PRIVACY POLICY

Dated December 8, 2022

This Privacy Policy (“Policy”) describes how INCRDBL UN LIMITED (“INCRDBL”, “We”) processes users’ personal data. By expressing your consent in the forms presented in our Games, or by using our Website (collectively “Services”), you or your representative (“User”, “You”) accept the Policy.

WHO WE ARE

INCRDBL UN LIMITED
Registration number: HE 406957
Legal address: Modestou Panteli, 8, Tseri, 2480, Nicosia,Cyprus.
E-mail: [email protected]

The Policy applies to all the Games developed and/or published by Us as well as to all Our Websites. Please, note that privacy policies of Platforms where a Game was downloaded from by a User may establish their own rules for users’ personal data processing when using the corresponding Platform. The Platform is independently responsible for such processes.

Please, check this page regularly, as We will publish the latest version of the Policy here. Amendments will be effective from the moment of publication.

IF YOU ARE UNDER 13 Y.O. IN ORDER TO CONTINUE TO USE OUR SERVICES PLEASE ASK YOUR PARENT OR YOUR GUIRDIAN TO STUDY POLICY WITH YOU AS THEY ARE OBLIGED TO ACCEPT THE POLICY ON YOUR BEHALF.

Acceptance of the Policy with respect to minors

To accept the Policy, you must reach the age of sufficient legal capacity under applicable legislation (the laws of the country of your residence: particularly, for residents of EU – 13 to 16 years, depending on the country of your residence within EU; in the USA – 13 to 16 years, depending on the state of residence within the USA).

If you are under the age of legal capacity, please ask your parents or other legal representatives for assistance before using our Games. By indicating your age through the special form within the Services as well as by continuing to use our Games, you certify that you are either reached the age of legal capacity to accept the Policy, or your parent/legal representative has reviewed and agreed to the terms of the Policy on your behalf.

If you, as a parent or other legal representative, learn that your child has accepted the Policy without your consent, please contact us (for example, via e-mail at [email protected] or other means indicated on the Website). We will promptly erase corresponding data and inform our partners about it.

We recommend that you monitor your children’s game sessions and web activity, as well as study parental control options that can be provided by us and/or our partners.

Definitions:

• “Contact data” means data that We collect when a User contacts technical support service of INCRDBL in order to be able to contact User as part of user support provision. Such data includes User data determined according to means User exploits in order to contact us with the aim to receive user support: email address, phone number and name/username.
• “Cookies” means small fragments of data sent by our web server and stored on User's Device. Cookies are stored when you visit the Website, and this allows us to make it work effectively: Cookies allow us to save your selected settings (e.g., language) and analyse Website traffic. You have the right to refuse Cookies that you do not want to be used in the Cookie-banner on the Website, however, please, note that you cannot disable Cookies necessary for functionality of the Website.
• “Device” means a device from which you use our Games and/or Website. Devices include mobile devices, tablets, personal computers, consoles, etc.
• “Device information” means technical information about your Device. Device information includes browser data and types of browser plug-ins, operating system and operating system version, information about the type and manufacturer of a Device, language set for a Device, version of Games installed on a Device used.
• “Financial information” means information about purchases made by a User, including purchase of In-Game Objects. Such information includes transaction ID (financial transaction number, including purchase, recovery, return), transaction amount, billing address, transaction date, transaction history (time of initiation of processing and completion time), purchase history. Please, note that when you make in-game purchases in Games, we do not collect and do not have access to your name, contact details and payment information. This information is collected and stored by the Platform or payment system operator of the Platform which you use to launch Games.
• “Game” means a game developed and published by INCRDBL, regardless of the Platform on which it is distributed or the Devices for which it is developed. In particular, term ‘Game’ includes but is not limited to the game «Word Masters».
• “IDs” means technical identifiers of a User assigned to them or their Device. Such identifiers include User ID assigned by INCRDBL; Platform ID; Device ID assigned by INCRDBL, advertising identifier of a User's Device (IDFA, GAID, etc.).
• “Terms of Use agreement” means an agreement between us and a User, on the basis of which User is granted access to our Games and other Services. User enters into a Terms of Use agreement with us by accepting its terms upon the first launch of a Game or access of the Website. The agreement is posted here: https://incrdbl.me/en/terms_of_use.html.
• “Platform” means online store through which the Game is provided to the User. The Platforms include, in particular:
  • Stores for mobile versions of the Game: Google Play, App Store;
  • Social networks: Facebook.

  This list is not complete and can be changed from time to time.

• “User information” means information that a User independently provides (publishes and presents in any form) in a Game. User information includes, in particular:
  • nickname in a Game;
  • list of “friends” in a Game;
  • data about User's gaming experience and behaviour, including statistics, User screen activity and User progress within a Game.
  User information is provided by a User voluntarily and may become available to other users. INCRDBL is not liable for composition and fact of dissemination of personal information that a User voluntarily and on his own initiative discloses to third parties.
• “User screen activity” means information available on the screen of the Device during Your engagement with the Game apart from Your sensitive personal data as well as outside messages and any push notifications You may receive within Your Game interaction that were not sent to You in the Game itself.
• “Website” means Our websites available at https://incrdbl.me/; http://wordmasters.me/.

Why do We need to collect and process Your personal data?

(1)

Collection and processing of Users' personal data is essential for our ability to support Games and Website, as well as their functionality.

Without it We cannot provide user support, display advertisements so that some of our Games and their elements remain free for You, restore progress in Games when switching Devices, analyze statistics of our Games to improve your user experience, correct errors in Games, determine the need for changes in our commercial decisions regarding Games.

(2)

Collection and processing of Users' statistical data helps us to analyze and therefore improve Our Services.

PLEASE NOTE that We do not use automated processing of personal data to make decisions that entail legal consequences for a subject of personal data, or otherwise affect her rights and legitimate interests.

What legal grounds do we have in order to collect and process Your personal data?

Collectively, we rely on the following legal grounds:

(1)

Your explicit consent with the Policy

In order to process personal data, We obtain Your consent to processing of personal data in accordance with the Policy through consent forms within the Services. Every User has a right to refuse to give the consent as well as to withdraw it (please see below for more information).

PLEASE NOTE that without obtaining such consent, unfortunately, we are forced to terminate access to the Services or significantly limit functionality of the Services for you.

(2)

Our contractual obligations with Users

We need to collect data in order for Us to fulfill Our obligations under the contract concluded between You and INCRDBL (Terms of Use agreement).

(3)

Our legitimate interest

Our legitimate interest is simply to provide the best and comfortable Services to You and it includes the following:

• market research where We offer our services, analysis of statistics;
• exercise and protection of Our rights and rights of third parties;
• marketing and promotion of Our Services;
• ensuring security and fraud prevention in the Services.

(4)

Requirements of the local legislation

The legislation of some countries may oblige Us to collect and/or process personal data in order to fulfill the local obligations. We strongly advise You to seek counsel with a professional lawyer to learn what specific requirements the legislation of Your country has.

What information do we collect and process?

We collect only the following categories of personal data:

• User information;
• Contact data;
• IDs;
• Financial information;
• Device information;
• E-mails;
• Cookies.

Below You can find a list of personal data processed, legal basis for collection and processing, and purposes We use the data for:

PLEASE NOTE that We do not collect any other categories of data and make every effort to exclude accidental collection of additional data.

PLEASE NOTE that We do not collect any of the sensitive data that may occur due to Your engagement with the Game.

INCRDBL cares for the safety of Your data. We follow generally accepted industry standards to protect Your information, both during transmission and once it is received. Our employees and third parties that We share your information with are obliged to keep confidentiality of Your data.

User screen activity data

What is it: within the User information We may as well collect User screen activity data. That means that while You are playing in Our Game We can record the information from Your screen Device that is related only to the Game. Basically, it is the visual representation of how You see the Game and how You interact with it.

PLEASE NOTE that the recording applies only to the Game – if You receive a message from an acquaintance or a push notification from another app, we will not see or collect it.

Why do We need to do so: only for the analysis of User behaviour. The visual representation of Your interaction with the Game will greatly help Us to understand more about the User experience. Based on that analysis We will be able to improve Our Service and Game performance and enhance Your interaction with the Game.

How do We do it: to capture Your interaction with the Game on Your screen We implement the Smartlook SDK – the software solution of Our partner Smartlook. As We described earlier, we are keen to secure all of Your personal data and make sure that Our partners take measures to keep it safe as well.
Nevertheless, We encourage You to read carefully Smartlook privacy documents to make sure that You agree to provide the User screen activity data:

• Smartlook Privacy Policy: please read here;
• how Smartlook excludes sensitive data from session recordings: please read here;
• how Smartlook secure the data: please read here.

How long do We store Your data?

We strive to limit the period of data processing to the necessary minimum and not to store them for longer than is reasonably necessary.

We process Your personal data only while You play Games, as well as for three years from the date of the last gaming session and activity in a Game. This is necessary to ensure Your ability to restore game progress and analyze the use of Our Games.

If applicable data protection legislation prescribes storage of personal data for a longer or shorter period of time, We will store personal data for a period in accordance with these legal requirements.

After the expiration of the specified period, Your data will be deleted, and Your game progress cannot be restored.

As for the storage of Cookies on the Website, their storage is limited to the period of Your session on the Website. However, there are several types of Cookies that can be stored for up to 1 year. These include Cookies that store information about the first visit of the Website and User's Device.

As for the storage of User information, We do not store the data of the private messages between the Users. The data from the Community chats is stored only in amount of the last 100 messages and then gets deleted.

We strongly advise You to seek counsel with a professional lawyer to learn what specific requirements the legislation of Your country has.

Do we transfer Your personal data to any third party?

INCRDBL is engaged in game development, and our partners – in Games analytics and demonstration of advertisements. Together we hope to provide You with the best user experience in the Games. With that purpose We may transfer Your data to third parties indicated in this Policy.

What we can transfer to third parties:

• User information;
• IDs;
• Device information;
• Cookies.

Due to that transfer of the data We can deliver Our Services to Our users, measure, analyze, show You advertisements, including targeted advertisements and improve performance of the Games and therefore Your gaming experience, and to continually update and develop Our Games.

By accepting the Policy, You agree that We may transfer certain data to third-party services, as well as receive data that may refer to You from third parties (e.g. Social Networks and Application Stores for payment verification).

Below is the current list of third parties we interact with:

While using our Games, You may see links to third-party websites or applications (for example, in advertisements shown in Games). We would like to warn You that We are not liable for the services of third parties and their data collection processes, and do not control them. By clicking on the links, You can share your personal data with third parties in accordance with their data processing rules.

What are Your rights regarding the personal data?

You have certain data subject rights under applicable data protection laws and regulations to:

(1)

request access to Your personal data (request the upload of a copy of Your personal data), and also have the right to correct or delete it;

(2)

obtain restriction of processing or to object to the processing of Your personal data;

(3)

request information about Our procedures of processing Your data;

(4)

file a complaint against Us with a supervisory authority of the country of Your residency.

PLEASE NOTE that You may have the other rights that granted by Your local legislation. We strongly advise You to seek counsel with a professional lawyer to learn what specific requirements the legislation of Your country has.

PLEASE NOTE that You may exercise any rights by contacting Us through [email protected]. In case You want Us to delete Your data we will fulfill such a requirement within 30 (thirty) working days, and your game progress on all Devices will be lost.

INFORMATION FOR EU RESIDENTS

You can exercise all the rights mentioned above in accordance with GDPR. In order to ensure Your rights regarding collection, storage and processing of personal data, You have a right to file a complaint with the authority at Your place of residence. The list of responsible authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

We may transfer personal data relating to You outside of the EEA, since We may store Your personal data, as well as transfer it to third-party services located outside of the EEA, e.g. the United States of America - the country, which may not offer the same level of data protection as the laws and regulations which apply to You.

We undertake to store Your personal data only in those jurisdictions that use the necessary security mechanisms to protect Your personal data, including various data encryption methods. With each of the third party, We accept obligations under the standard contractual clauses adopted by the EU Commission, which give Us a legal basis for such transfer.

While We and third-party service providers apply the aforementioned measures, under Article 49(1)(a) of the GDPR We are obliged to list the following potential risks of such storage outside of the EEA:

(1)

Existence of different rules and regulations on personal data processing in such other jurisdictions that are different from the GDPR. Nevertheless, We provide personal data subjects with the level of guarantees granted to personal data subjects by the GDPR.

(2)

Obtaining access to Your personal data by state organs of the United States of America, or other special governmental Services. However, such access can only be obtained by these organs in accordance with the applicable law of that country and if there are legal grounds for obtaining the access. We undertake obligation not to disclose information in the absence of such legal grounds and only in the minimum required value.

(3)

Efforts of illegitimate access to the personal data. We take all the necessary measures to prevent such efforts and do not allow unauthorized access to Your personal data.

PLEASE NOTE that by agreeing to processing of Your personal data in accordance with this Policy, You give Us explicit consent to transfer of Your personal data to jurisdictions outside the EEA, despite all possible risks of such transfer.

IF YOU RESIDE IN CALIFORNIA, USA

As We are subject to the California Consumer Privacy Act (“CCPA”), We warrant that:

• We are committed to using data about users as permitted by the CCPA, and
• We do not sell users’ personal data.

You have the following rights under the CCPA:

(1)

Right to know and right to delete – You have a right to request disclosure or deletion of Your personal data. To exercise this right, please, contact Us via [email protected];

(2)

Right to opt out – Since We do not sell Your personal data, You have a right to opt out from future potential “sales” of personal data by contacting Us via above-mentioned e-mail containing a phrase “Do not sell my data”. You may also opt out from the future potential sale of data related to You by not using Our services.