EEA PRIVACY POLICY

As used in this Privacy Policy, “Moving Eye”, “We”, “Us” or “Our”, refers to Moving Eye, informacijske tehnologije, d.o.o., a limited liability company with its registered address Dalmatinova ulica 5, 1000 Ljubljana, Slovenia.

This Privacy Policy covers how we collect, use, disclose, transfer and store information received about users from the European Economic Area, Switzerland and the UK (collectively referred to as “Europe”) and/or information received about Europe users’ computing devices through their use of the Apps. 

We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

This Privacy Policy is part of and incorporated by reference into the Terms of Service (the “Terms”) governing the use of all “Moving Eye” branded software applications (the “Application/s”, or “ App/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or https://swampattack.com, and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with your information (including personal information) any time you are in contact with us or use the Applications or the Websites.

We take the privacy of our users and data security very seriously and believe in the right of our users to know which data is collected and for what purpose. We therefore strive to make our actions transparent and allow our users to control the collected data and remove it if they so wish, and we take all reasonable precautions to prevent unauthorized access to this data.

We value your privacy and will never sell your information to anyone without your knowledge and consent.

When accessing our website and/or using any of our Apps you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you are based in, you authorize Moving Eye to use your information in, and as a result to transfer it to and store it in the United Kingdom and any other country where Moving Eye, or any third party service providers acting on its behalf, operates. Privacy and data protection laws in some of these countries may vary from the laws in the country where you are based, but we will always take appropriate steps to safeguard the privacy of your personal information. 

Only when the transfer is based on one of the following safeguards, we will transfer your personal information:

1. If a country outside of Europe ensures an adequate level of protection in accordance with European data protection legislation.

2.  If we have entered into standard contractual clauses with our contractual partner that are adopted by the Commission of the European Union in accordance with European data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy rights. 

Please read this Privacy Policy in order to learn more about the data we collect, what we use it for and how we protect your privacy.

Collected information

We may collect any or all of the information that you give us together with data about your use of the website and applications, but we will primarily use the collected data to provide you with a satisfactory service and enhance your Moving Eye experience. We use information for (i) delivering and improving our services and products, providing updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the apps, and administering the apps; (ii) analytics and research in a way that we use your information for understanding and analyzing trends in connection with usage of the apps, gathering demographic information about user base, data about where download of our app was performed, and we might use created reports and analysis for the purpose of business intelligence; (iii) security in a way to use your data for enhancing the safety and security of our products and services; (iv)providing customer support to you and to respond to your inquiries; and (v) our legal obligation when we are required to do so by law. 

We use different SDKs from our business partners and they share collected information with us. For detailed information, see the Analytics section below. 

Collection of device and technical information

We might collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app and to personalize the content of the app.

We automatically obtain certain information about your computing device, including (i) IP address; Country or region; (ii) IDFAs, IDFVs, Advertising IDs; (iii) Language; Locale (specific location where a given language is spoken); (iv) Time zone, session start/stop time; (v) Network status (Wi-Fi, etc.), browser plug-in types and versions; (vi) User agent string (UA), platform, SDK version, timestamp; (vii) Our apps installed; (viii) Technical device information (e.g., device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, Android ID, Android Serial No); (ix) Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications); (x) Player identifier string (we collect player identifier string only upon your sign into Google Play Games Services or Apple’s Game Center). In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps. Older versions of our Apps may still obtain information such as UDID number and IMEI number. If you wish to prevent this, please update the App with the latest version available on the App Store.

Collection of classical personal information

We may also collect personally identifiable information about you (such as your name and surname, email address, birth year, player name and password), as well as non-personally identifiable information (such as age range and gender) that you provide us by contacting us directly. We might also collect the messages You sent to Us (such as chat logs and player support tickets). 

We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.

If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail to privacy@movingeye.games and your e-mail will be deleted from our database.

What is collected data used for

Our use of information collected from you                       

We use the information collected from you for delivering and promoting our services, for advertising, internal analysis and research to improve the services. You hereby allow us to collect, process and store the data as stated in this Privacy Policy. We use the information we collect about you/your computing device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

1.     Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Applications and the Websites, administering the Applications and the Websites, and customer communications, develop and improve the App and player experience, manage our relationship with you, provide social features as part of the App, customize your App experience, respond to your comments and questions and provide player support, provide you our offers in the App as well as in other websites and services, and by email, send you related information, such as updates, security alerts, and support messages, enable you to communicate with other players, create accounts and allow you to play our games and use the App, to operate, maintain and provide all the features and services found on the App now and in the future, verify and confirm payments, send you App-related communications, to provide support and to help you solve any technical difficulties.

2.     Analytics and research: Understanding and analyzing trends in connection with the usage of the Applications and the Website, auditing, learning about user behavior within the Applications and the Websites (how often you use the Application/Website, the events that occur within the Application/Website, aggregated usage, performance data etc.), gathering demographic information about our user base, data about where the Application was downloaded from. For information that can be treated as personal information in some legislation, we use only device identifiers. We use the data we receive from Third Party Social Network for internal analytics.

3.     Advertising: We offer our Apps for free or at low cost and in order to do that we need to share information we collect from you with our third party advertising partners that assist us in delivering advertisements to you. When you use our apps we rely on our legitimate interest to show contextual advertisements to you. Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent. When you use our Apps we show contextual advertisements to you. In order to enable advertising we allow our advertising partners to collect advertising identifiers that are considered as personal information under some data protection legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on an anonymized and aggregated basis, this means in a way that cannot be tracked back to your device. If you have consented to sharing of your personal information for the purposes of interest-based advertising, the advertisements you see are more relevant to you and are based on your app and device usage, online behavior and interests (this is commonly referred to as online behavioral or interest-based advertising). Learn more about sharing your personal information for the purposes of interest-based advertising in the “Who can show personalized ads to me?” Section of this Privacy Policy.

You have an option to withdraw or manage your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the App settings and clicking the “personalized ads” button and manage your preferences. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

You can find the setting for your mobile device by following the directions below or contact your device provider.

iOS DEVICE

Go to your Settings \> Select Privacy \> Select Advertising \> Enable the “Limit Ad Tracking” setting

Go to your Settings \> Select General \> Select About \> Select Advertising \> Enable the “Limit Ads Tracking” setting

More information about the iOS setting can be found here: https://support.apple.com/en-us/HT202074

ANDROID DEVICE

For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Settings app \> Google \> Ads > Enable “Opt Out of Interest-Based Advertising” 

4.     Game Notifications: We have two types of notifications in our Apps – local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server. We use such notifications to remind you about your activities within the App. You will receive such notifications only if you are subscribed to such notifications in the App. You can always unsubscribe from push notifications, please use the instructions provided below.

For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON. 

For Android: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.

When you decide to unsubscribe from such notifications, such notification tokens will be deleted from our database. 

5.     In-App Purchases:  Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store. Please review the privacy policy and terms of service of your app store. For more information on in-app purchases in Our Apps please see In-App Purchases Section of our Terms of Service.

Who can show personalized ads to me? 

Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent. Based on your consent we share information we collect from you that can be used to personally identify your device, e.g., persistent identifiers such as advertising ID, IDFA, IP address with our advertising partners and they can use such data for interest-based advertising. For example, they may attach the information gathered from our App to information gathered from other apps, websites, or via other services, and then build profiles, show you an ad based on such profile (for example they might know that device with your advertising ID has clicked on a sports ad within other publisher’s app and show to you a sports ad in our App). In addition, we may use and share such information with our advertising partners to target and optimize our advertising and promotions in our and other publisher’s apps.

We allow our advertising partners to show interest-based ads to you only if you have given the consent to the sharing of your personal information for the purposes of interest-based advertising.

Our advertising partners use different technologies for the purposes of interest-based advertising that process your personal information in different ways, so please review their data processing practices before you provide your consent to sharing your persistent identifiers such as advertising ID, IDFA, IP address and other information that may be personal to you for the purpose of interest-based advertising.

Please see the following list of advertising providers that are allowed to show interest-based advertising and review their data processing practices, including the technologies they use for the purposes of interest-based advertising:

–       Google(AdMob) https://support.google.com/admob/answer/7665968; https://support.google.com/dfp_premium/answer/9012903; https://support.google.com/admob/answer/2753860#Interest_based

–       Facebook Audience Network https://www.facebook.com/about/privacy/update?ref=old_policy

–       Facebook Ad Campaigns https://www.facebook.com/about/privacy/update?ref=old_policy

–       AdMost https://resources.admost.com/privacy-policy/

–       Unity Ads https://unity3d.com/legal/privacy-policy

You can withdraw your consent to sharing your personal information for the purposes of interest-based advertising at all times by going to the app settings and clicking the interest-based ads button where you can manage your preferences. 

When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

Storing of information

We store your information for as long as needed to provide you with our services and for as long as we are legally obliged to do so. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services and in any event no later than five (5) years after your interaction with our products has ceased.

We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Location information is stored to the extent and for the duration necessary for the provision of a value-added service. Direct marketing and provision of value-added services information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

Deletion of information

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

Protection of personal information

We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Sharing your personal information 

Partners working for us

We have partners who perform services on our behalf,such as data storage, technical or customer support and data analytics. Processors are contractually required or bound by law to protect your data and are only permitted to process such data in accordance with our agreements with them.

Other companies and public authorities.

Based on your consent or if so required by law we may supply or disclose your data, including personal information to third parties.

We cannot provide all services necessary for the successful operation of our products by ourselves. We must therefore share collected information with third parties (collectively referred to as “Partners”). The only personal information we collect from users for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, IP address). Such persistent identifiers are used and shared with third parties only to place contextual advertisement (including frequency capping, fraud prevention and tracking for the attribution and billing purposes), to authenticate users of or personalize the content on Apps, to maintain or analyze the functioning of the Apps, personalize the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.

Information collection relating to children

We consider ourselves to be oriented towards the general public and even though our products and services are not directed to, and we do not knowingly collect personal information from, children under the age of digital consent according to EEA data protection legislation, with the sole exception of persistent identifiers as described herein. If we learn that we have collected personal information of a child under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@movingeye.games. 

Opt-out

You are always free to opt out from the future collection of your personal information by Moving Eye in accordance with this Privacy Policy by uninstalling all the Applications from each of your computing devices and discontinuing use of the Websites.

Request user data deletion

When you install and use “Moving Eye” mobile applications, we can collect and process some of your data for different legitimate purposes.

You will find below explanations regarding the reasons why we may collect data.

Why is data collected?

“Moving Eye” and its third-party partners collect data: 

The third-party partners that “Moving Eye” will share the data with are: 

Data deletion requests

To delete user data collected by “Moving Eye”, please reach out to “privacy@movingeye.games”.

If you also want to request the deletion of the data that may have been collected about you or your device by our third-party partners that are acting as independent data controllers, you will find below the contact for each partner and the link to the relevant section of their privacy policies:

Third Parties terms of service

We may provide links and/or connections to third-party websites or services from our website and our Apps. We are not responsible for the practices employed by websites or services linked to or from Moving Eye website or applications, including the information or content contained therein.

Please remember that when you use a link to go from the Moving Eye website movingeye.games or applications to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those linked on our website or in our applications, are subject to that third party’s own rules and policies. We are not responsible for the privacy practices or content of these third-party sites.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Third party social networks 

Some of our Apps enable you to connect to third party social networks, to share the content you created within the Apps on such third party social networks or to participate in leader boards or multiplayer apps. If you connect to a third party social network, such as Google Play Games Service or Apple Game Center, you will be able to use your account to log in on multiple devices and to synchronize progress across those devices. If you use Third Party Social Networks to participate in game related activities, such as in leader boards and multi-player games, you share your information with other players and Third Party Social Networks (for example scores, rankings and achievements).

Third party terms and conditions

Our Apps may contain links to third party websites, products, or services. For example, the Apps may feature offers from third party advertisers or the ability to engage in transactions with such entities. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

Support

If you have further questions or any concerns regarding privacy with Moving Eye and have already signed up in Moving Eye, the best way to get the answers is to contact our DPO, Blaž Porenta by sending an email to:privacy@movingeye.games (subject ‘DPO”). Should you have any concerns or complaints our DPO is not able to solve, you have the right to lodge a complaint with a supervisory authority, Information Commissioner’s Office, by telephone on 0303 123 1113 or contact us via live chat at https://ico.org.uk/global/contact-us/ .

If you submit a support request, we may receive your email address and other information you provide related to your support request (“Support Information”). We use Support Information only to provide support to you. We don’t rent, sell or share your email address unless we have your express consent and in the following circumstances:

  1. We may share your Support Information with our support providers, but only for the purpose of providing support to you.
  2. We may share your email address and Support Information to enforce compliance with our mobile application license agreements and user agreements, to respond to legal requirements, when legally required to do so, and at the request of governmental authorities.
  3. We may share your email address and Support Information with a successor entity or in connection with a corporate merger, consolidation, sale of assets or other corporate reorganization provided that use of your email address is otherwise in compliance with this Privacy Policy.

Your data protection rights

You have the following data protection rights:

1. To access, correct, update or request deletion of your personal information. You may do so by contacting us at privacy@movingeye.games

2. To object to the processing of your personal information ask us to restrict processing of your personal information or request portability of your personal information. You may do so by contacting us at privacy@movingeye.games

3. If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us using the details at privacy@movingeye.games. 

4. You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

You can control and limit the type of personal information we collect and process about you in a number of ways. For example, you can disconnect your social media account(s) from our games or control your social media privacy settings to limit the information shared with us. You can also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You can also limit or disable the use of cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Security

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the amended version will supersede this version of our Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. We will take reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.

If we make changes in the way we use your email address, we will notify you in advance of posting by email. Such modifications will become effective on the date set forth in the email.

English language

By accepting this Privacy Policy you acknowledge that you are proficient in the English language, or have consulted with an advisor who is sufficiently proficient in English, so as to allow you to understand the terms of this Privacy Policy. 

Privacy questions

For general information please feel free to contact us via contacts provided on https://movingeye.games and for privacy question via privacy@movingeye.games

Version 1.1. 

Last revised in January 2024

Moving Eye d.o.o.

info@movingeye.games

Privacy | Legal | 2019-2024 Moving Eye d.o.o.