PRIVACY POLICY

Effective Date: 05. 27, 2024.

Introduction and Overview
Information Collection
Use of Information
Sharing of Information
Other Parties
Analytics and Advertising
Your Rights and Choices
Children
Data Security
International Transfer
Changes to this Privacy Policy
Contact Us

Introduction and Overview.

This Privacy Policy describes how Elegant Develop Publisher (“Elegant Develop,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to our platform (the “Platform”), games available through the Platform (the “Games”), websites for the Platform, Games (the “Websites”) and related applications (the “Apps”), and any online location operated by us that links to this Privacy Policy (collectively, the “Service”).

By using the Service, you agree to our Terms of Use and our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

Information Collection.

We collect information about you when you use the Service, including when you use the Platform, play our Games, register an account, update your profile, access our content, sign up for a rewards program, participate in a promotion, or contact customer support. We collect information about you in a variety of ways depending on how you interact with us;

Information You Provide To Us.

Directly from you when you provide it to us with opt-in process, such as when you register for an account, sign up to receive communications from us, make a purchase, or contact us by phone, email, or otherwise.

The categories of information we collect when you use the Service include:

Contact Data,including your first and last name, email address, phone number, and postal address.
Account Credentials,including your username, password, password.
Demographic Data,including your date of birth, gender, and country.
Profile Data,including your interests, inferences, preferences and favorites.
Content, includingcontent within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in product reviews or blog comments). We also collect content within any messages you exchange with other users through the Service (such as if you use our chat functionality).
Personal Contacts Data, including the first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent.

If you participate in a promotion and are declared a winner, depending on the prize we may also collect your driver’s license number, passport number, or other similar identifiers as set out in the applicable promotion’s additional terms and conditions.

If you are eligible for a gift by participating in an event, we may collect the following in order to provide the gift to you:

If a physical gift: name, mailing address, phone number, and email address.
If a digital gift: name, mobile phone number, and email address.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically.

Automatically through the use of cookies, server logs, and other similar technologies when you play our Games or otherwise interact with our Websites, Streaming Services, Apps, and other Services, as well as when you interact with our advertisements, and communications.

The categories of information we automatically collect include:

Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, gameplay data related to your interactions with our Platform, Games, and Streaming Service, faulty use records, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
Device Data, including data about the type of device or browser you use, your telecommunications provider, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address, a Global Unique Identifier, and Ad Id.
Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

The types of tracking technologies we use to automatically collect information include:

Log Files, which are files that record events that occur in connection with your use of the Service.
Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
Pixels(also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities, that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
App Technologies, which are technologies included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps may include SDKs which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our Apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

Information from Other Sources.

From your friends if they provide us with your contact information for purposes of inviting you to play our Games or otherwise engage with our Services.

We do not purchase personal information from other sources without your consent. From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources (including the public domain). For example, if you log into your user account through social media sign-in services. We will base these collections on your consent where required by law.

Use of Information.

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

Operating and managing our Service.
Performing services requested by you, such as responding to your comments, questions, and requests, and providing customer service.
Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
Preventing and addressing fraud, breach of policies or terms, and threats or harm.
Monitoring and analysing trends, usage, and activities.
Conducting research, including focus groups and surveys.
Improving the Service and other Elegant Developwebsites, apps, marketing efforts, products and services.
Developing and sending advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
Fulfilling any other purpose at your direction.
With notice to you and your consent.

In many situations we have more than one purpose. For example, when you create an account with us we will collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in giving our users the best experience possible while playing our Games. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Notwithstanding the above, we may use and share information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. To the extent we maintain and use such de-identified information, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. We conduct regular assessments and improvements to ensure that service providers with whom we share personal information for the purpose of service provision comply with our privacy policy and process personal information appropriately.
Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
Promotions and Prizes. Our promotions and prizes may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion or collect a prize, we share information as set out in the official rules or additional terms and conditions that govern the promotion or prize, as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion or collecting a prize, you agree to the official rules or additional terms and conditions that govern that promotion or mission, and acknowledge that these terms and conditions may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
Public Forums.We share information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
Merger or Acquisition. If another company acquires, or plans to acquire, our company, business, or our assets, we may share your personal information with that company, including at the negotiation stage.
Security and Compelled Disclosure. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
Facilitating Requests.We share information at your request or direction.
We share information in other situations with notice to you and your consent.

Please note that we do not rent, sell for monetary consideration, or provide personal information to third parties for purposes other than as described above, including to complete transactions and provide the Services.

Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.

Some examples include:

Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
Logging-In. We may allow you to log-in or create an account through social media or another platform, such as through a Google, Apple, Line or Vkontakte account. If you choose to engage with such integration, we may receive information from the platform that you have authorized to share with us, such as your public profile name, email address, and internal identification information. Please note that the platform may independently collect information about you through the integration.
Brand Pages. We may offer our content through social media. Any information we collect from your engagement with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Elegant Develop or the Service in a tweet or post), we may use your reference on or in connection with our Service. Please not that the social media provider will use your information in accordance with their privacy policy.
PlatformLinking. We may offer you the ability to link your Elegant Develop account to another service in order to retrieve certain data about your account on that service. For example, if you link your account to a gaming platform such as Steam or Twitch, the linking may allow us to obtain information such as your gaming username, email address, photo, game performance, and high scores. For more information about how these platforms handle information about you, please refer to their respective privacy policies and terms of use.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and which country they store information in. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising.

We use analytics services to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our Websites, Apps and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

Your Rights and Choices.

Account Information.

You may access, update, or remove certain information that you have provided to us through your Elegant Develop account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Tracking Technology Choices.

Cookies and Pixels.Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track.Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.
App and Location Technologies. You can stop all collection of information via an App by uninstalling the App. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an App by uninstalling the App or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

Communications.

E-mails. You can opt-out of receiving promotional emails from us at any time by emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
Push Notifications.If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

Children.

The Service is intended for general audiences, and is not directed at children under the age of 13. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If we become aware we have collected personal information in violation of COPPA, we will remove the personal information in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old.

We will make reasonable good faith efforts to remove the data from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

International Transfer.

Please be aware that information collected through the Service may be transferred to, processed, stored, and used in jurisdictions different from your country of residence. Data protection laws in these other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in other jurisdictions as set out in this Privacy Policy.

Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email:

elegdev@outlook.com