"Crates and Cannons" The Privacy Policy

Who we are

Ingsoftware LCC Niš, Tolstojeva Str. No. 44, 18000 Niš, the Republic of Serbia (hereinafter just Ingsoftware or Company) is a full-cycle development agency and the ultimate technology partner for startups.

We have offices on three major continents and pride ourselves as a tech force of 85 software engineers, UX designers, managers, and advisers that delivers end-to-end professional and transformative IT services.

More information about us you may find here: https://www.ingsoftware.com.

The person in charge of data processing within our Company:
Ivana Bjelica,
ivana.bjelica@ingsoftware.com,
+381 60 0777838.

Scope of the privacy policy

This Privacy Policy describes and applies only to:

• data collection by using "Crates and Cannons" (hereinafter the Game and the App);
• the use and sharing of information collected on and after the date that this Privacy Policy is posted.

ABOUT DATA PROCESSING IN GENERAL

By downloading and starting to use our game, we are starting to process some of your personal and non-personal data.

Collecting is the basic form of the processing of your data, but at the same time, we are transferring your data as well.

Regarding the processing of your data, Ingsoftware is the controller, but we don’t do that by ourselves.

We are processing your data by using the services and tools of our associates.

Those are the processors in light of the processing of your data.

Here is the full list of the processors:

• Exit Games Inc. (USA) and Exit Games GmbH (Germany), which operate as one entity, commonly know as Exit Games;
• PTC Inc. (USA).

We have concluded the standard Data Protection Agreement (DPA) with Exit Games, and you may ask privacy@photonengine.com for a list of our sub-processors that Exit Games involves.

Also, we have accepted „PTC Data Processing Terms & Conditions“, which you may find here , and the „PTC Inc. Sub-Processor List“ you may find here.

INFORMATION THAT WE COLLECT

When you use the App, we automatically receive and record data from your mobile device and network connection, including:

• the IP address of the end-user device – IP address of your device;
• user id (automatically generated);
• the device model identifier;
• operating system identification;
• network signaling;
• date and time you use the Service;
• performance of the Service; and
• your feature use in our App.

When You install our Game, you will be asked to grant access to your mobile device’s camera. Your permission to access these features is needed for the Game to function properly. If you grant such permission, we may collect information about your usage of these features.

COLLECTION PURPOSES

We use the data we collect for the following general purposes:

• to ensure an error-free and comfortable usage of our Game;
• to administer, protect and improve our Game.

LEGAL BASIS FOR DATA PROCESSING

The above-mentioned data will be processed on the legal basis of LEGITIMATE INTEREST (Art. 6. para. 1. sentence (f) of GDPR - General Data Protection Regulation).

Our legitimate interest follows the data collection purposes listed above.

RETENTION PERIOD

We will retain personal data only for as long as it is necessary in relation to the purposes for which they were collected.

DATA INTEGRITY

We will take reasonable steps to ensure that your personal data is reliable for its intended use, accurate, complete, and current.

WHERE WE STORE DATA

Data that we are processing may be stored in various locations, including, in the United States of America, Asia, the European Economic Area, or other locations. It may be processed by staff operating outside the European Union who work our processors.

TRANSFER AND SHARING OF DATA

Data that we are processing may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if one or more of our processors’ servers are from time to time located in a country outside the EEA. If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

We do not share your data with others, except as follows. We share your data within our processors and its affiliates wherever they may be located. We also may share your data with third parties who process the data on our behalf for the purposes outlined in this Policy, with our instructions and provide appropriate technical and organizational security measures. We may also share your data as required by law or in the interest of protecting or exercising our or others' legal rights, e.g., without limitation, in connection with requests from law enforcement officials and connection with court proceedings. We may share or transfer your data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Finally, we may also share your data information where You have permitted us.

YOUR RIGHTS REGARDING DATA PROCESSING

You have certain rights relating to your personal data, subject to local data protection laws.

Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:

• to access your personal data held by us (right to access);
• to rectify inaccurate personal data and, taking into account the purpose of processing the personal data, ensure it is complete (right to rectification);
• to erase/delete your personal data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
• to restrict our processing of your personal data, to the extent permitted by law (right to restriction of processing);
• to transfer your personal data to another controller, to the extent possible (right to data portability);
• to object to any processing of your personal data carried out based on our legitimate interests (right to object);
• not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"), but Automated Decision-Making currently does not take place within our Game; and
• to the extent we base the collection, processing and sharing of your personal data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

If you wish to exercise these rights, please see the section „Contact Us“.

We will respond to your request consistent with applicable law. To protect your privacy and security, we may require you to verify your identity.

CHILDREN’S PRIVACY

Children are not allowed to use the Game, and we do not collect personal data from them.

We define “children” as follows:

• residents of the EEA - anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence;
• residents of other regions - anyone under 13 years old.

AMENDMENTS

This Privacy Policy may be amended from time to time.

Any changes we may make to our Privacy Policy in the future will be publicly announced and published.