Privacy & Policies

INFORMATION ABOUT PROCESSING OF PERSONAL DATA / PRIVACY POLICY

This information on the processing of personal data is addressed to the customers (players) of Flyboys Games s.r.o., who are primarily users (“Players”) of our software products (“Games”). Our company is committed to the proper processing of its customers’ personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council (General Data Protection Regulation, referred to as “GDPR”) as well as California’s Assembly Bill No. 375 (California Consumer Privacy Act, referred to as “CCPA”) and relevant Czech legislation.

Please, follow the text below to acquaint yourself with the processing of your personal data. The purpose of this document is to provide you with a clear understanding of why we process your personal data, how we process it, your rights in relation to this processing, and other relevant information.

CONTENT:

A. Terms related to the process of assessment of personal data

B. Who is the controller of your personal data?

C. Which personal data are we processing?

D. From which source are we collecting your personal data?

E. What are the main purposes for processing your personal data?

F. To whom can your personal data be provided?

G. Where are your personal data being processed?

H. How long do we keep your personal data?

I. Profiling and the process of an automated decision

J. Your rights related to processing of your personal data

K. Inappropriate behavior and rule violations

L. How can you get more information and enforce your rights?

FULL POLICY

A. Terms related to the process of assessment of personal data

Please familiarize yourself with the basic terms listed in this document, which can be useful for a better understanding.

Personal data – any information that relates to an identified or identifiable individual, e.g., name, surname, date of birth, telephone number, e-mail address, user ID, IP address, etc.
Affected person / Customer – an individual to whom the personal data are related.
Processing of personal data – an operation or set of operations with personal data, e.g., collecting, recording, organizing, storing, changing, using, providing to third parties, or deleting.
Controller / Service provider - an individual or legal person who determines the purpose and methods related to the processing of your personal data; this competence can be transferred to an intermediary.
Intermediary – an individual or legal person, a public authority, an agency, or another subject that processes personal data for the controller and in his name.
Purpose – a reason why personal data are being processed by the controller.
Special categories of personal data – sensitive personal information defined by its specific character, e.g., health or biometric data to identify the person.
Authorized (legitimate) interest – an interest of the controller or any other subject that results in the need to process personal data, if it prevails over the interest of the affected person/customer.
Profiling – any automated processing of personal data, which consists of the use of personal data to evaluate certain personal aspects of the affected person/customer.
Recipient - an individual, legal person, public authority, or any other subject to whom personal data are provided.

B. Who is the controller of your personal data?

The controller of your personal data is Flyboys Games s.r.o. with registered residence: Chomutovská 215, Klášterec nad Ohří, Czech Republic, IČO: 24689599, registered in the Commercial Register of the District Court KSUL Krajský soud v Ústí nad Labem, insertion no. C 35979 (hereinafter referred to as “Company”). The Company determines the purpose and methods of processing your personal data.

Basic information about Company: Chomutovská 215, Klášterec nad Ohří, Czech Republic.

For questions concerning the processing of your personal data by the Company, feel free to contact us via support@flyboys.games.

C. Which personal data are we processing?

The Company collects and processes personal data necessary to provide you with products and services or, where appropriate, to protect itself and its legitimate interests. The Company primarily processes the following categories of personal data about its customers (Players):

Identifiers: name, surname, age, gender, e-mail address, unique identifier of a player (User ID)
Internet or other similar network activity: Access history and information on your interaction with the Games, IP address, Cookies files, in certain situations also your Facebook friends and other traffic data (IP address, device model, CPU architecture, OS version, etc.)
Geolocation data: country
Information you provide: the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to our games, use our developer tools (including creating and publishing games and other content), complete surveys, or contact us through player support requests or customer service.

The listed categories are also the types of personal information that the Company has collected from its customers within the last twelve (12) months.

D. From which source are we collecting your personal data?

The Company collects your personal data primarily from you, especially when accepting the mutual (contractual) agreement about software use (EULA), completing surveys, or contacting us through player support requests or customer service. Your personal data can also be collected from other subjects – third parties, e.g., Facebook, Google, Apple, Amazon, Steam, Samsung, WizQ, but only based on your authorization provided to these subjects to grant your data to the Company.

E. What are the main purposes for processing your personal data?

For the purpose of concluding and fulfilling the contract

Due to the process of conclusion and fulfillment of the contract, the Company processes your personal data to provide access to the software (Games) of the Company for the user (Player), to provide player support and improve the quality of services provided by the Company, necessary for the proper function through updates and enhancements, enhancing the game environment, and providing new functionalities. For this purpose, the Company may follow your interactions with the Company, monitor different areas of your interest, and use your information to personalize our communication with you, including offering in-game surveys. The collected data can also be used for purposes of optimizing and improving the content of services provided to you by the Company as part of the software and to detect potential malfunctions and errors.

Collected and processed data by the Company may also be used to compile and publish general statistical reports to extend and customize services provided to players, appealing to their preferences. These data do not contain information that could lead to the identification of any individual.

Data collected by the Company for the designed purposes are processed based on the contractual agreement between the Company and end-users – Players – in the form of defined licensing terms and agreements about the use of products and services provided by the Company (EULA).

The EULA is a contract in accordance with Article 6, point 1, letter b) GDPR for determining the legal basis for processing personal data.

For the needs of the above-defined purposes, the Company processes personal data mentioned in Section C of this Policy, as well as the following personal data of the players:

Registration and authentication via Apple, Google
Direct registration: e-mail address and other traffic data

For the purpose of direct marketing

Under the conditions of its software (game), the Company also uses the functionality of so-called “banners,” through which the player is offered “gems” (a specific kind of payment under the conditions of each game). This menu is displayed to the players while using software (playing the game) as one of the options within the game settings or menu. The player can purchase additional options, extensions, accessories, or other functionalities within the terms of a specific game through these menus.

Based on a similar approach, various limited offers (so-called “premium items”) are promoted to purchase special editions of particular elements under the conditions of the software.

These activities represent the form of direct marketing used by the Company (in relation to aforementioned regulations) oriented at specific players and addressing their potential needs.

The Company implements these activities only under the conditions of the software (game) itself. The use of these activities does not lead players to the process of purchase, nor does it limit them in common use of the game.

According to GDPR, the legal basis for processing your personal data in terms of this form of marketing is the legitimate interest of the Company in accordance with Article 6, point 1, letter f) and in accordance with section 47 of the GDPR.

For the direct marketing purposes, the Company processes the following personal data of players:

E-mail address
User ID
IP address

In-App Purchases

All in-app purchases must be made through the official platforms provided by Google or Apple. Any purchases made through unofficial platforms will be considered a violation of the terms and may result in the termination of the player's account.

F. To whom can your personal data be provided?

We process your personal data to the fullest extent possible internally within the Company. Your personal data is provided to other subjects only when necessary to achieve the purpose of processing.

We do not sell your personal data to other businesses. Your personal data might, in some cases, be disclosed to and processed by our intermediaries for business purposes (see below); however, personal data is not shared

for monetary or other valuable consideration.

In the preceding twelve (12) months, we have not sold personal data. Our policy is that we do not and will not sell the personal data of our customers (Players).

Intermediaries

The Company cooperates with external subjects, which process personal data under the name of the Company (“Intermediaries”). Intermediaries process personal data based on a contract between the Company and the intermediary. Current company intermediaries include:

- Google Cloud Services (GCS)

- Payment portals: Google, Apple

- Customer support: Youtrack

The purpose of intermediaries’ services is to collect, store, and provide data necessary for the basic and distributed operation of services provided by the Company within the offered software, as well as providing the basic infrastructure for the operation of specific functionalities and software components.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to our intermediaries for business purposes:

- Identifiers

- Internet or other similar network activity

- Geolocation data

Public authorities

Your personal data can be provided to public authorities in case of imposition by law or if this advance is necessary for the fulfillment of legal obligations. Public authorities include courts and authorities involved in criminal investigations, etc.

G. Where are your personal data being processed?

Your personal data is processed on servers within cloud services provided by third parties based on a contract between the Company and the particular third party. These companies are considered intermediaries from the perspective of personal data processing.

H. How long do we keep your personal data?

The Company processes your personal data for as long as necessary for the duration of the EULA’s contractual relations.

The Company applies the principle of minimization, which means that after the processing duration expires, the personal data will be anonymized or deleted from databases and information systems of the Company, at the latest ten years after the termination of a contractual obligation of EULA.

I. Profiling and the process of an automated decision

The Company does not implement automatic individualized decision-making, including profiling, that could cause legal effects on you.

J. Your rights related to the processing of your personal data

You have the following rights concerning the processing of your personal data:

Access to personal data: You have the right to request information on whether we process personal data about you and request access to this personal data. You have the right to know why we collect the personal data, how we process it, what kind of personal data we process, which organizations receive the personal data, and how the personal data is stored.
Objection to the processing: You have the right to object to the processing of your personal data if the processing is carried out due to the legitimate interest of the Company. If the Company cannot demonstrate that there are necessary and legitimate reasons for processing that prevail over your interests, rights, and freedoms, or reasons for the demonstration, application, or defense of legal requirements, the Company will end processing based on your objection without undue delay.
Correction of personal data: You have the right to demand the correction of inaccurate or incomplete personal data, limitation of our processing, and completion of incomplete personal data. The Company is obligated to correct or complete your personal data without undue delay based on available technical options.
Deletion of personal data: You have the right to demand the deletion of your personal data without undue delay. However, the Company may deny your deletion request if retention of your personal data is necessary for the purposes for which the data was collected.
Restriction of processing: You have the right to request that the processing of your personal data is restricted. There is a risk that we will be unable to provide you with our services during the time the processing is restricted.
Portability of personal data: Under some circumstances, you have the right to access your personal data in a structured, commonly used, and machine-readable format (data portability) and transmit those data to another controller (if technically possible). This right is limited to personal data you have provided us with if it is processed to fulfill a contract with you or based on your consent.
Non-discrimination: We will not discriminate against you for exercising any of your rights. Unless permitted by the CCPA, we will not a) deny you use of our services, b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, c) provide you with a different level or quality of services, d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

K. Inappropriate Behavior and Rule Violations

Flyboys Games s.r.o. maintains a strict policy against inappropriate behavior and violations of our rules, including but not limited to:

Modification of Game Code: Any attempt to modify the game code to gain an unfair advantage will result in the immediate suspension or termination of your account.
Unauthorized Purchases: All in-app purchases must be made through the official platforms provided by Google or Apple. Any purchases made through unofficial platforms will be considered a violation of the terms and may result in the termination of the player's account.
Cheating and Exploiting: Using cheats, hacks, or any other means to manipulate the game's mechanics or other players' experiences is strictly prohibited and will result in account suspension or termination.
Harassment: Any form of harassment, abusive language, or behavior towards other players or staff members is unacceptable and will lead to disciplinary actions, including account suspension or termination.

Violating any of these rules may result in the termination of your account without prior notice. Flyboys Games s.r.o. reserves the right to enforce these rules at its sole discretion.

L. How can you get more information and enforce your rights?

If you have questions about the processing of your personal data or want to know more information, you can contact us by writing to Flyboys Games s.r.o., Chomutovská 215, Klášterec nad Ohří, Czech Republic, or by e-mail at support@flyboys.games.

This document will be regularly updated. Status as of 1.1.2023.