© 2024 All Rights Reserved.
MADE BY UNDERSTANDLast updated: July 22nd, 2024
1.1. https://artik.agency (the “Website”) and Services (as defined below) are provided by YESWORKS OU, located at Nurme 16, 11616 Tallinn, Estonia (“Company”, “we”, “our” or “us”) and our subsidiaries.
1.2. This Privacy Policy shall be read alongside, and in addition to, our End User Licence Agreement accessible online at https://artik.agency/eula (the “EULA”) and our Cookie Policy accessible online at https://artik.agency/cookie (the “Cookie Policy”).
1.3. This Privacy Policy sets out how we collect and use your personal information when you (i) use the services offered by the Company and its subsidiaries by visiting our website; (ii) use games and the Website as defined in the Terms; and (iii) registering an account, if any, (an “Account”) and use the mobile, online, and downloadable products, including, games and services (the “Services”) offered by the Company and its subsidiaries on the Website and the choices available to you in connection with our use of your personal information (the “Privacy Policy”).
1.4. It is reminded that information collected via the Services offered by the Company and its subsidiaries is used by the Company, responsible for its processing.
1.5. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
1.6. Please note that if you use other products and services that the Company suggests on the Website, or such products and services are provided by or together with third parties, you may be required to register “extra” accounts, and in that case additional privacy policies shall be applied and accepted by you.
2.1. By making the Services available, we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register an Account, and use the Services;
(b) provide true information about yourself to the extent necessary for the use of the Services;
(c) understand that, by posting your personal information, if there is such a technical possibility in the Services, and where it is accessible by other users of the Services, you have manifestly made this information public, and this information may become available to other Website users and Internet users, be copied, and be disseminated by them;
(d) understand that some types of information transferred by you to other Service users cannot be deleted by you or by us;
(e) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such a check is necessary in order for us to fulfill our obligations to you.
3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop, and implement new features of our Services, and enhance the functionality of the available Services. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed
analyses of this data, to our affiliates and partners as set out in the table below and in section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our games, why we collect and process it, and the legal basis below.
3.3. General clauses, which shall apply to your use of the Website and the Services related to the Company:
3.3.1. Data you provide for registering in the Services, including your e-mail and/or other identifiers available. We use this information to manage and administer the Services provided to you, fulfill our obligations to you, and provide you with updates and information on our and selected third parties’ products and services.
3.3.2. Additional data you provide when you create or edit your Account, including your first name and surname, nickname, gender, date of birth, avatar picture, and language preferences. We use this information to provide our Services to you, verify your Account, and provide updates and information on our and selected third parties’ products and services. We also use this information to tailor and improve advertisements.
3.3.3. Additional data received when you access the Services, including information regarding technical devices, IP address, device IDs, and other technical information. We use this data to constantly improve the content of our Services, optimize your user experience, and personalize the use of our Services. We also use this information to tailor and improve advertisements.
3.3.4. Information that is automatically received at the time of access to the Services with the use of cookies. We use this information to tailor and improve advertisements.
3.3.5. Information created by you while using the Services, including information posted in any in-game chats. This information can be available to other users of our Services. We use this information to manage and administer the Services.
3.3.6. Information obtained as a result of your behavioral actions when using Services and payment features. We use this information to manage and administer the Services and to tailor and improve advertisements.
3.3.7. Information created, posted, sent, or otherwise made available by you while placing requests to our Service Support. We use this information to verify your identity, fulfill your support request, investigate complaints, and provide efficient service.
3.3.8. Data collected via third parties, including your social network IDs, application store IDs, and friends list. We use this information to manage and administer the Services provided to you, show your friends who play the same game, and provide updates and information on our and selected third parties’ products and services.
3.3.9. Information received as a result of your behavioral actions when using the Services, including game actions and achievements. This information may be available to other users of our Services. We use this information to manage and administer the Services and to tailor and improve advertisements.
3.3.10. Information received about you as a result of other users’ actions on the Services. We use this information to manage and administer the Services, verify your identity, fulfill your support request, investigate complaints, and provide efficient service.
3.3.11. Data obtained via third parties, including your social network IDs, application store IDs, social network nickname, and friends list. We use this information to manage and administer the Services provided to you, show your friends who play the same game, post your achievements into your social account, and retain data about your usage of our Services across different mobile devices.
3.3.12. Information received as a result of your use of the payment functionality of the Services. We use this information to manage and administer the Services, investigate complaints, and provide efficient service.
3.4. We may also undertake certain actions to prevent fraudulent activity in our Services, improve our Services and provide you with better user experience, such as automatic collection and processing of screenshots of your screen during the time when the game is launched and the game's window is not minimized to ensure users’ compliance with the Terms of Use of the relevant Service. Please be aware that such collection and processing of the screenshots complies at any time with this Privacy Policy and no decisions are based solely on automated processing.
3.5. Our legitimate interests include (1) maintaining and administering the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your Account is adequately protected; and (6) complying with any contractual, legal, or regulatory obligations under any applicable law.
3.6. As part of maintaining and administering the Services, we use the information to analyse user activity and to ensure that the rules and Terms of Use of the Services are not violated.
3.7. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body, or agency, or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
3.8. In case you provided us with a consent to the sending of marketing information, you may withdraw your consent to the sending of marketing information to you by amending your privacy settings in your Account. An option to unsubscribe will also be included in every SMS or e-mail sent to you by us or our selected third party partners.
3.9. Please note, that if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and/or your sexual orientation), you have to take care not to post this information or share this data on the Website and/or Services. Once you have provided this data, it will be accessible by other Website users and it becomes difficult for us to remove this data.
3.10. Please note, that if you withdraw your consent to data processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages of the Website.
3.11. If we intend to further process your data for any other purpose besides those set out in this Privacy Policy, we shall provide you with details of these purposes before we commence data processing.
4.1. Publicly available data. Your username and other information that you provide or post while using the Services can be available to all users of the Services. We take technical and organisational measures to ensure that your data is safe. Please note, that by posting your personal information in publicly accessible areas (resources accessible by other users of the Services), you have manifestly made this information public, and it may become available to other users of the Services and Internet users and be copied and/ or disseminated by such users. Please keep in mind that once other users have gained access to or copied your data, neither you nor we are able to delete or remove such data from possession of those other users.
4.2. Sharing with third parties. We may share your personal information with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to affiliated entities, as well as our partners, in order to provide you with the Services offered by the Company and its subsidiaries, to administer the Services, for example, if you choose to share your data across other social media platforms, to administer the billing services or to personalize, adjust and improve our Services or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal information to third parties.
The transmissions of personal data with the recipients (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure manner and in application of an agreement between us and each recipient as may be necessary under applicable law. We undertake to ensure that each recipient knows the directive principles of personal data protection and submit to them in application of the law and/or of a particular contract.
4.3. Confidentiality obligations. In case we share your data with selected third parties, including our third party contractors and application developers, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use the services or applications they offer. The developers use the information provided to them in order to provide you with additional services, including technical support, if applicable. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.
4.4. Advertising disclaimer. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender, location (country, city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.
4.5. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.
4.6. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, we may also disclose your personal information to a third party if we decide to transfer a business to that third party, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to our successor or assignee.
4.7. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities in case it is necessary because of your participation in public tournaments. We may also publish your data as part of the tournament score tables on our and third party websites.
4.8. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defense of our rights and interests. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.
5.1. The Services may contain links to Websites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services, and you shall ensure that you review the relevant third party’s privacy statement, which will govern your data privacy rights.
5.2. We bear no liability for the actions of third parties, which, as the result of your use of the Internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.
5.3. We bear no liability for the consequences of the use of the information that, due to the nature of the Services, is available to any Internet user. We ask you to take a responsible approach to the scope of the information posted on the Website.
6.1. We may transfer and maintain some of your personal information on our servers or databases outside the European Economic Area (EEA).
6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7.2. You are entitled to withdraw your consent to process your personal data under this Privacy Policy at any time by removing the data from your Account or alternatively by deleting your Account through your
Account settings and following the instructions provided by the Company after your sending such a deletion request.
7.3. You may request to remove your Account and data on our Services by contacting the Service Support (see section 11 for details). Please note that such withdrawal does not have any impact on the validity of the consent before withdrawal, and we reserve the right to process your personal data on another lawful basis if permitted by applicable law.
Please also note that uninstalling our game (or any application related to our Services) from your device does not automatically result in consent withdrawal or any deleting your personal data from our servers.
7.4. We may remove your Account or the information you post, as provided by the Terms.
8.1. You have the following rights, in certain circumstances, in relation to your personal information:
8.1.1. Right to access your personal information.
8.1.2. Right to rectify your personal information: you can request that we update, block, or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for the purpose of processing.
8.1.3. Right to restrict the use of your personal information.
8.1.4. Right to request that your personal information is erased if:
8.1.4.1. it is no longer required in relation to the purposes for which it was gathered or processed in another way;
8.1.4.2. you withdraw your consent concerning processing subject to consent;8.1.4.3. you are justifiably opposed to the processing;
8.1.4.4. it has been subject to illicit processing; or
8.1.4.5. it is imposed by law.
8.1.5. Right to object to processing of your personal information.
8.1.6. Right to data portability (in certain specific circumstances).
8.1.7. Right not to be subject to an automated decision.
8.1.8. Right to lodge a complaint with a supervisory authority.
8.1.9. For processing based upon your consent, the right to withdraw that consent at any time.
8.1.10. You may have other rights under your legislation of your country of residence, including the right to define the instructions relative to the outcome of your personal data after your death.
8.2. You also have the right to independently remove personal information on your Account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.
8.3. If you would like to exercise these rights, please contact us via mail or e-mail. We will aim to respond to you within 30 days from the date of receipt of your request, unless another, shorter term, is prescribed by applicable laws. We will need to verify your identity before we are able to disclose any personal data to you.
9.1. We take technical, organisational, and legal measures, including, where suitable, encryption, to ensure that your personal data is protected from unauthorised or accidental access, deletion, modification, blocking, copying, and dissemination.
9.2. Access to the Services is authorised using your login and password. You are responsible for keeping this information confidential. You shall not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
9.3. If you forget your login details, you can request us to send you verification information as agreed by the Terms.
9.4. To reduce the probability of third parties gaining unauthorized access, if you login to your Account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your Account. You will then need to contact Service Support and provide certain additional information to verify your credentials and gain access to your Account.
10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to them.
11.1. If you have any questions, please send your inquiries to Service Support at corporate@artik-media.com or send your request to us in writing to Nurme 16, 11616 Tallinn, Estonia. Please quote this Privacy Policy so we can deal with your enquiry efficiently. We will aim to respond to you within 30 days from receipt of your request, unless another, shorter term, is prescribed by applicable laws.
11.2. All correspondence received by us from you (written or electronic enquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for responding to the enquiry, except as expressly provided by law.
11.3. The e-mail address of our DPO is corporate@artik-media.com