Confidentiality Policy

This Confidentiality Policy (hereinafter, the Policy) contains the rules governing the use of

User personal information by tltGames.

Game—Galaxy Clicker, a mobile game developed by tltGames that is only lawfully available from App Store or Google Play. The Game is a piece of application software that comprises data, algorithms, and audio and video generated based thereupon for the User to obtain a certain outcome envisage by the Game script.User (Player)—an individual using the Game for personal, non-commercial purposes.

tltGames—Limited Liability Company TLT GAMES, INN (Individual Taxpayer No.) 6321417703, registered under the law of the Russian Federation at: Russian Federation, Samara Region, City of Togliatti.

1. General Provisions

1.1. By playing the Game you, of your own free will and in your own best interests, consent in writing to the following types of processing your Personal Information may be subject to: collection, recording, organization, storage, specification (updates, amendments), retrieval, use, transfer (distribution, submission, access), depersonalization, blocking, archival or deletion for the purposes set forth herein, using any, all or no means of automation, as tltGames, in its sole discretion may see fit.

1.2. The terms used in this Policy shall be construed in accordance with, first, the law of the Russian Federation, second, international legal acts and, third, customary business use or scientific doctrine.

2. Personal Information

2.1. In this Policy, Personal Information is understood as set forth below:

2.1.1. Information about self the User voluntarily provides when playing the Game, including said User's personal information;

2.1.2. User's depersonalized data transmitted automatically based on software settings.

2.2. tltGames shall have the discretion to determine what kind of Personal Information Users are to provide to be able to play the Game, including but not limited to email address, information about the mobile device used (model, type and operating system version), screenshots of the Game profile, in-game purchase data (date, description/goods purchased, transaction identifier). Users, at their own discretion, may choose to also provide other information that has not been identified by tltGames as mandatory.

2.3. Public Information Users may, at their own discretion, provide any other additional information about themselves for the purpose of communicating with other players, such as first and last name, gender, date of birth, city they live in or any other information in the format of their own choosing. By disclosing this information in the Game chat room, the User makes it available to an unlimited number of persons, i.e. makes it public.

2.4. tltGames does not verify Personal Information it receives for accuracy, nor checks if the User reporting same is in possession of any consents that may be required for processing same in accordance with this Policy. It is presumed that Users act reasonably and in good faith, comply with applicable law, take any measures necessary to keep all the information up-to-date and possess any and all consents necessary from the owners of any personal information.

2.5. Users acknowledge and consent to the use in the Game of third party statistics and analysis software (such as GameAnalytics, Google AdSense and AdMob) that may enable such third parties to transmit and receive depersonalized information described in para 2.1.2 herein.

Such third party software [information] may include:

  • browser information (type, version, cookies);

  • operating system information (type, version, screen resolution);

  • request information (time, click-through source, IP address).

The composition and scope of depersonalized data collected by third party software is determined by the owners of copyright to said software.

2.6. tltGames shall not be liable for the use of any Personal Information by any third parties the User may interact with when playing the Game.

3. Reasons for Processing Personal Information

3.1. tltGames will process only that Personal Information, which is needed for achieving the goals set.

3.2. tltGames may only use Personal Information for the following purposes:

3.2.1. Granting the User access to the Game and ascertaining proper Game functionality;

3.2.2. Identifying Users in the Game;

3.2.3. Providing technical and other support for playing the Game. Users shall communicate with the technical support service via the Internet using specific software (the Game's pages on Google Play, AppStore, Facebook, Vkontakte) and/or electronic mail;

3.2.4. Keeping in Contact with the User to improve information services and Game performance. Contact with the User will be maintained as set forth in para 3.2.5 herein;

3.2.5. Conducting marketing research, statistical analysis and other studies using depersonalized data.

Data collected by the systems indicated in para 2.5 herein is depersonalized and used to determine how much time Users spend playing the Game and what their interests and preferences may be.

4. Personal Information Security Requirements

4.1. tltGames shall store and secure Personal Information against unauthorized access and sharing in accordance with its internal rules and regulations and subject to the requirements of applicable law. Personal Information is processed at the tltGames office.

4.2. Personal Information shall be kept confidential, except for its public component, if any, as per para 2.4 herein, or where User-selected software settings allow for open sharing of information with other Game Players or any other Internet Users.

4.3. tltGames may only share Personal Information with third parties under the following circumstances:

4.3.1. Where the User has given his or her consent for same, including where User-selected software settings do not limit sharing of certain information;

4.3.2. Where such sharing may be necessary for the User to be able to use Game functionality or where the Game's specific features require same;

4.3.3. Due to the Game being transferred to a third party to possess, use or own;

4.3.4. If ordered by a court or another authorized government body, as set forth in the law;

4.3.5. To protect tltGames' rights and lawful interests.

4.4. Personal Information shall be processed and stored for as long as it may be needed for the purposes for which it had been collected.



5. Changes in Personal Information

5.1. The User may exercise his or her right to withdraw consent to processing of Personal Information, by sending a request for same to tltGames at tltgame.support@yandex.ru.

5.2. To raise the quality of the Game and services rendered thereunder, and to ensure availability of legal recourse, tltGames may maintain electronic logs of actions taken by Users when playing the Game—for a period of one (1) year from the moment any such action is taken.

6. Changes to the Confidentiality Policy

6.1. tltGames may unilaterally change or terminate this Policy giving no prior notice to the User. Any new version of the Policy shall be deemed effective from the moment it is posted on tltGames website, unless stipulated otherwise in said new version of the Policy.

6.2. The current version of the Policy is available at the tltGames site, at http://tltgames.tilda.ws/gc-privacy-policy-en .

7. Contact Information

7.1. Please contact us with any questions regarding this Policy, at tltgame.support@yandex.ru.


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