Privacy Policy

Last updated October, 5th 2019

The data controller is Harutyun Lazyan, individual borin in Armenia on 1999 February 15th, having registration address in Armenia, Yerevan, Malatia-Sebastia, Oganov Street 16, Apt.14. 

Protection of your personal data is fundamental to us. This confidentiality policy outlines information pertaining to the manner in which we collect a process this data.

"Personal data" or "Data" shall mean any information relating to an identified or identifiable natural person.

"Data controller" shall mean the person that determines the purposes and means of the processing.

Remit of the personal data protection policy

When you install and use Harutyun Lazyan's 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.

What data is collected?

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications.

  • Identity-related data: for some of our applications, we are likely to collect data from your Facebook account, when you

    login

    using Facebook connect: Public profile (surname, forename, age, gender, email address, profile photos, hobbies), friend list

  • IDFA publicity identifiers (for IOS devices) and GAID (for Android devices)

  • Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the publicities we display (for instance, time spent on these, potential clicks)

  • Data pertaining to your geographical position (IP address)

We are also likely to use cookies which correspond to small files containing letters and figures downloaded onto your device when you access our applications.

Why is data ollected?

Harutyun Lazyan and its third-party partners collect data:

  • To provide you with the services you asked for
  • To run analytics and understand how users interact with our product and services in order to continuously improve it

The third-party partners that Harutyun Lazyan will share the data with are:

  • GameAnalytics
  • Facebook Analytics
  • Voodoo

Purposes of processing UNDERTAKEN by Harutyun Lazyan and legal basis for processing

Data collected by Harutyun Lazyan is used to:

  • Provide our applications

  • Guarantee use and improvement of our applications

  • Develop new applications

  • Understand your centers of interests and, thanks to this profiling, propose you targeted and relevant advertisements (SDK advertising),

  • Make statistics on your use of the games, including the number of games played, your duration of use or the advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).

  • Communicate with you, notably when you contact us by any means whatsoever

We collect the data listed hereinabove, in whole or in part, only once we have your express consent for the purposes for which they are to be processed, through a pop-up in our applications.

At any time you can withdraw your consent from the "Settings" page in our various applications.

Term of data storage

Harutyun Lazyan stores your personal data for a maximum duration of 13 months after collection. Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature whatsoever.

Data transfer

In such instance as your Data is transferred outside of the European Union, we ensure that:

  • the personal data is transferred to countries

    recognised

    as offering an equivalent level of protection.

  • Personal data is transferred via certified entities under the Privacy Shield.

  • For personal data transferred outside of countries

    recognised

    by the National Data Protection Authority (CNIL) as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of template contractual clauses.

Personal data concerning children

Harutyun Lazyan does not knowingly collect any personal data concerning children under 15 years old.

Your rights concerning data collected

8.1. Your rights

You have all of the following rights concerning the data we collect:

  • Right to confirmation of the existence of a data processing

You are entitled to obtain from the controller confirmation as to whether or not data related to you are being processed.

  • Right to access your Data

You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data. This right also includes that of receiving a copy of data processed.

  • Right to request rectification of your Data if incorrect.

You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect, incomplete or obsolete.

  • Right to request deletion of your Data

You are entitled to request deletion of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

  • Data is no longer necessary in light of the purposes for which it is collected or processed in any other manner;

  • you withdraw consent over which processing is based, and there is no legal basis for processing;

  • you object to processing and there is no overriding legitimate ground for processing;

  • you consider that your data has been processed illicitly;

  • your data should be deleted to respect a legal obligation.

  • Right to limit processing

You are entitled to request that the data controller limit the use of your data solely on those grounds for which provision is made by applicable regulation and in particular when:

  • you object to the accuracy of your Data;

  • you consider that processing is illicit and you object to deletion of your data;

  • data is still required for exercising or defending your rights in court even though Harutyun Lazyan no longer requires this data,

  • The right to object to processing by withdrawing your consent (with it being reiterated that this withdrawal may not harm the legality of processing based on the consent granted prior to its withdrawal),

  • The right to benefit from data mobility

You are entitled to reclaim your data provided to Harutyun Lazyan, in a structured format, commonly used and machine-readable, and the right to transfer this data to another data controller, for instance so as to change service provider.

  • Post-mortem guidelines

If you consider that Harutyun Lazyan has defaulted in respect of its obligations in light of your personal data, at any time you may issue a complaint or make a claim to the competent authorities.

Terms for exercising rights

You may exercise the aforementioned rights by sending an email to the following address: newgo.help@gmail.com.

Due to the obligation of security and confidentiality in Data processing incumbent upon Harutyun Lazyan, you are hereby informed that your request will be processed subject that you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

Harutyun Lazyan will determine whether this is admissible or not within one month following receipt of the claim. In such instance as it is deemed admissible, Harutyun Lazyan will provide all information requested or implement the rights claimed within the aforementioned deadline.

If, given the complexity of the claim or the number of requests received, the aforementioned deadline cannot be respected, Harutyun Lazyan will notify you prior to expiry of this deadline, of this deadline being pushed back by a maximum of two months following its decision.

Harutyun Lazyan hereby notifies you that it will be entitled, where applicable, to object to any requests which are clearly abusive (in their number, repetitive nature, or systematic).

Data deletion requests

To delete user data collected by Harutyun Lazyan, please reach out to newgo.help@gmail.com.

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:

  • GameAnalytics:
    • email: privacy@gameanalytics.com
    • privacy policy: https://gameanalytics.com/privacy/#6-changing-or-deleting-your-information
  • Facebook Analytics:
    • email: none, please refer to the privacy policy
    • privacy policy: https://www.facebook.com/policy.php

  • Voodoo:
    • Voodoo does not collect any of your personal data, and only provides an SDK package to retrieve the data collected by the above mentioned partners. You can still contact them to request the deletion of their accesses to the partners' interfaces.
    • email: dpo@voodoo.io

Personal data security

We take all necessary security measures so as to prevent as far as practically possible any alteration or loss of your data or any unauthorised access thereunto.

In such instance as we should be aware of any illegal access to personal data concerning you and corresponding to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if this fulfils a legal requirement.