Effective Date: January 25, 2025
“Polyglotiki Studio” (“Studio”) is designed to protect the privacy rights of our users (“Users” or “You”). This privacy and cookie policy (the “Policy”) has been created to inform you about the ways in which we collect, store, use and manage the information you provide in connection with your use of any Studio website (collectively, the “Sites”) or any Studio game or application (the site, games and applications, collectively, the “Services”).
Please note that the scope of this Policy is limited to information collected by Studio using the Services. This policy does not apply to the practices of third parties that Studio does not own and/or control. Studio also offers its Services to Users residing in the EU. Studio is the data controller for personal information (also “personal data”) collected from these Users. Users who reside in the EU may direct questions related to how we collect, store, use and disclose their personal information either to Studio at the address below or to our representative at the following address: 198260, St. Petersburg, st. Stoikosti, 18, bldg. 2, apt. 129.
By using our Services, you are asked to agree to this Policy and the processing of your data, including your personal information (personal data) in the manner specified in this Policy. Therefore, we process your personal information based on your consent. In any case, any use of the Services will be interpreted as your agreement with this Policy. If you do not agree to these terms, do not use the Services.
This policy simply informs you about how the Studio collects, stores, uses and discloses your personal information. We do not ask you to agree to this Policy. If We require your consent, We will ask for it in the form of separate notices and consent forms. Please note that if you provide us with consent, you may withdraw that consent at any time by contacting us at app@poliglotiki.ru.
You are advised to check this Policy regularly as it may be amended from time to time as set out below.
1.1. The purpose of this Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.
1.2. Activities related to the collection, storage, distribution and protection of User information are regulated by this Policy, other official documents of the Studio and applicable law. We strive to minimize the amount of personal information that We collect from Users when they use the Services.
1.3. The current version of the Policy, which is a publicly available document, was developed by the Studio and is available to any Internet user at: https://www.poliglotiki.ru/privacy.html.
2.1. The processing of personal data is based on the following principles:
2.2. Collection of personal data. The User's personal data is transferred to the Studio with the consent of the User.
2.3. Storage and use of personal data. The Users' personal data is stored exclusively on electronic media and processed using automated systems. How long we store your personal information will depend on the purpose for which we originally collected the personal information. We will not store personal information longer than is necessary for our business or for legal requirements.
2.4. Transfer of personal data. The Users' personal data is not transferred to third parties, except in cases expressly stated in this Policy. The provision of Users' personal data at the request of state (local) authorities is carried out in the manner prescribed by law.
2.5. When you make purchases in games, applications (Paid Services), we do not collect or have access to your name and payment information. This information is collected and stored by your platform (such as the Applestore or Google Play) or your platform's payment processor.
3.1. Please note that third party partners/vendors, such as analytics companies, may also use cookies or other technologies, and these partners are subject to their own policies.
3.2. We use mobile analytics software to better understand the functionality of our Services on your device. This software may record information such as how often you use the game (app), events that occur in the game (app), performance data, and where the game (app) was downloaded from. We do not link the information we store in the analytics software to any personal information you submit in the game (app).
3.3. Our Services may contain third party tracking tools from our partners. Such third parties may use cookies, APIs, and SDKs within our Services to enable them to collect and analyze User information on our behalf. Third parties may have access to information such as your device identifier, MAC address, geo-location information, and IP address for the purpose of providing their services in accordance with their privacy policies. This policy does not cover the use of third-party tracking tools. We do not have access to or control over these third parties. The third parties we use for analytics are listed below:
4.1. The Studio processes the Users' personal data to fulfill the Studio's obligations to the Users regarding the use of the Services.
4.2. The Studio may use the User's personal information for the following purposes:
5.1. We collect and process Users' personal information under the following conditions:
| Personal information | Purpose(s) | Who |
|---|---|---|
|
— email address; — additional information provided by the User at the Studio's request, to fulfill the Studio's obligations to Users regarding the use of the Services. In particular, the Studio has the right to request from the User a copy of an identity document or any other document containing the User's first name, last name and photograph, as well as any additional information that, at the discretion of the Studio, is necessary and sufficient to identify the User |
Marketing and Communications, Legal Compliance | Studio |
| IP address | Provision and improvement, Research and analytics | Studio, Yandex.Metriсa, Google Analytics |
| Information about your age | Research and analytics | Google Analytics, Yandex.Metriсa, AdMob, Fabric, Firebase |
| Location information, which means general information about the location from which you use the Services (such as country and city) | Provision and improvement, Research and analytics | Google Analytics, Yandex.Metriсa, AdMob, Fabric, Firebase |
| Device information, which means technical information about your device. When We refer to device information, this means your device identifier, operating system version, jailbreak information, network information, your device brand and manufacturer, the language you have set for your device, the version of the application installed on your device, and your operator name. | Provision and improvement | Google Analytics, Yandex.Metriсa, AdMob, Fabric, Firebase |
| Information received as a result of other Users' actions through games, applications (e.g. purchase/subscription, errors) | Provision and improvement | Google Analytics, Yandex.Metriсa, Fabric, Firebase |
| Android Advertising ID | Advertising placement and analysis indicators | AdMob |
| User Interests | Research and Analytics | AdMob, Firebase |
| Cookie | Provision and Improvement, Research and Analytics | Google Analytics, Yandex.Metriсa |
6.1. The Studio takes your privacy seriously and operates transparently. In this sense, by providing sufficient identification (to protect the privacy of others), you can request information from us about the personal data we hold about you, and you can correct any inaccurate data we hold.
6.2. In certain territories (including the EU), you also have the legal right to request a restriction of processing, to object to processing, and the right to data portability. However, these rights are subject to certain conditions and do not always apply.
6.3. You have the right to withdraw your consent on the basis of which We process your personal information at any time, however, this does not affect our lawful processing based on your consent before that withdrawal.
6.4. Push notification
We may occasionally send you push notifications through our games, applications to send you game updates, application updates, high scores and other notifications related to the Services that may be important to you. You can opt out of receiving these types of communications at any time by disabling them at the device level through your settings.
6.5. For users in the European Union.
If you wish to exercise any of these rights, please contact us at: app@poliglotiki.ru.
7.1. The Studio takes technical, organizational and legal measures to protect Users' personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other illegal actions.
7.2. We have implemented commercially reasonable technical, physical, managerial and organizational measures aimed at protecting your personal information from accidental loss and from unauthorized access, use, modification or disclosure. However, We cannot absolutely guarantee that unauthorized third parties will never be able to use, disclose or modify your personal information for improper purposes.
7.3. In the event that personal information has been compromised as a result of a security breach, the Studio will promptly notify those individuals whose personal information has been compromised in accordance with the notification procedures set forth in this Policy.
7.4. 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 we receive it. 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 third party services put in place appropriate security measures to protect against unauthorized access or disclosure of the information We have collected.
We do not knowingly collect children's personal information without parental consent, except as permitted by applicable laws, such as the Children's Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, Studio and its suppliers/partners may collect personal information strictly to support Studio's internal operations and/or legitimate interests, such as analytics. If you are a parent of a child who uses the Site or application (Services), you may review or delete your child's personal information and opt-out of further collection of their personal information by contacting us at app@poliglotiki.ru. Please contact us if you believe that we are collecting a child's personal information in violation of COPPA or GDPR.
9.1. Users have the right to send their requests to the Studio, including requests for the use of their personal data in writing: 198260, St. Petersburg, Stoikosti St., 18, bldg. 2, apt. 129, or in the form of an electronic document containing a qualified electronic signature in accordance with the legislation of the Russian Federation, to our email address app@poliglotiki.ru.
9.2. The Studio must review and respond to the User's request within 30 (thirty) days from the date of receipt of the request. This period may be extended for another two months, when necessary, taking into account the complexity and number of requests.
9.3. All correspondence received by the Studio from Users (requests in writing or submitted electronically) is considered restricted information and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the request may not be used without the explicit consent of the User in any way other than to respond to the problem described in the received request, or in cases expressly provided for by law.
This policy does not apply to the actions and Internet resources of third parties. The Studio is not responsible for the actions of third parties who, as a result of using the Services, have access to information about the User, which, by the nature of the Services, is available to any Internet User. The Studio recommends that Users take a responsible approach to the amount of information they provide about themselves.