Axlebolt LTD

Privacy Policy

Last Updated: 16 September 2021

Welcome! This Privacy Policy explains how Axlebolt Ltd. (“Axlebolt” or “we”), collects, uses, and shares your personal data while you play Axlebolt’s games (“Games”).

We may make changes to this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you via a notice in the Games prior to the change becoming effective.

1. What kind of personal data does Axlebolt collect?

When you play the Games, Axlebolt acts as the controller of your personal data.

We aim to minimize how much personal data we collect from users when they play the Games. Most of our data collection is limited to the following types of data, which do not identify you personally but may uniquely identify the device you are using to play the Games (“Device”). In some countries, this type of data may be considered as personal data:

• “Advertising ID”, which means the resettable and unique identifier associated with your mobile phone or tablet that is used by advertisers for ad tracking.
• “Location Information”, which means general information about the location from which you’re playing the Games without information about exact geolocation (e.g. IP address, country, and city).
• “Device Information”, which means technical information about your device. When we refer to device Information, this means your device ID, your internet service provider (ISP), your browser and browser plug-in types, operating system and operating system version, jailbreak information, network information, the brand and manufacturer of your device, the language you’ve set for your device, the version of the Game installed on your device, and the name of your carrier.
• “User’s ID”, which means a unique number (code) automatically generated and assigned to your account to identify your account in the Game.
• “User’s Name”, which means a set of characters and/or numbers not already used by another player in our Games, which you can change in your account independently. It is not obligatory to change User’s Name and it does not have to be your real name.
• “User’s Avatar”, which means a picture or a photo which you can but not obliged to upload to your account in place of the default avatar.
• “Voice Data”, which means recordings of the voice while using voice chat.

Personal Data	Legal Basis for Collection	Purpose(s)
When You Play the Games
Advertising IDs, Location Information, and Device Information	Performance of the License Agreement which you conclude with Axlebolt by playing the Games	Analytics – for more information, please see Section 3.
Advertising IDs, Location Information, and Device Information	Your consent which you express by playing the Games and our legitimate interest for direct marketing	Advertising – for more information, please see Section 4.
Device Information	Our legitimate interest in preventing cheating in the Games	Preventing cheating in the Games
Voice Data	Your consent which you express by playing the Games and our legitimate interest in preventing cheating in the Games as well as complying with certain legal requirements	Voice chat function availability
User’s ID, User’s Name, User’s Avatar	Your consent which you express by playing the Games. User’s Name and User’s Avatar are processed only if you decide to provide them voluntarily	Identification and personalization of your account
When You Contact Customer Support
Name and email address, Location Information, Device Information, User’s ID, User’s Name, User’s Avatar	Your consent which you express by filling in the contact form	You have the option to contact our customer support team directly from some of our Games or using our social networks and email. When you do, we will collect and use this information to respond to your requests and/or comments.

Does Axlebolt collect my financial information when I make in-app purchases?

When you make in-app purchases in the Games, we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. Apple’s App Store, Android’s Google Play or Huawei’s App Gallery) or your platform’s payment processor.

2. How long will Axlebolt keep my personal data?

We will keep your personal information as long as you play the Games. After you stop playing the Games, we store your personal information for no longer than 3 years or for the period that is necessary to comply with the legal requirements under applicable law.  

We will keep your personal information for 3 years after you stop playing the Games in order to preserve your in-game progress and in-game purchases in case you decide to resume playing our Games. However, if you wish to delete your account and personal information completely, we will erase it immediately at your request. To request it, you can contact us at privacy@axlebolt.com.

Please note, that once personal information is erased upon your request or 3 years period from your last gaming session expires, your account will be deleted, and your progress and purchases will be lost.

Please note that we do not store your Location Information. Your Location Information is processed once upon the start of playing the Games to identify your region but is not stored by us.

3. How is my personal data used for analytics?

As a game developer, it is important for us to know how users interact with our Games. We and our partners (“Analytics Service Providers”) will collect your Location Information, Device Information, and Advertising IDs so that we can deliver our game services to our users, measure, analyze, and improve performance of the Games, and to continually update and develop our Games.

For example, we will use this information to assess the difficulty level of Games, fix any bugs or errors in the Games, evaluate the demographics of our users, and to determine whether or not we need to support a new Device type for the Games. A list of our Analytics Service Providers could be found here: www.axlebolt.com/partners.

4. How is my personal data used for advertising?

To help us keep our Games running, we show ads in our Games with the help of third-party advertising partners (“Ad Partners”). We integrate Ad Partners’ technologies into our Games which are then used by the Ad Partners to determine what kind of ads to display to you.

i. Do Ad Partners collect my personal data?

In order to show you ads that might be interesting and/or relevant to you (“Targeted Ads”), Ad Partners collect and use your Advertising ID, Location Information, and Device Information. If location services are enabled in your Device settings, the Ad Partners may additionally collect your geolocation information. Because these Ad Partners’ technologies control what kind of personal information is collected from your Device and how it is used, we encourage you to review their respective privacy policies. A list of our Ad Partners could be found here: www.axlebolt.com/partners.

ii. How to opt-out of receiving Targeted Ads.

If you do not want to receive Targeted Ads on your mobile Device, you have an option to opt-out of receiving Targeted Ads when we first ask your permission on showing you such ads. Apart from this, your mobile Device may give you the option to opt-out of receiving Targeted Ads on all apps on your Device. In addition, you may be able to opt-out of receiving Targeted Ads from a specific Ad Partner. Please review our Ad Partner list found here to see if an Ad Partner offers the ability to opt-out of receiving Targeted Ads.

In any event, you can contact us at [email protected] and inform us about your wish to opt-out of receiving Targeted Ads. We will share this information with our Ad Partners.

Please note that if you opt-out of receiving Targeted Ads, you will still receive contextual ads, which are non-targeted ads related to the content of the Game you are playing.

5. How is Voice Data used?

Participating in voice chat in our Games means your voice logs are subject to recording and processing. Axlebolt has no plans to record player voice chat or expand the voice comms capabilities beyond the voice chat.

Axlebolt itself will not store voice chat recordings but will attract Vivox as a partner for integrating this technology. Vivox as a processor will store and process your Voice Data as well as will implement appropriate technical and organizational measures to ensure a level of security of your Voice Data (for more information please see our list of partners - www.axlebolt.com/partners).

Voice recordings will be used to take action against players who use voice comms to harass, use hate speech, or otherwise disrupt gaming experience.

If you prefer to not have your voice chat captured, you may turn off voice chat.

6. How are User’s Name and User’s Avatar used?

Our Games do not require you to share your name or avatar. In order to minimize personal information we process, we assign a User’s ID to your account. However, if you wish to personalize your account, you have an option to provide us with a User’s Name of your choosing and which is not already used in our Games by another player. You also can but not obliged to upload a User’s Avatar to your account. If you do that, we will process you User’s Name and User’s Avatar, though you can delete or change them at any moment.

7. Children’s personal data.

Our Games are rated as having content suitable for those aged 17 years and older. Thus, we do not knowingly collect children’s personal information.

If you are a parent of a child under 17 years old playing the Games, you may review or have your child’s personal information deleted and refuse the further collection of his/her personal information by contacting us at [email protected]. Please contact us at [email protected] if you believe we are collecting a child’s personal information and we will delete this information as quickly as possible.

If your child contacts our customer support, we will delete their email address immediately after responding to their request if we become aware of the fact that your child is under 17 years old.

8. Third-parties and their privacy policies.

Throughout the Games, you may see links to third-party websites or applications (e.g., in ads which are shown in the Games). Please be aware that if you follow the links to third-party websites or applications, you might share your personal data with such websites or applications. Axlebolt does not control collection of personal data by third-party websites or applications and we encourage you to read their privacy policies.

9. Is my personal information secure?

The security of your personal information is important to us. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our partners stake appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. For Axlebolt, this includes, but is not limited to, ensuring that all of your information is disclosed only on a “need to know” basis and ensuring that all information collected by Axlebolt is done so via secured connections and protected and encrypted by industrial grade security software to guard against unauthorized access.

10. Social media features and tools.

The Games may include integrated social media features and tools, such as the Facebook “Like” button, the YouTube “Share This” button, and the Twitter “Follow” button. These features may collect information on your IP address. Social media features and tools are hosted by a third-party, and your interactions with these integrated social media features and tools are governed by the privacy policy of the company providing it.

11. Sharing your personal information for business/legal reasons.

A. Business Transfers. As we continue to develop our business, we may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third-parties. In any of these types of transactions, any information you provide may be one of the transferred business assets (subject to any pre-existing privacy notice unless you consent otherwise). In the event that all or substantially all of our assets are acquired or we merge with a third-party, your information will likely be one of the transferred assets. You understand and agree that we reserve the right to transfer any information collected from you in the case of any such transfer. In such event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.

B. Legal. We may disclose information you provide to respond to subpoenas, court orders, requests from authorities, and other legal process, and to establish/exercise our legal rights. We may also disclose your information to defend against legal claims when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We may share your information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, violations of our License Agreement, or as otherwise required by law.

12. Is my personal data sold to any third parties?

No, Axlebolt does not sell personal data of the users of the Games to any third parties and has never tried to sell any personal data.

13. How do I access, manage, or update my personal information?

Please contact us at [email protected].

14. For users in the European Union.

A. Legal Basis for Processing. Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information.

Typically, we will rely on the following legal basis for processing your personal information: (i) where our processing is necessary to perform a contract with you (e.g. to make the Games accessible to you in accordance with the our License Agreement); (ii) your consent which you express by agreeing to play the Games; or (iii) where our processing is in our legitimate interest (e.g. processing for direct marketing or preventing cheating in the Games). For more information, see Section 1 of this Privacy Policy.

If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at [email protected].

B. Your Personal Data Rights.

You as the data subject have the following rights relating to the processing of your personal data:

(1) Right of access (right to obtain from Axlebolt confirmation as to whether your personal data are being processed and other information concerning your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of your personal data, the period of personal data storage, the existence of automated decision-making, including profiling, in respect of your personal data);

(2) Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal data of data subjects);

(3) Right to rectification (right to the rectification of inaccurate personal data concerning you);

(4) Right to erasure (right to obtain the erasure of personal data concerning you);

(5) Right to restriction of processing (right to obtain from Axlebolt the restriction of processing on the legal grounds provided in Art.18 GDPR (for example, when the accuracy of the personal data is contested by you or we no longer needs the personal data for the purposes of the processing));

(6) Right to data portability (the right to receive the personal data concerning you, which You has provided to Axlebolt, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from Axlebolt to which the personal data have been provided);

(7) Right to object (right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including the right to object at any time to processing of personal data concerning you for marketing purposes);

(8) Right not to be subject to a decision based solely on automated processing, including profiling;

(9) Right to file the request or complaint to Axlebolt regarding your personal data processing.

(10)Right to withdraw your consent for personal data processing.

If you would like to exercise any of your rights, please contact us at [email protected].

C. Transfer of Personal Data Outside of the EU. Because some of our Analytics Service Providers and Ad Partners are located in countries outside of the European Union, your personal information will be transferred to other countries, e.g. the United States of America, that may not offer the same level of data protection as the laws of your country of residence.

While we and our partners take all the reasonable and necessary measures aimed at protection of your personal data against unauthorized access by third parties, we shall inform you about the possible risks of such storage of your personal data in jurisdictions outside European Union under Art.49(1)(a) of the GDPR. Such possible risks include:

(1) Obtaining access to your personal data by state organs of the United States of America or other special governmental services, including police. However, such access can only be obtained by these services in accordance with the applicable law of that country and if there are legal grounds for obtaining the access.

(2) Efforts of hacking attacks. Axlebolt takes all the necessary measures to prevent such attacks and do not allow hackers to access your personal data.

(3) Storage of personal data in the jurisdictions to which Axlebolt has no access (the United States of America). However, partners of Axlebolt that store your personal data in such jurisdictions use all the necessary security mechanisms for protecting your personal data.

(4) Existence of different rules and regulations on personal data processing in such jurisdictions that are different from the GDPR. However, Axlebolt and its partners provide personal data subjects with the level of guarantees granted to personal data subjects by the GDPR.

By agreeing to the processing of your personal data in accordance with this Privacy Policy and by playing the Games, you provide us with the explicit consent to transfer your personal data to the United States of America despite all the possible risks of such transfer. 

D. How to File Complaints. If you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence. For contact information for your supervisory authority, please visit here.

15. Axlebolt’s contact information.

Axlebolt Ltd.

Registration No.: HE 409660

Registered address: Christodoulou Chatzipavlou, 221, Helios Court, Flat 401, 3036, Limassol, Cyprus

If you have any questions about our Privacy Policy or about our use of your personal information, please contact us at [email protected].