Privacy Policy

Publication Date: 19 June 2018

Privacy Policy (hereinafter referred to as the "Policy") applies to information that either allows or does not allow the user to be identified (including personal data) in the applicable law (hereinafter referred to as "Personal Information"), which Travel And Play, LLC (hereinafter referred to as "Our Company") can receive about you when you use any programs and / or websites of Our Company (hereinafter referred to as the "Products"), as well as when Our Company performs the agreements and contracts signed by you, needed to use Our Products.  

You provide our Company with your Personal Data and give a full and unconditional consent for its processing, including cross-border transfer, solely under the following privacy policy.

We can also transfer and receive your Personal Data from our partners (hereinafter referred to as "Partners"), programs, websites, products or services which are used (for example, from our advertisers). The transfer of Personal Data is possible only in cases established by the applicable law, and is carried out by virtue of the contracts between us and each of the Partners.

1. Personal Data processing
The responsibility for all the activities related to the processing of Personal Data during the use of the company Products is held by Travel And Play, LLC, a legal entity created under the laws of the Russian Federation and registered at Novosibirsk, 630090, Inzhenernaya St. 4A, office 729, Russian Federation 
For Product users who are located in European economic area or in Switzerland our legal representative is the Akadem GmbH company, a legal entity created under the laws of Austria and registered at Bauernmarkt, 2, 1010, Vienna.

2. Purpose of the Policy
The protection of your Personal Data and your Privacy is extremely important for Our Company. Therefore, when you use the Products of Our Company, we protect and process the Personal Data received from you in strict compliance with applicable laws.

3. The List of collecting Personal Data
The Personal Data collected during the Products usage may differ depending on which Product of Our Company you use, and whether you use your account to access the Products or not (in cases when authorisation is provided).

We do not check the Personal Data provided by you and do not know its reliability. We also do not know if you have sufficient legal capacity to provide us with your Personal Data. Nevertheless, Our Company assumes that you provide reliable and sufficient Personal Data, you have the right to provide it yourself or, if necessary, you have obtained the consent of your legal representative, and you update your information when needed.

Our Company, depending on the Product, can collect the following categories of Personal Data about you:
(a) Personal Data provided by you yourself when using the Products: your surname, first name, patronymic, phone number, country of residence, address, age, expenses and revenues data, account balance, e-mail, Skype number;
(b) electronic data (IP address, cookies, browser ID information, hardware and software information, Product version, mobile operator name);
(c) the date and time of access to the Products (including the time zone);
(d) information on your activity during the use of the Products;
(e) information on geolocation;
(f) other information about you, as well as the Products used by you, necessary for processing in accordance with the conditions governing the use of specific Products of Our Company;
(g) the information about you that we receive from our Partners in accordance with the terms of agreements between you and our Partners and / or agreements between Us and our Partners.
Our Company purposefully does not collect such Personal Data as race origins, political views, health information and biometric data, unless you yourself, in any way, indicate it in our Products.
Our Company does not collect Personal Data to the extent it can materially affect your rights and freedoms.
We also use cookie files to collect Personal Data and associate such information with your device and web browser. Our Products use cookie files, which makes our services more efficient, safe and convenient for the user. Most of the websites and applications use cookie files to improve their functionality. These files allow the Product to "remember" the user during the current visit or subsequent visits. The cookie files are used for a variety of purposes: for example, they allow to save the search settings, help you register in our services or are used to select the targeted advertisement.
The user can restrict or prohibit the use of cookie files using the settings of his browser. The cookie files we store on the user's hardware neither harm nor contain viruses.

4. Legal basis and purposes of Personal Data processing
Our Company does not have the right to process your Personal Data without sufficient legal grounds. In this regard, we process your Personal Data only in the following cases:
(a) when processing is necessary to fulfil our company's contractual obligations to you, including ensuring the operation of the Products;
(b) when processing is necessary to comply with the obligations established by law;
(c) when (provided by the applicable law) the processing is necessary to ensure the legitimate interests of our company in case if such processing does not have a significant impact on your interests, rights and freedoms.
(d) improving, changing, personalising, or otherwise enhancing the Products for the benefit of all users, understanding how you interact with them;
(e) offering you other products of our company or of other companies which, in our opinion, may be interesting to you (i.e. showing you advertising that takes into account your interests);
(e) for specific purposes, we may request your special consent to the processing of your Personal Information.
(g) giving you access to the Products;
(h) providing access to your account (when it's needed for the Product usage);
(i) contacting you to provide you with notifications, requests and information related to the operation of the Products, the implementation of agreements with you and the processing of your requests and applications;
(j) facilitating the Products usage;
(k) creating new Products;
(m) protecting your rights and rights of Our Company;
(n) collecting, processing and presenting statistics and other studies.
Attention. If you refuse to grant us the right to process personal data, we will not be able to guarantee the full functionality of some of our Products.

5. Protection of Personal Data
Our company takes appropriate organisational and technical measures to protect personal information from unauthorised or accidental access to it, modification, loss or destruction. We constantly update the security measures, guided by the latest technological developments, as well as by applicable law.

6. Third party access to Personal Data
Our Company can also transfer Personal Data to third parties, in order to implement the aims and objectives specified in this Policy. Such third parties may include:   

(a) partners, such as website and application owners, advertising networks and other partners who provide us with services related to the placement and display of advertising on websites, programs, products or services owned or controlled by such partners;
(b) advertisers or other Partners who display advertisements for you in Our Company’s Products, as well as such Partners as information or analytical service providers or consultants. 
(c) third parties for whom has been made an assignment of rights or obligations under the relevant agreement; 
(d) any national and/or international regulator, law enforcement agencies, central or local executive authorities, other official or government authorities or courts which Our Company should provide with information according to the applicable law;
(e) third parties, if you have agreed to the transfer of your Personal Data or the transfer of Personal Information is required to provide you with the relevant Product or to perform a specific agreement or contract entered into with you;
f) any third party in order to provide legal protection to Our Company or third parties if you violate the User Agreement of Our Company services, this Policy or the terms governing the use of certain Services, or in situations with such a violation.

7. Personal Data Storage
Our Company has taken measures to transfer and store your personal data according to the applicable law and the rules of personal data protection.

8. The Personal Data storage period
Our Company will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer needed.

9. Your rights
You have the right to access your Personal Data which is processed by Our Company according to this Policy, if it is provided by the applicable law.
If you admit that any information we store about you is incorrect or incomplete, you can correct and/or supplement your Personal Data (if it is provided by the Product) or contact us and request correction.
In addition, you have the right to:
(a) require the partial or complete removal of your Personal Data; 
(b) require restrictions on your Personal Data processing; 
(c) take exception against your Personal Data processing.
Our company will comply with these requests under the applicable law.
In cases provided by applicable law, you can also have other rights, not specified above.
Please note that most of the Personal Data about you that we hold can identify only a particular browser or device and cannot identify you. You will need to provide us with additional information so that we can identify your personal data that we hold, and to implement your request.
To exercise the rights above, please contact Our Company (see clause 11).

10. Updating this Policy
Our Company has the right to make changes to this Policy at its discretion. Therefore, we recommend you to periodically review this Policy.

11. Feedback
If you have any questions regarding the protection of your personal information or about this Policy, please contact us using our support e-mail:
support@travelandplay.mobi - for applications downloaded from Apple App Store
developer@travelandplay.mobi - for applications downloaded from Google Play

You also can use our support e-mail to send requests on your personal data correction or complaints connected with illegality of its processing.

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