket handling platforms like Zendesk, Helpshift, Intercom); - Government authorities on lawful grounds. 7.2. In the event of a sale, merger, or reorganization, data may be transferred to a legal successor. 7.3. We expect all partners to adhere to security standards and data processing practices in accordance with applicable laws and Chinazes OÜ’s guidelines. However, we are not responsible for the actions of partners, including their own compliance with data protection laws, and recommend they independently ensure compliance. 8. DATA STORAGE AND SECURITY 8.1. Data is stored on secure servers located in the EU, USA, and — if required to comply with local laws — in other jurisdictions such as Asian countries. We use trusted hosting platforms (e.g., AWS, Google Cloud) and apply appropriate technical and legal data protection measures. 8.2. Data retention is limited to the purposes for which it was collected. Once that period ends, data is deleted or anonymized. 8.3. We take reasonable measures within our technical and organizational capabilities to protect personal data in our possession from unauthorized access, loss, or alteration. We use secure servers and communication protocols. However, we are not liable for the actions of third-party service providers (e.g., hosting platforms), including potential outages, breaches, or incidents occurring outside our direct control. 9. DATA BREACHES 9.1. In the event of a data breach on our side (e.g., compromise of internal systems or unauthorized access to our services), we will notify the supervisory authorities and affected users within 72 hours, as required by the GDPR. We are not responsible for breaches or security incidents occurring on the side of third-party service providers (including hosting platforms, marketplaces, or analytics services) if such incidents occur beyond our control and where we have taken reasonable protective measures. 10. JURISDICTION AND GOVERNING LAW 10.1. The primary matters concerning data protection and terms of use shall be governed by the laws of Estonia and the European Union (including the General Data Protection Regulation — GDPR). 10.2. In certain cases, and where not prohibited by applicable law, disputes may be resolved in other jurisdictions by mutual written agreement of the parties. 11. CONTACT INFORMATION Email for inquiries and requests: info@chinazes.games Data Protection Officer (DPO): Jelena Kolajevs Supervisory authority in Estonia: https://www.aki.ee/ 12. POLICY CHANGES 12.1. We may update this Policy. All changes become effective upon publication on the website or in the application. We will notify users if changes are material. © Chinazes OÜ, 2025