1. General information
1.1 The company “Last Gear Publishing SRL” having a principal place of business at B-dul Pipera (Fosta Sos. Pipera-tunari) 1/Vi, Bucharest, Romania, (“we”, “us”, or “our”) do not collect from individual users, including children under the age of 16, (“you” or “your”) certain personal data from our mobile applications (“Inno’s Adventure”, “Baseball Run Smash”, “Hell’s Kitchen”, “Moonbear Smash”).
• The term “personal data” refers to any information relating to a natural person who can be identified, directly or indirectly, by using such information; and
• The term “processing” refers to collection, storage, erasure, use, and disclosure of personal data.
2. Kinds of personal data collected by us
2.1 Taking into account that some Last Gear Games are primarily targeted at children, we respect strictest data protection principles.
2.2 When you use our games, we do not collect any personal data from you. Our analytics functionality may have access to your IP address. However, we neither store nor use or access your IP address for any purposes. Your IP address is not used, in any manner, including in combination with other information, to identify you.
2.3 The personal data listed below may be provided by you voluntarily:
• When you send us feedback or contact us via email or the contact form, we collect your (i) name, (ii) email address, and (iii) any other personal data you decide to provide us. We delete such personal data from our databases as soon as we reply to your message.
2.4 We shall not, in any manner, make your personal data public.
2.5 Sensitive data. We do not collect, under any circumstances, any sensitive data from you, such as your health information, opinion about your religious and political beliefs, ethnic origins, membership of a professional or trade association, or information about your sexual orientation.
3. Kinds of non-personal data collected by us
3.1 When you use Last Gear Games, we may collect your non-personal data. The non-personal data includes analytics data, such as your activity on our games. The non-personal data collected by us does not allow us to identify you in any manner.
3.2 Aggregated data. We do not aim to aggregate your personal data and non-personal data. In case your non-personal data is aggregated with certain elements of your personal data in the way that allows us to identify you, we will treat such aggregated data as personal data.
3.3 Purposes of non-personal data. The non-personal data is used to analyze what kind of users plays our games, how they find it, how long they stay, what functionalities of the application they use. We use the non-personal data to improve our business activities and provide you with the best possible services.
4. The purpose of collection of your personal data
4.1 We use your personal data only for the purposes for which such personal data is provided:
• Your email address, name, and other personal data (if any) submitted through the contact form are used to reply to your requests on a one-time basis. After we reply to your request, we immediately delete such personal data.
4.2 Legal grounds for data processing. Depending on the circumstances in which you provide your personal data to us, the collection and processing of your personal data by us is carried out on the basis of one of the following legal grounds:
• Pursuing our legitimate business interests (e.g., analyzing the usage of Last Gear Games);
• If you have provided us with your explicit consent; or
• If we are required by law to do so.
5. Protection of your personal data
5.1 We will put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data. We use organizational and technical security measures to protect all types of personal data, such as limited access to your personal data by our staff, secured networks, and encryption.
5.2 Security breaches. Please note that, due to the inherent risks of using the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances beyond our reasonable control. In case a personal data breach occurs, we will inform the relevant data protection authority without undue delay and immediately take reasonable measures to mitigate the breach, as stipulated in the applicable law.
6. Exercising your rights
6.1 We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date.
6.2 We provide you with the possibility to exercise your rights regarding your personal data. You can request us to:
• Access your personal data that we retain;
• Move your personal data to another entity;
• Delete your personal data from our systems;
• Object and restrict processing of your personal data;
• Withdraw your consent;
• Process your complaint.
6.3 If you would like to exercise your rights listed above, please contact us by email at firstname.lastname@example.org. We may ask you to provide us with an identifying piece of data, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 1 week.
6.4 Launching a complaint. If you would like to launch a complaint about the way in which your personal data is handled, we kindly ask to contact us first. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
7. Retention period
7.1 Your personal data will be kept for as long as is necessary to provide you with the requested service. For instance, if you contact us by using the contact form, we will retain your personal data only until we reply to your enquiry.
7.2 When your personal data is no longer necessary to deliver the requested service or you cease using Last Gear Games, we will immediately delete your personal data, unless we are required by the applicable law to retain such personal data for a certain period of time.
8.1 We will seek explicit prior consent from you (if you are above the age of 16) or you parent or guardian (if you are under the age of 16) in the following cases:
• Before responding to you more than on a one-time basis;
8.2 We provide the parents or guardians of children under the age of 16 with an option to agree to the collection and use of the child’s personal data without consenting to the disclosure of the personal data to third parties.
8.3 If a person under the age of 16 has provided us with personal data without obtaining parental consent in advance, the parent or the guardian may contact us by email at email@example.com and request us to destroy or de-identify the personal data.
10. Contact details
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data (its correction, removal or use), you can do so by sending a letter to our email address: firstname.lastname@example.org