TThis Online Privacy Policy (the “Policy”) is a document developed to help Users understand methods the Company
collects, processes, uses, discloses, and manages Personal Data.
Users are people using any digital products or services produced/provided by the Company on the Platform
(hereinafter the “User” / “Users” or “you”).
The Platform is an Internet platform that hosts applications, games or any other digital products produced by
the Company (hereinafter the “Platform”).
Personal Data is information relating to an identifiable person that can be obtained by the Company when the
user is using digital products or services produced/provided by the Company (hereinafter “Personal Data”).
Aggregated and otherwise non-identifiable Personal Data is information that cannot be used to identify a User.
Personal Data Processing is an action performed by Controllers or Processors (under GDPR), including automatic
and non-automatic operations with Personal Data of Users.
Data Controller is an organization that collects Personal Data from citizens of the European Union.
Data Processor is an organization that processes Personal Data on behalf of the Data Controller.
Application is software developed by the Company that performs a specific function directly for a User.
Game is a game developed by the Company.
Our Company is committed to protect and respect your privacy. This Policy has been developed to inform you about the
ways we collect, process, use, and manage the information you provide in connection with any game or application or
any other digital products or services produced/provided by the Company (hereinafter referred to as “Products”
or/and “Services”). Please note that the scope of this Policy is limited only to information collected by the
Company through use of the Products. This Policy shall not apply to any practices of third parties that the Company
will neither own nor control.
We process your personal Data subject to your consent. Any use of the Products shall be construed as your
acknowledgement and agreement with this Policy and our terms of use specified below. If you do not agree to these
terms, please do not use the Service.
In respect of the use of Personal Data our Company complies with the regulations of the Russian Federal Law on
Personal Data (No. 152-FZ), enacted as of July 27, 2006 and (where applicable) 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, and repealing Directive 95/46/EC (General Data
Protection Regulation) (“GDPR”).
Please note that this Personal Data is collected automatically by third parties (controllers or processors under GDPR) due to the fact that you’re using our Products/Services:
The list of third parties collecting Personal Data under this paragraph include:
We may also cooperate with third parties (including, e.g. partners, technical contractors, payment services, analytics providers, search information providers), and may receive Personal Data from them as part of the service we provide to you, or for legal reasons and share Personal Data with such third parties. Such third parties will not collect Personal Data, except for the persistent identifiers (such as IDFA, IDFV, Advertising ID, or IP address) which are able to uniquely identify your device, but they do not identify you personally.
By accepting the terms and conditions of this Policy you agree that we may disclose any aggregated and non-identifiable Personal Data to third parties without restriction for any purpose.
Our Company collects Personal Data for some or all of the following reasons:
Pursuant to GDPR you have certain data subject rights among other things changing or deleting your Personal Data,
requesting access to your Personal Data and its rectification, obtaining restriction of processing your Personal
Data, asking for a copy of your Personal Data, objection to processing of your Personal Data.
Please note that we do not collect and store your Personal Data. Pursuant to paragraph 3 of the Policy your Personal
Data is collected automatically by third parties (controllers or processors under GDPR). If you wish to request
access to your Personal Data, to rectify your Personal Data, if you want to remove your Personal Data just send us
an e-mail request to: policy@projectfirst.ru. We will make every reasonable effort to help you and shall forward
your request to our partners (controllers or processors under GDPR) which may access your Personal Data and operate
under their own privacy policies. We will respond to all your requests within reasonable time.
We assure you that we will use your Personal Data in accordance with this Policy to the extent deemed to be
reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to
ensure security, integrity, accuracy and privacy of the information you have provided to us.
If you have any questions, comments, or concerns about this Policy, please contact our Company by email:
policy@projectfirst.ru.
Some of our Games has an option to personalize your advertising using software development kits (SDK) of Appodeal,
Admob, Yandex AppMetrica, GameAnalytics, OneSignal and other third-party companies, In particular, these SDK may
collect and process your Personal Data such as device identifiers, location data, demographic and other data to
provide you with relevant advertising. By consenting to this, you will also see ads that Appodeal and its partners
believe are more relevant to you.
You may opt-out of interest-based personalized advertising on mobile applications by checking the privacy
settings on your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based
ads” (Android). For personalized in-game offers opt-out, you may use the options provided in the Game settings.
At the same time some of our Games may use software development kits (SDK) of Yandex AppMetrica, GameAnalytics,
OneSignal and other third-party companies for analyzing players gaming experience and your gaming experience to
improve it. These SDK may collect and process your Personal Data such as device identifiers, location data,
demographic and other data in anonymous form to provide you with relevant playing experience to improve the quality
of the game.
If you ever change your mind, you may withdraw your consent from the Setting menu on your Android or iOS
device.
As we do not process or operate information on the age of Users of our Products, the Company may not been able to
prevent processing of the data of person under the legal age. We also do not intentionally collect personal
information on the age through our Products. If you are a parent or guardian of a child and you believe that we have
inadvertently received personal information about the child, please contact us and we will delete the information
from our records. If you are a parent of a teenager under 16 (or any applicable age in your country), we will seek
your consent, if you wish your minors to access the Products.
We also follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed
to protect the online privacy of children in Internet and therefore in our games and apps that are directed to
children. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the
Federal Trade Commission’s website of the United States of America.
If you believe that we may have unintentionally collected your child’s personal information without your prior
consent, you may contact us by e-mail: policy@projectfirst.ru
Parents who have registered their child to the our Games and Apps should understand that information, including but
not limited to a child's first name, last name's initial, country of residence and behavioral activity, may be
collected by third parties including, for example, analytics providers, search information providers.
Our Games and Apps may contain advertisements about third party products and services but in any case, we did
not permit behaviorally-targeted advertising to children in our Games and Apps where we have actual knowledge that
the user is under the age of 13.
The Company may change this Policy from time to time. Any such changes will be posted here in the present Policy, and we advise you to check back frequently to look for any updates or changes. We shall reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Policy will indicate the data it was last updated. Your continued use of our Platforms will acknowledge your acceptance of changes in our Policy.
Project First LLC
Registered address: 19-14 1st Spasonalivkovskiy pereulok, Moscow, 119049, Russia
Contact information:
https://www.projectfirst.tv/index.en.html
Email: policy@projectfirst.tv
If you contact us via e-mail, we will collect your name and e-mail address, as well as any other information
included in the e-mail, in order to respond you. We may only use your Personal Data submitted in your communications
to contact and respond to you.