Privacy Policy Rungers

The last update: January 08, 2024

In accordance with Article 1 of the Law of Ukraine “On Personal Data Protection” (the “Law” or the “Regulation”), Kushnirenko Denys hereby provides its clients, including potential clients, as well as third parties in general (e.g., trustees, legal representatives, etc.) who contact them on behalf of clients, including potential clients (“Data Subjects”), with the information required by law regarding the processing of their personal data (“Data”).

Who we are

RungersSingle-player game
Data ControllerPhysical person entrepreneur.
Kushnirenko Denys.
Address: 7 Bobrova St., Pryluky, Chernihiv Oblast, Ukraine

We offer our games to users residing in jurisdictions around the world, including the European Union and the United States. 
Kushnirenko Denis is the controller of the personal data collected from these users, insofar as this concept applies in these jurisdictions.
In accordance with the EU General Data Protection Regulation (“GDPR”), we have appointed Kusnirenko Denis as our representative for the purposes of the GDPR in the EU and for the purposes of COPPA in the United States.
Users residing in the EU and the U.S. may contact us with questions regarding how we collect, store, use and disclose their personal information at the address below.
Data Protection Officer
personal data
Kushnirenko Denys.
E-mail: terrakote@amateursdreamstudio.com

HOW WE COLLECT PERSONAL DATA

The data to be processed by the Data Controller may be obtained

– from the Data Subject, including through remote communication methods used by the Data Controller (e.g., websites, applications for smartphones and tablets, call centers, etc.);

– From third parties (e.g., parties who arrange transactions on behalf of the Data Subject, commercial companies and risk information companies, outside companies for market research purposes, etc.).

Data from public sources will also be used, such as public registers, lists, documents that can be consulted by anyone (such as balance sheets, information contained in the company registry at the Chambers of Commerce, real estate documents and other so-called authorizing documents, such as mortgage registration or foreclosure transcripts), and Data extracted from sources publicly and generally accessible to all, such as printed or digital newspapers, information taken from telephone directories, websites of government agencies or other supervisory and supervisory authorities.

WHAT DATA WE PROCESS

DATA CATEGORY

Personal Data

When you use the Rungers app on the mobile platform, we may collect and process (store, share with our partners, process for analytical purposes) the following data strictly in accordance with the lawful bases set out above:

– Your E-mail address and/or social network account.

– Your advertising identifier, i.e., 
” if you are using an Apple device, IDFA (Identifier For Advertising) / IDFV (Identifier For Vendors)
” if you are using an Android device, GAID (Google Advertising ID).

– Your location at the city/region level (based on your internet protocol – ‘IP’ – address),

– Technical information about the device you are using and your connection (e.g. operating system, device model, connection type, language, time zone),

– Technical data relating to the application you are using (e.g. the version of the application you have installed),

– Data relating to your in-game activities and interactions with our apps (e.g. gameplay data, total game time, how and when you use our apps, your level in the game, details of your in-app purchases, excluding your payment/credit card information)

– Data relating to advertisements placed on our apps (e.g. number of ads you clicked on, time of purchase, number of IAPs you purchased).
NOTICE
We do not collect, and we ask you not to provide us with any information that is subject to certain legal restrictions and requirements, such as racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and labor unions, criminal convictions or suspected criminal offenses, or health, sex, biometric or genetic information.
Cookies collection and processing
We use cookie technology to collect additional data about the use of our Application and/or Site and to improve their performance and the quality of our services. Cookies are small files that network software services or service providers place on your device through the Application and/or Site (if you allow) that allow the Application and/or Site or service providers to recognize your browser and store and remember certain information. Through the use of cookies, we may process information such as:
Device data, hardware model, unique device identifiers, MAC address, IP address, operating system version and device settings; Log file information: Time and duration of site usage, search queries, location information and any other information stored in cookies that allows us to uniquely identify your browser or account. We use cookies for many important purposes – for example, to help you log in and improve your experience using our service or services. We may use cookies to better understand how you interact with the Application and/or Site, to track the total number of users and traffic routing, to improve our Application and/or Site and our services, to understand your preferences based on previous or current activity, and to enable us to provide you with the highest quality of service.

FOR WHAT PURPOSES WE NEED THE DETAILS OF THE PERSON CONCERNED

PURPOSE OF PROCESSINGLEGAL BASIS FOR PROCESSING
Registration and processing of contact information requests. 
The processing of the data subject’s personal data is carried out for the purpose of performing preliminary and follow-up actions related to registration requests, information and contact management and/or the sending of information material, as well as for performing any other obligations arising therefrom.
The legal basis for such processing is the fulfillment of services corresponding to the registration request, the provision of information and contact data and/or the sending of information materials, as well as the fulfillment of legal obligations.
The provision of data is optional.
However, any refusal by the person concerned to provide the data will make it impossible for the controller to provide the service requested.
Contractual relationship management.
The processing of the data subject’s personal data is carried out for the purpose of performing actions prior to and subsequent to the purchase of the Service and/or product, such as, for example, managing the relevant order, performing the Service itself and/or the product purchased, billing and payment management, processing complaints and/or service reports, and providing assistance, sending messages with content, and performing any other obligations arising from the contract.


The legal basis for such processing is the performance of the services inherent in the contractual relationship and compliance with legal obligations.
The provision of data is optional, however, any refusal by the person concerned to provide the data will make it impossible for the controller to provide the requested services.
Protection of the right in court or out of court proceedings.
The processing of the Data Subject’s Personal Data shall be carried out for the purpose of establishing the exercise or protection of the Controller’s right and/or defending against claims by others in judicial or extrajudicial proceedings.
The legal basis for such processing is the pursuit of the legitimate interests of the Controller, taking into account the balance of rights of the latter and the Data Subject.
General and computer security.
Personal data of the data subject is processed for the purposes of network and information security, the protection of corporate assets and the security of Rungers systems.
The legal basis for such processing is to comply with the legal obligations and pursue the legitimate interests of the Controller, taking into account the balance of rights between the Controller and the Data Subject.
The Data Subject has the right to object at any time, for reasons related to his/her personal situation, to the processing of personal data concerning him/her for the relevant purpose.
Fraud prevention.
The processing of the data subject’s personal data is carried out to ensure control in order to monitor and prevent fraudulent actions and payments, by means of software systems that carry out checks in an automated way and before the negotiation of the service/product. Failure to carry out such checks with a negative result will make it impossible to carry out the transaction. 
The interested party, in any case, may express an opinion, obtain an explanation or challenge the decision, explaining the reasons for the decision to Customer Service at:  terrakote@amateursdreamstudio.com 
The legal basis for such processing is the pursuit of the legitimate interests of the Controller, taking into account the balance of rights the latter and the Data Subject.
The Data Subject shall have the right to object at any time, for reasons relating to his/her personal situation, to the processing of personal data concerning him/her for the relevant purpose.
Promotions for services/products similar to those purchased. 
The processing of the Data Subject’s personal data is carried out for the purpose of sending email messages related to promotions and offers of services/products of the Controller that are identical and/or similar to those covered by the current contract with the Data Subject, unless the Data Subject objects to such processing initially or during subsequent communications.
The legal basis for such processing shall be the legitimate interest of the Controller to promote products or services in which the customer may have a legitimate interest, taking into account the balance between the rights of the latter and the Controller.
The Data Subject shall have the right to object at any time, for reasons relating to his or her personal situation, to the processing of personal data concerning him or her for the relevant purpose.
Behavioral advertising
Contextual advertising designed to be tailored to a user’s specific interests.
Users in the United States may opt out of receiving interest-based advertising from many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Users in the European Union or United Kingdom may go to the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr
Promotional activities for services/products offered by Rungers. 
The personal data of the data subject is processed for the purpose of sending (with express consent) communications about promotions and offers of the Owner’s Services/Products by means (e.g. regular email, telephone calls with the operator, Push notifications) including automated means.
The legal basis for such processing is the consent given by the data subject prior to the processing itself, which can be freely withdrawn at any time, without prejudice to the legitimacy of the earlier processing.
Any refusal by the data subject to give consent entails the impossibility to use the services in question, with no adverse consequences for the contractual relationship with the data controller.
Profiling.
The processing of the data subject’s personal data is carried out, with specific consent, for profiling purposes, for example to analyze the data transmitted and the Services / Products purchased in order to offer promotional messages and/or commercial offers according to the choices made by users.
The legal basis for such processing is the consent given by the data subject prior to the processing itself, which can be freely withdrawn at any time, without prejudice to the legitimacy of the earlier processing.
Any refusal by the data subject to give consent entails the impossibility to use the services in question, with no adverse consequences for the contractual relationship with the data controller.

TO WHOM WE REPORT THE DETAILS OF THE PERSON CONCERNED

CATEGORIES OF RECIPIENTSPURPOSE
Company or groups of companies RungersAdministrative, accounting, and service-related tasks
Third-party suppliers and group companies
Rungers
Providing services (support, maintenance, product delivery/delivery, additional services, network and electronic communication service providers) related to the requested service.
Credit institutions and digital payment institutions, Banking/postal institutionsManagement of fees, payments, reimbursements related to the execution of contracts
External specialists/consultants and consulting companiesFulfillment of legal obligations, enforcement of rights, protection of contractual rights, collection of debts
Financial management, state authorities, judicial authorities, supervisory bodies oversight and controlFulfillment of legal obligations, protection of rights; lists and registers maintained by public authorities or similar bodies, based on special regulations, in connection with the requested service.
Persons officially delegated or having recognized legal titleLegal representatives, supervisors, guardians, etc.
Entities in these categories act independently as individual data controllers or as data processors appointed by the Data Controller.
Data may also be known, in connection with the performance of assigned tasks, to the Owner’s personnel, including interns, temporary employees, consultants, and specifically authorized data processors. Personal data in any case will not be disseminated and therefore will not become known to unidentified persons, in any form, such as by giving them access or reviewing them.

HOW WE PROCESS DATA OF THE DATA SUBJECT

Data processing shall be carried out by manual, computerized and telematic means and in compliance with the necessary measures prescribed by regulations to ensure confidentiality, integrity and availability of the Data and to prevent damage, both material and non-material.

WHERE WE PROCESS THE DATA OF THE DATA SUBJECT

Personal data of the Data Subject is stored in archives located on the territory of Ukraine. If it is necessary to achieve the stated purposes, the Data Subject’s data may be transferred abroad to countries/organizations outside Ukraine that guarantee the level of personal data protection recognized by the European Commission in its decision as sufficient, or on the basis of other relevant guarantees, such as the Standard Contractual Clauses adopted by the European Commission, or with the consent of the Data Subject. The Data Subject has the right to receive a copy of such guarantees, as well as a list of countries/organizations to which the data has been transferred, by writing to terrakote@amateursdreamstudio.com.   

By using our Game (App), you are transferring data to the United States. If you are from the European Union or other regions with laws governing data collection and use, please note that you consent to the transfer of your information to the United States and its processing worldwide. By submitting your personal data, you consent to its transfer and processing in accordance with this Policy.

HOW LONG DO WE KEEP STAKEHOLDER DATA

The Data will be stored in a form that identifies the Data Subject for a period of time not exceeding that necessary to achieve the purposes for which it was collected, taking into account the laws applicable to the activities and sectors in which the Data Controller operates. Upon expiry of the time limits thus established, the Data will be deleted or converted into an anonymous form, except in cases where its continued retention is necessary to fulfill obligations (such as tax and accounting ones) that remain even after termination, or to comply with orders issued by public authorities and/or supervisory bodies.

POLICY REGARDING MINORS

Generally, we direct our Services to a general audience, and we do not knowingly collect, solicit, or market personal information from children under 16 years old (or older, if required by applicable law), and do not wish to do so.

We reserve the right to request proof of age (for example, we may request your month and year of birth) or parental or legal guardian consent at any time, and we may block users if we suspect they are under the applicable age.

If we learn that a child under 16 years old is using the Services, we may block such use. If we become aware that personal information from a child has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you learn about any personal information we have collected from a child under age 16, please contact us immediately.

We encourage all parents, guardians, and others of the age of legal majority to instruct children to never give out their real names, addresses, or other personal information without permission when using the Internet.

WHAT ARE THE RIGHTS OF DATA SUBJECT

By contacting terrakote@amateursdreamstudio.com, the data subject has the right to access, delete, correct inaccurate data, merge incomplete data, restrict processing, portability of their data and object to processing in cases provided for by the Law.

The data subject also has the right to lodge a complaint with the competent supervisory authority in Ukraine or with the authority performing its duties and powers in the state where the violation occurred, as well as to apply to the court.

CHANGES TO THIS POLICY

We may make changes to this Policy from time to time. Use of information we collect now is governed by the Policy in effect at the time we use such information. If we make changes to the way we use personal information, we will notify you, for example, by posting an announcement on our Service or sending you an email to an email address you may have provided to us. Material changes will be effective seven (7) days after such notice is posted on our Services or emailed to you, whichever comes first; all other changes to this Privacy Policy will be effective as of the “Last Revision” date indicated. If applicable law requires consent to the processing of your data in accordance with this Privacy Policy, your continued use of the Services on or after the Last Revision Date will constitute acceptance of and agreement to be bound by those changes. In the event that the terms must be modified as required by law, the changes may be effective immediately or as required by law and without notice.

We use the following services:

Google Analytics is a web analytics service. Address: Google LLC, 1600 Amphitheatre Parkway Mountain View, California, 94043 USA. More information can be found here
Appodeal is a service to optimize mobile advertising revenue. Address: 575 Market St, 5th Floor San Francisco, CA 94105,USA. Read more here.1

CONTACTS

Physical person entrepreneur.

Kushnirenko Denys.

Address: 7 Bobrova St., Pryluky, Chernihiv Oblast, Ukraineterrakote@amateursdreamstudio.com