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Privacy policy

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Privacy policy

THIS TEXT IS OF AN URGENT IMPORTANCE, READ IT CAREFULLY PRIOR USING THE SOFTWARE. YOU ARE FREE TO DECLINE THIS PRIVACY POLICY AND IF YOU DO SO, PLEASE, DO NOT USE THE SOFTWARE AS IT OTHERWISE WOULD MEAN THAT YOU ARE CONSENT TO THIS PRIVACY POLICY. WE MAY ASK YOUR EXPLICIT CONSENT FOR PROCESSING YOUR PERSONAL DATA IF IT IS NECESSARY IN YOUR DATA REGION, BUT MAKE SURE THAT YOU FULLY UNDERSTAND WHICH DATA WE PROCESS.

Privacy Policy

  1. Introduction

    1. Last Level, LLC (“Last Level”, “LL”, “We”) provides software applications, games and websites (Products). At Last Level the privacy and security of our Users are of paramount importance. Last Level is committed to protecting the data you share with us. This privacy policy explains how Last Level processes information that can be used to indirectly identify an individual (“Personal Data”) collected through use of its Products.

    2. For the purposes of this policy, Last Level defines the term “User” as an entity with which Last Level has an established relationship, the term “Customer” as any User who makes purchases within our Products.

    3. Any information stored on Last Level’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Last Level implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. We encrypt that information using secure socket layer technology (SSL), and NaCl encryption to protect your stored data and data within our Products.

  2. Collection and use

    1. PERSONALLY IDENTIFIABLE INFORMATION (PII)

      1. Last Level collects personally identifiable information (“PII”) when you choose to provide it to us. PII is any information that specifically identifies or locates a particular person or entity. We receive and store any PII you provide to us. The types of PII collected may include your name, postal address, telephone number, and email address. For example, you may choose to send PII about yourself in an email, by completing an online form on the Websites, or by signing up for our service or e-newsletter. You may also provide us with PII in order to setup an account with us. Last Level uses this information for our reasonable business purposes, including to contact you to respond to your inquiry, to provide the service requested. We may share Client PII with partners as necessary to improve the Service. Once obtained, Last Level will store your PII for as long as needed to provide services and for a reasonable time thereafter for record keeping purposes.

      2. Last Level may collect, record and analyze information of Users to its Products. We may record your IP address. Last Level may add information collected by way of pageview activity. Furthermore, Last Level may collect and process any Personal Data that you volunteer to us in our Products’s forms, such as when you sign up for information and newsletters. If you provide Last Level with your social media details, Last Level may retrieve publicly available information about you from social media. Such Personal Data may comprise your IP address, Geolocation data (based on your IP address), your email address, interest in Last Level products, as well as information as to the type of relationship that exists between Last Level and yourself.

      3. We DO NOT collect information about: age, gender, political thoughts, religious beliefs, phone number etc, unless User would like to share such information with us directly.

    2. NON-PERSONALLY IDENTIFIABLE INFORMATION

      1. Last Level also collects non-personally identifiable information (“Non-PII”) from our Products. Non-PII is pseudonymous information that cannot by itself be used to specifically identify a particular person or entity, and may include your purchases, numbers of Users, completed tasks or quests, your in-product achievement, ranking score,  length of time spent using Products, actions performed within our Products, statistics, smartphone type and model, usage habits, the time/date of your visit to the Products and your device’s operating system and its version. We may use a third-party analytics provider to help us collect and manage this data. We use this information to help manage and improve the Products.

      2. By using our software, you consent to the collection and use of your non-personally identifiable information.

      3. If you don’t want us to keep and process such information, please contact us directly to delete your account and all the data we collected about you. You may not use our products after that.

    3. Behavioral Targeting / Re-Targeting:

      1. We partner with third parties to display advertising on our Sites and manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools (to learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org or if you are located in the European Union you may use the resources at http://www.youronlinechoices.eu/. If you access the Optimizely Service or Sites on your mobile device, you may not be able to control tracking technologies through the settings. Please contact or consult the respective privacy policies of such ad servers or ad networks for more information.

    4. Purpose of processing PII

      1. Last Level uses the collected data to communicate with Users, to customize content for Users, to show ads on other Products to Users, to make special offers for specific Users based on performed actions of such Users, and to improve its Products by analyzing how Users navigate our Products.

    5. Sharing PII

      1. Last Level may also share such information with third-parties in order to provide a requested service or transaction or in order to analyze the User behavior on its Products.

      2. We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Last Level or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

    6. Ads

      1. Please be aware that while using our Products, Users can follow links to other sites and/or software applications that are beyond our sphere of influence. Last Level is not responsible for the content or privacy policy of these other sites and/or software applications. For information on how our selected third parties may use your information, please see their privacy policies.

        1. Unity

        2. Ironsource

        3. Chartboost

        4. Applovin

        5. Google

        6. Facebook

        7. Adcolony

    7. Collection of User data

      1. During a User’s registration, you provide information such as an Identification Data (ID) collected from the service provider, such as Google Play or App Store and other platforms where our Products are located. This information is used by Last Level to identify the User and provide them with support, services, mailings, sales and marketing actions and to meet User License agreement obligations.

      2. Please, pay attention, you cannot use our Products without having an authorised account in Google Play, App Store or any other platforms where our Products are located.

      3. Last Level Users can at any time reach us out to with a request to edit, delete and update personal data. Last Level. Last Level will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

    8. Products Users

      1. If you are a user of our Products, then this section is relevant for you. By using our software, you consent to the collection and use of your PII as described herein. If required by applicable law, we will seek your explicit consent to process PII collected on this Products or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your PII, the use of the Products may be subject to restrictions.

  3. What Happens In The Event Of A Change Of Control

    1. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Optimizely Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

  4. Geographical location

    1. Last Level offers a number of data regions. A Last Level “Data Region” is a set of data centers located within a defined geographical area where User data is stored. Personal Data is not transmitted between Data Regions. For Last Level Users with accounts located in Last Level’s European Data Region, all Personal Data is processed in the EEA. For Users with accounts in the Data Regions: United States of America (US) and Canada, all Personal Data is processed solely in Data center in Canada. For Users with accounts in our Asia Pacific Data Region, all Personal Data is processed in Singapore.

  5. Processing and collection

    1. Processing in the European Economic Area (EEA)

      1. For Users with accounts located in Last Level’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (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, known as the General Data Protection Regulation (GDPR), and Last Level’s processing will take place in accordance with the GDPR.

    2. Controller

      1. Last Level processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR: The Last Level entity which you as a User entered an agreement with when using Last Level’s platform, will be the Controller for User data, as outlined above in “Collection of User data” section. Last Level adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, Last Level processes all data provided by its Users with accounts in its European Data Region, in the European Economic Area (EEA) only. All data collected by Last Level Users through Products will be stored exclusively in secure hosting facilities provided by OVH, . Last Level has a data processing agreement in place with its provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

      2. Processing in the United States Of America (US): For Users in the l US Data Region, Last Level processes data solely in data centers located in Canada. Last Level has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the User’s data in Last Level’s possession. Last Level will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

      3. Processing in Canada: For Users with accounts in the Last Level Canada Data Region, Last Level processes data solely in data centers located in Canada. Last Level has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in Last Level’s possession. Last Level will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

      4. Processing in other regions: For Users with accounts in our Asian Pacific Data Region, Last Level processes data solely in data centers located in Singapore. Last Level has adopted reasonable physical, technical and organizational safeguards which substantially mirror the EU safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Users data in Last Level’s possession. Last Level will promptly notify the User in the event of any known unauthorized access to, or use of, the User’s data.

  6. Retention and deletion

    1. Last Level will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Respondent data, Last Level’s Users have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Respondent data, Users with an active account will therefore have the responsibility to delete data when required. When a user’s account is terminated or expired, all Personal Data collected through the platform will be deleted, as required by applicable law.

  7. Acceptance of these Conditions

    1. We assume that all Users of our Products have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our Products and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of Last Level Products and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

  8. DPO and complaints

    1. Last Level’s Data Protection Officer: Last Level has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

  • Last Level

  • Attn: Data Protection Officer

  • address

  • Saint-Petersburg

  • Russia

  • dpo@ll-games.com

9.       For Further Information

If you have any further questions regarding the data Last Level collects, or how we use it, then please feel free to contact us by email at: legaldepartment@ll-games.com, or in writing at: address - Saint-Petersburg, Russia.