Privacy & Cookies

This Privacy Policy is effective from May 27, 2023.

We, at Black Snow Games, Inc. (hereinafter – “we”, “us”, “Black Snow Games”), have created a Privacy Policy that aims to help you understand what Data we collect, what we use it for and how you can exercise your rights. Reading Privacy Policy is important, so we hope you will give it time and attention.

For us the privacy and security of our customers, clients and visitors are of paramount importance. We are committed to protecting the Data you share with us. This privacy policy explains how we process information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of our website and products (“Services”).

For the purposes of this Policy, we define the term “Customer” as a person who has concluded the Service Agreement and the term “User” as an individual who uses our Services.

Personal Data may be freely provided by the Customer and User, or, in case of Usage Data, collected automatically when using the Black Snow Games Services.

Any use of Cookies – or of other tracking tools – by Black Snow Games or by Data Controllers of third-party services used by Black Snow Games serves the purpose of providing the Service required by the Users and Customers, in addition to any other purposes described in the present document and in the Cookie Policy.

Customers and Users are responsible for any third-party Personal Data shared with Black Snow Games and confirm that they have the third party’s consent to provide the Data to the Data Controller.

We adhere to the following principles in order to protect your privacy:

  • principle of purposefulness – we process personal Data fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of Data processing;
  • principle of minimalism – we collect personal Data only to the extent necessary for the achievement of determined purposes and do not keep personal Data if it is no longer needed;
  • principle of restricted use – we use personal Data for other purposes only with the consent of the Data subject or with the permission of a competent authority;
  • principle of Data quality – Personal Data shall be up-to-date, complete and necessary for the achievement of the purpose of Data processing;
  • principle of security – security measures shall be applied in order to protect personal Data from unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures;
  • principle of individual participation – the persons shall be notified of Data collected concerning him or her, the persons shall be granted access to the Data concerning him or her and the persons have the right to demand the correction of inaccurate or misleading Data.

Data we collect

Websites Users

We may collect, record and analyze information of Users of our website.

We collect name and email address only in a case when User wants to contact us and fills one of our contact forms. We use the collected Data only to communicate with You. If You do not want us to collect your Data, please do not use our contact form and do not give your consent for it.

While processing Personal Data of our Users, we rely on your consent to the processing of your Personal Data for the purpose to communicate with you. When we share such information with our contractors (which may be located outside of the European Economic Area) in order to provide a requested answer or solution promptly and correctly, we also rely on your consent. We use such Data in ways you would reasonably expect and which have a minimal privacy impact. 

We also record Usage Data. It is information collected automatically through Black Snow Games website (or third-party services employed by Black Snow Games), which can include: the IP addresses or domain names of the computers utilized by the Users who use Black Snow Games, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page) and the details about the path followed with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the Users’ IT environment.

We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you. When combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed into our website. We use Google Analytics to analyze data. Information collected this way is stored for no longer than one year.

Users can control the use of Cookies at the individual browser level. If you reject Cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. To learn more and for a detailed Cookie notice, the User may consult the Cookie Policy.

Processing of Usage Data relies on our legitimate interests. It is necessary for managing and running our business to efficiently and effectively provide quality services including website support, developing and improving services, and determining who may be interested in them.

When you contact us by telephone, email or filling in the contact form, you give us your implicit consent because you reasonably expect us to reply. We collect the Data you give us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of the organization of our support service. 

We keep personally identifiable information associated with your message, such as your name, email and mobile telephone number, so as to be able to track our communications with you in order to provide you with high quality service. We may record telephone conversations to improve our support quality and train our employees. We always warn you about this at the beginning of every conversation.

Wherever possible, we aim to obtain your explicit consent to process your Personal Data, for example, by asking you to agree to use Cookies.

By registering on the mailing list, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Black Snow Games. Your email address might also be added to this list after becoming a Customer.

Customers

In order to carry out our obligations under a contract between you and us we must process the information you give us.

We collect names, email, telephone numbers and bank details. This information is used by us to identify the Customers, provide them with services, mailings, notification, support and marketing actions, and to meet other contractual obligations.

We rely on our legitimate interests when we reach potential corporate clients by contacting them via Business-to-Business emails that contain marketing materials about the services we offer. Such an approach to marketing is extremely important for the development of our business. This processing has appropriate safeguards and a minimal privacy impact.

Product Users

Some of our Products require you to register with us or sign up for an account before you can use them. Where this is the case, you provide us with information including your age and the in-app username that you choose to use on our Products. We collect and use this information in order to authenticate you when you register an account and use the Products, to make sure you are eligible and able to receive the Products, and so that you receive the correct version of the Products.

You may be required to have an account with a supported external single sign-on service in order to use some of our Products. Where this is the case, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Black Snow Games Products.

If you choose to link your Google account to the Products, we will collect your Google email address and an authentication token provided by Google.

If you choose to link your Facebook account to the Products, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.

If you choose to link your Apple account to the Products, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.

Depending on the particular Product you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.

We collect and use your device location information as you use our Products (and, if you elect to turn on background location tracking for participating Products, while you are not directly interacting with these Products), including how you move around and events that occur during in app activity or gameplay. Our Products include location based games whose core feature is to provide an experience tied to your real world location, so we need to know where you are to operate these apps and games for you, and to plan the location of in-game resources (for example Energy Core within Battle for Earth). We identify your location using a variety of technologies, including GPS and mobile/cell tower triangulation.

We also collect and use your in-game or in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to operate the Products for you and to personalize your gameplay and user experience. We will also generate an internal account ID when you use certain Products to associate you with an account.

We also use the information above to show in-game sponsored locations that are in your vicinity as part of the gameplay experience.

We further use the information above in order to provide technical and customer support to you.

You also give us Personal Data when you make a purchase through our Products, subscribe to our publications, register for a live event, enter a competition, promotion or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, age, and email address. We use that information to fulfill those Services to you and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

  • Using your IP address, browser type, operating system, the web page you were visiting before accessing our Products, the pages of our Products which you browsed or the features you used, and the time spent on those pages or features, the links on our Products that you click on, device and advertising identifiers, age, gender, as well as actions you take during gameplay, your in-app user settings, preferences (including avatar characteristics), and your in-app purchases to learn about our users, and understand who is using our Products and how.
  • Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
  • Using your email address and device information in order to share updates and news with you either within the apps or by email. You can unsubscribe from these at any time in your device settings or in-app settings.
  • Analyzing your in-game actions and achievements to show you rewards, promotions, or other offers about our Products that are tailored to your personal user experience. You can choose to opt out of this and certain other processing of your Personal Data by following the steps described in “Your rights”.
  • To improve the features that we offer you through the Products, or to provide you with new or additional features for our Products.
  • To organize and run live events based on or featuring our games. Note that when you participate in live events your in-game actions and achievements, in-game username and and other components of your in-game profile will be visible to other event participants and to the public (for example on leaderboards displayed at the event and online).
  • Using your in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to carry out anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service, to prevent abuse, and to provide a fair gaming experience to all players.
  • To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.

Сompliance with General Data Protection Regulation (GDPR) and the United Kingdom legislation

For Users and Customers located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such Data, known as the General Data Protection Regulation (GDPR), and the United Kingdom legislation.

We process Personal Data as a Controller, as defined in the GDPR.

Black Snow Games with whom you as a Customer have entered into an agreement will be the Controller for Customers’ Data as outlined above in the “Customer” section.

Also Black Snow Games will be the Controller for Users’ Data, as outlined above in the “User” section.

The processing and transfer of personal Data is carried out in accordance with the requirements set out in the Data Protection Act 2018 and Privacy and Electronic Communications Regulations (PECR) of The United Kingdom.

Your rights

Users and Customers can review, correct, update, delete or transfer their personally identifiable information. For that, contact us directly at developers@blacksnow.tv We will acknowledge your request within seventy-two (72) hours and handle it promptly and as required by law.

As a Users or Customers you may:

  • Object to processing of your Data. Users and Customers have the right to object to the processing of their Data.
  • Access your Data. Users and Customers have the right to learn if Data is being processed by a Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users and Customers have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of your Data. Users and Customers have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
  • Delete or otherwise remove your Personal Data. Users and Customers have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller. The easiest way to delete your Personal Data is to submit a request through our website or email us at developers@blacksnow.tv.
  • Receive your Data and have it transferred to another controller. Users and Customers have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

You can withdraw your consents at any time by replying to the email with your withdrawal and your Personal Data will be deleted in 48 hours.

Also, you have the right to lodge a complaint with a supervisory authority if you think that we violate your rights. You could contact The Information Commissioner’s Office in The UK via its website or phone. However, we recommend that you contact us first.

Data Retention

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

We will keep your Data for the period that you are our Customer or User. If you are no longer a User of Black Snow Games, we will keep your Data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal or regulatory obligations.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between you and us shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes.

Usage Data information from contact forms are deleted on an annual basis. Your information will be deleted if you did not communicate with the support team for more than 12 (twelve) months.

Any Data collected for the purpose of analytics will be deleted in 12 months after being collected.

In any other cases we keep your Personal Data for as long as we need to provide the Products to you and fulfill the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to Data portability cannot be enforced after the expiration of the retention period.

We always use pseudonymisation as a method of securing the Personal Data we process as the Processor.

There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.

We never process any kind of sensitive Data and criminal offense Data, not as a Controller nor as a Processor. Also, we never undertake profiling of personal Data.

Information Security

We care to ensure the security of personal Data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process Your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction or unauthorized disclosure. This is done through appropriate administrative, technical and physical measures.

We always use pseudonymisation as a method of securing the Personal Data we process as the Processor.

There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.

We never process any kind of sensitive Data and criminal offense Data, not as a Controller nor as a Processor. Also, we never undertake profiling of personal Data.

Personal Data we share with others

We work with third party service providers which provide Services development, hosting, maintenance, sending emails, marketing, technical support and assistance, processing credit card payments, IT and cyber security services, law enforcement agencies, regulators and other authorities and other third parties necessary to provide products or services which you have requested.

We use Google Analytics to monitor and analyze web traffic. Google Analytics is a web analysis service provided by Google LLC. (“Google”). Google utilizes the Data collected to track and examine the use of our Services, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy – Opt Out. Privacy Shield participant.

When you use the Products, and in particular when you play our games, use social features within those games, or take part in live events, we will share certain Personal Data with other players or users. This Personal Data includes your in-game or in-app profile (such as your username) your in-game or in-app actions and achievements, real-world locations associated with your gameplay, or which gameplay resources you interacted with when playing the game (for example Energy Core within Battle for Earth), and your in-game messages and related content you share with other players or users. Additionally, certain games or apps link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services; Black Snow Games does not control and is not responsible for the practices of these third-party sharing features.

We may need to share your Personal Data with the third parties that provide those services. Where your Personal Data is transferred outside of the European Economic Area (“EEA”), we require that appropriate safeguards are in place. These contractors may have access to, or process Personal Data on behalf of us, as part of providing those services to us. We limit the information provided to these service providers to the extent it is reasonably necessary for them to perform their functions.

We guarantee that we have Data Processing Agreements in place with our service providers, ensuring compliance with the GDPR and our contracts with them required to maintain the confidentiality of such information. All Data transfers inside and outside of the EEA are being done in accordance with these Data Processing Agreements. All Data transfers are performed in accordance with the strictest security regulations.

For more detailed information about the international information transfers to our business partners, service providers and developers outside of the EU/EEA, please contact us using the details given in the “Contact us” section below.

Use of site by children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not knowingly collect Personal Data from them. We define “children” as follows:

Residents of the UK: anyone under 13 years old.

Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.

Residents of the Republic of Korea, anyone under 14 years old.

Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.

Users declare themselves to be adults according to their applicable legislation.

Application of this Privacy Policy

This Privacy Policy is applicable to only our Services. This version of the Privacy Policy is effective from December June 29, 2023.

Please be aware while visiting our site. Our Services contain links to other websites and resources. Once redirected to another website or resource, this Policy is no longer applicable. We are not responsible for the content or privacy policies of these other sites.

Acceptance of these Conditions

We assume that all Users and Customers have carefully read this document and agree to its content. If one does not agree with this privacy policy, they should refrain from using our Services.

Changes and Updates to Our Privacy Policy

We may update this policy from time to time, so please review it frequently. All changes to this Privacy Policy are effective upon being posted on this page.

If any material changes are made to this Privacy Policy, we will use reasonable endeavors to inform you in advance by email or notice on the Services. When we change this Policy in a material manner, we will let you know via email prior to the changes becoming effective and update the “effective date” at the top of this page.

Contact us

f you have any questions about the practices of our Services, please contact us at developers@blacksnow.tv

Cookies policy

Black Snow Games uses cookies to improve your user experience of our Services and provide relevant content and functionality. We also use cookies to analyze our traffic statistics. We also use cookies to show relevant ads to you and analyze our traffic statistics.

Our Services use cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our Services and helping our team to understand which sections of the Services you find most interesting and useful.

Black Snow Games Services use different types of Cookies for different reasons, as follows:

  • Absolutely Necessary Cookies. These Cookies are essential to enable you to move around Black Snow Games Services and use its features. Without these Cookies, services you have asked for, like adding items to an online shopping cart, cannot be provided.
  • Performance Cookie. These Cookies collect information about how you use Black Snow Games Sites. Information collected includes, for example, browsers and operating systems used, domain name of the Services previously visited, number of visits, average duration of visit, and pages viewed. These Cookies do not collect information that personally identifies you and considers aggregated data. Performance Cookies are used to improve the user-friendliness of Services and enhance your experience.
  • Functionality Cookies. These Cookies allow the Services to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume that you are happy with it.