Last Updated: 20 September 2022

PRIVACY POLICY

Greetings! This is a Privacy Policy – the document that explains how The Artstorm FZE, (“Artstorm”, Company”, “We”) processes Your (“User”, “You”) Personal data when You engage in our Games.

The Privacy Policy applies to all the Games developed and/or published by Us. Please be aware that the Store from where You can install our Game may have different rules for personal data processing. The Store is solely responsible for Your data processing when You use it.

Please check this page regularly, as We will publish the latest version of the Policy here https://artstorm.com/en-US/privacypolicy.html. Amendments will be effective from the moment of publication.

ABOUT US:

Name: Artstorm FZE;

Address: Umm Al Quwain, One UAQ Building, 3rd floor, office 320, U.A.E.;

Contact email: info@artstorm.com.

— For the purposes of European data protection laws (GDPR), we are the data controller;
— For the purposes of CPPA, we are the data controller.
— For the purposes of The UAE Federal Decree-Law No.45 of 2021, we are the data controller.

At Artstorm the privacy and security of our Users are of paramount importance. Artstorm is committed to protecting the data you share with Us.

BASIC DEFINITIONS:

We do not intend to bother or bore You with the terminology, but We need to clarify some of it:

“CCPA” means California Consumer Privacy Act;
“Game” means all published mobile games and mobile games under development the design, creation, development, modification, publishing and distribution of which was organised and provided by Artstorm FZE and to which Artstorm FZE have all exclusive right, including, but not limited to “Modern Warships”;
“GDPR” means Regulation 2016/679 of the European Parliament and of the Council;
“In-game ID”, which means a unique number (code) automatically generated and assigned to your account to identify your account in the Game;
“Personal data” means any information relating to an identified or identifiable natural person;
“Store” means an online store, platform or web-site through which the Game can be provided to You, namely: Google Play; App Store; AppGallery; https://artstorm.com/;
“Terms of Use agreement” means an agreement between Artstorm and a User, on the basis of which User is granted access to our Games and other services. The agreement is posted here: https://artstorm.com/en-US/useragreement.html.

WHAT DATA WE COLLECT AND WHY:

We collect only the necessary categories of Your Personal data in order to meet the specified above purposes:

Categories of Personal data	Purpose of processing	Basis of processing
Emails (and Name if shown or provided when received an email); In-game ID.	Providing You with access to Games (creating and sustaining of User’s account); Ability to save Game progress; Provision of User tech support.	Agreement (Terms of Use)
In-game User behaviour.	Statistics analysis of the use of Our services; Ability to amend and improve the Games and users’ experience within them.	Legitimate interest
In-game User behaviour; In-game ID.	Providing You with personalized ads.	Consent

PLEASE NOTE: We do not collect any of Your Personal data but mentioned above. That includes any information that You can provide or can be gathered by the third-parties for marketing and advertising services (please see the list of such parties below) as well as any financial information about in-Game purchases that You make. That Personal data is processed by the relevant third party that is responsible for the processing and security of the data.

PLEASE NOTE: We do not collect any sensitive data about you such as information about your race or ethnicity, religious beliefs and sexual orientation; information about your health, including any medical condition, or information about criminal convictions and offenses.

HOW LONG WILL WE SECURELY KEEP YOUR DATA:

We intend to limit the period of data processing to the necessary minimum and not to store them for longer than is reasonably necessary.

We may process it only while the User participates in Games, as well as for three years from the date of the last gaming session and activity in each Game. This is necessary to ensure the ability to restore Game progress and analyse the use of the Games.

If applicable data protection or other legislation prescribes storage of Personal data for a longer or shorter period of time, We will store Personal data for a period in accordance with these legal requirements.

You can always request to delete all or any part of Your Personal data. To do so, please contact us at info@artstorm.com.

PLEASE NOTE: All Your Personal data is stored securely and is accessed by authorized personnel only. Artstorm implements and maintains appropriate technical, security and organizational 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 Games.

PLEASE NOTE: We keep all Your Personal data in a combined virtual storage with the storages that provided by Google Cloud Platform with the access to corporate Google Drive and Google Firebase, by Amazon with the access to Amazon Web Services as well as by Microsoft with the access to Microsoft PlayFab.

CAN A THIRD-PARTY PROCESS YOUR DATA:

Yes. It is important for Us to cooperate with some of the third-parties for Analytics (marketing/purchases), Advertising and Personal data storage purposes as well as to provide You with the most comfortable ways of registration in Our Games:

(1) Analytics:

As Our primary goal is create an engaging and fun experience for a User we need to understand users’ behavior and their interaction with the Games. To do so We use the several services, namely:

AppsFlyer on the basis of the respective Data Processing Agreement. Please read AppsFlyer’ Services Privacy Policy here: https://www.appsflyer.com/legal/services-privacy-policy/ and Data Processing Agreement – here: https://www.appsflyer.com/legal/dpa/;

Google Firebase on the basis of the respective Data Processing Agreement. Please read Firebase’ Data Processing and Security Terms here: https://firebase.google.com/terms/data-processing-terms;

Xsolla on the basis of the respective Data Processing Agreement.

PLEASE NOTE: Xsolla is a payment service provider that processes all of Your Personal data related to in-Game purchases. Artstorm do not collect or store any of such financial data.

Please read Xsolla’ Privacy Policy here: https://xsolla.com/privacypolicy.

(2) Advertising:

We may show ads in our Games with the help of third-party advertising services that are named below. We may as well request such third-parties to show You ads on their own platforms and other sources based on Your Personal data. These companies may access Your Personal data and operate under their own privacy policies.

PLEASE NOTE: in order to show you ads that might be more relevant to you (personalized ads) via third-parties services We need Your explicit consent to use some of Your Personal data, namely in-game behaviour and in-game ID.

By expressing Your consent in the forms presented in our Games, or by registering and using Our Games You or Your representative accept the Policy and provide Us with the consent to show You personalized ads via ad providers (third-party services) that are listed below.

To accept the Privacy Policy and provide Us with Your consent, you must reach the age of sufficient legal capacity under applicable legislation (the laws of the country of your residence). If You reside in the EU and are under 16 y.o. or under the age of sufficient legal capacity in accordance with the legislation of Your residence, please ask Your parent or guardian to read and accept this Privacy Policy.

If You want to opt-out of receiving personalized ads, please contact us at info@artstorm.com

Please be aware that while using our Games, Users can follow links to other sites and/or software applications that are beyond our sphere of influence. Artstorm is not responsible for the content or privacy policy of these other sites and/or software applications.

List of ad providers (third-parties services):

AppsFlyer with integrated Facebook, Twitter, IronSource. Please read again AppsFlyer’ Services Privacy Policy here: https://www.appsflyer.com/legal/services-privacy-policy/ and Data Processing Agreement – here: https://www.appsflyer.com/legal/dpa/

Google AdMob (includes advertising partners of Google AdMob) on the basis of the respective Data Processing Agreement. Please read the privacy information here: https://www.termsfeed.com/blog/privacy-policy-admob/ and here: https://support.google.com/admob/answer/6128543?hl=en.

Google Firebase – please read again Firebase’ Data Processing and Security Terms here: https://firebase.google.com/terms/data-processing-terms.

TikTok on the basis of the respective Data Processing Agreement. Please read the privacy information here: https://www.tiktok.com/legal/page/row/privacy-policy/en and here: https://www.tiktok.com/legal/tiktok-data-sharing-agreement;

Unity on the basis of the respective Data Processing Agreement. Please read the privacy information here: https://unity3d.com/legal/privacy-policy

(3) Data storage:

To ensure that we keep Your data protected and in order to be able to use it with high efficiency We as well use the third-party services that are listed below. Such companies can process Your Personal data under the respective agreement with Us:

Amazon Web Services – please read the privacy information here: https://aws.amazon.com/privacy/;

Google Cloud Platform (with the access to Google Drive and Google Firebase). Please read the privacy information here: https://policies.google.com/privacy;

Microsoft PlayFab – please read the privacy information here: https://privacy.microsoft.com/en-us/privacystatement.

(4) Ways of registration in Games:

As part of improvement of the Game experience We added the opportunity to register in Games not only via email, but by authorization through Facebook, Apple, Google and Huawei accounts.

PLEASE NOTE: should You choose to register via the authorization We do not collect any of Your Personal data. Any of the data as well is processing only by the relevant processor (Facebook – Meta Inc., Apple Inc., Google LLC, Huawei Technologies Co., Ltd). We encourage You to read their privacy policies:

Apple – please read the privacy information here: https://www.apple.com/legal/privacy/en-ww/;

Facebook – please read the privacy information here: https://www.facebook.com/policy.php;

Google – please read the privacy information here: https://policies.google.com/privacy.

Huawei – please read the privacy information here: https://www.huawei.com/en/privacy-policy.

YOUR DATA SUBJECT RIGHTS:

You have the right to information about what Personal data We process, how and on what basis as set out in this policy, to be notified about data breach as well as other rights granted by the applicable legislation, including GDPR:

Right of access	You have the right to obtain confirmation whether your Personal data is being processed and how (you can request a copy of the Personal data undergoing processing).
Right to rectification	You have the right to correct any inaccuracies in your Personal data at any time. To do so, please contact Us at info@artstorm.com and we will correct it without undue delay.
Right to erasure	You have the right to request the erasure of your Personal data should the data no longer be necessary in relation to the purposes for which it was collected, should you withdraw your consent or due to other legal requirements. To do so, please contact Us at info@artstorm.com and we will erase it without undue delay.
Right to restriction of processing	You have the right to request the restriction of processing your Personal data in order to verify its accuracy, when you oppose the erasure of the Personal data, when it is required for your participation in legal claims or for other purposes provided to you by applicable law.
Right to data portability	You have the right to receive your Personal data in commonly used and machine-readable format as well as to transmit it to another controller without any fee.
Right to object	You have the right to object to Personal data processing where we are relying on a legitimate interest to do so. We will continue to process it only after We will demonstrate compelling legitimate grounds to do it. You also have the right to object if We process your Personal data for the purposes of direct marketing
Right to withdraw consent	You have the absolute and unrestricted right to withdraw your consent at any time. If you wish to withdraw your consent once it is given, you should contact Us at info@artstorm.com.
Right not to be subject to a decision based solely on automated processing, including profiling

FOR EU USERS:

We may transfer personal data relating to You outside of the EEA, since We may store Your personal data as well as transfer it to third-party services located outside of the EEA (some of our engaging third-parties, including Analytics service providers and Ads providers, are located in countries outside of the European Union), which may not offer the same level of data protection as the laws and regulations which apply to You. Please see the list of specified countries below.

We undertake to store Your personal data only in those jurisdictions that use the necessary security mechanisms to protect Your personal data, including various data encryption methods. With each of the third party, We accept obligations under the standard contractual clauses adopted by the EU Commission with provision of the assessment regarding the level of protection of Your data when applicable.

Country	Existence or absence of an adequacy decision by the Commission	Applied appropriate or suitable safeguards
China	Absence	Standard contractual clauses adopted by the EU Commission with provision of the assessment of the level protection regarding Personal Data
Israel	Existence	Data transfer to this country is expressly permitted by The European Commission.
Singapore	Absence	Standard contractual clauses and assessment
The United Arabic Emirates
The United States of America

FOR CALIFORNIA (US) USERS:

Please note that We as well committed to using Your Personal data as permitted by the CCPA. According to the document You have the following rights among others:

Right to know	You have a right to request disclosure of Your Personal data. To exercise this right, please contact Us at info@artstorm.com.
Right to delete	You have a right to request deletion of Your personal data. To exercise this right, please contact Us at info@artstorm.com.
The right to non-discrimination for exercising their CCPA rights	Artstorm respects every User and encourages You to exercise any of Your granted rights. We warrant that in doing so You will not face any discrimination on Our behalf. To exercise any of the rights, please please contact Us at info@artstorm.com.

PLEASE NOTE: We do not sale Your data to anyone. Nevertheless, You have the right to opt-out under the CCPA that You as well may exercise by contacting Us at info@artstorm.com and to check or request to stop selling Your data.