1. Introduction and Overview

This Privacy Policy describes how Zenova Interactive OOO (“Zenova,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to our PlayNC platform (the “Platform”), games available through the Platform (the “Games”), streaming service available through the Platform (“Streaming Service”), websites for the Platform, Games, and Streaming Service (the “Websites”) and related applications (the “Apps”), and any online location operated by us that links to this Privacy Policy (collectively, the “Service”). We have a comprehensive company privacy policy including those for service providers, third parties and affiliates, and operate in accordance with it. This Privacy Policy has been established and is being operated in alignment with our policy for protecting personal information.

By using the Service, you agree to our Terms of Use and our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a Nevada resident, California resident, Taiwan citizen or otherwise a data subject as defined under Taiwan law, Japanese citizen or otherwise a data subject as defined under Japanese law, or data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.

For personal data transferred from the United Kingdom, the European Union, or Switzerland we will provide appropriate safeguards, such as through the use of standard contractual clauses.

2. Information Collection.

We collect information about you when you use the Service, including when you use the Platform, play our Games, use the Streaming Service, register an account, update your profile, access our content, sign up for a rewards program, make a purchase, participate in a promotion, or contact customer support. We collect information about you in a variety of ways depending on how you interact with us;

A. Information You Provide To Us.

Directly from you when you provide it to us with opt-in process, such as when you register for an account, sign up to receive communications from us, make a purchase, or contact us by phone, email, or otherwise.

The categories of information we collect when you use the Service include:

• Contact Data, including your first and last name, email address, phone number, and postal address.
• Account Credentials, including your username, password, password hints, and information for authentication and account access (such as a PIN).
• Billing data, including Guardian email address, coupon codes, mobile phone personal authentication information, bank name, and credit card company.
• Demographic Data, including your date of birth, gender, and country.
• Profile Data, including your interests, inferences, preferences and favorites.
• Commercial or transactions information, including records of products or services purchased, obtained, or considered.
• Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in product reviews or blog comments). We also collect content within any messages you exchange with other users through the Service (such as if you use our chat functionality).
• Personal Contacts Data, including the first and last name, email address, and phone number of your personal contacts. We collect data about your contacts with your consent and in order to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
• When you access third-party services, such as third-party online gaming services and social media services — through our services, these third-party services may be able to collect information directly from you or about you, including information about your activity on our services like your account information, nickname, and profile information.

If you participate in a promotion and are declared a winner, depending on the prize we may also collect your driver’s license number, passport number, or other similar identifiers as set out in the applicable promotion’s additional terms and conditions.

If you are eligible for a gift by participating in an event, we may collect the following in order to provide the gift to you:

• If a physical gift: name, mailing address, phone number, and email address.
• If a digital gift: name, mobile phone number, and email address.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

Automatically through the use of cookies, server logs, and other similar technologies when you play our Games or otherwise interact with our Websites, Streaming Services, Apps, and other Services, as well as when you interact with our advertisements, and communications.

The categories of information we automatically collect include:

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, gameplay data related to your interactions with our Platform, Games, and Streaming Service, faulty use records, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your telecommunications provider, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address, a Global Unique Identifier, and Ad Id.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
• The types of tracking technologies we use to automatically collect information include:
• Log Files, which are files that record events that occur in connection with your use of the Service.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
• Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities, such as the Facebook SDK, that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
• App Technologies, which are technologies included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps may include SDKs (e.g., the Facebook SDK), which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
• Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our Apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

C. Information from Other Sources.

From your friends if they provide us with your contact information for purposes of inviting you to play our Games or otherwise engage with our Services.

We do not purchase personal information from other sources without your consent. From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources (including the public domain). For example, if you log into your user account through social media sign-in services (e.g., Facebook Connect). We will base these collections on your consent where required by law.

3. Use of Information.

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

• Operating and managing our Service.
• Performing services requested by you, such as responding to your comments, questions, and requests, facilitating a refund, and providing customer service.
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Preventing and addressing fraud, breach of policies or terms, and threats or harm.
• Monitoring and analysing trends, usage, and activities.
• Conducting research, including focus groups and surveys.
• Improving the Service and other Zenova websites, apps, marketing efforts, products and services.
• Developing and sending advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
• Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
• Fulfilling any other purpose at your direction.
• With notice to you and your consent.

In many situations we have more than one purpose. For example, when you create an account with us we will collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in giving our users the best experience possible while playing our Games. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Notwithstanding the above, we may use and share information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. To the extent we maintain and use such de-identified information, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

• Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. We conduct regular assessments and improvements to ensure that service providers with whom we share personal information for the purpose of service provision comply with our privacy policy and process personal information appropriately.
• Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Promotions and Prizes. Our promotions and prizes may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion or collect a prize, we share information as set out in the official rules or additional terms and conditions that govern the promotion or prize, as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion or collecting a prize, you agree to the official rules or additional terms and conditions that govern that promotion or mission, and acknowledge that these terms and conditions may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
• Public Forums. We share information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
• Merger or Acquisition. If another company acquires, or plans to acquire, our company, business, or our assets, we may share your personal information with that company, including at the negotiation stage.
• Security and Compelled Disclosure. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Facilitating Requests. We share information at your request or direction.
• Consent. We share information in other situations with notice to you and your consent.

Please note that we do not rent, sell for monetary consideration, or provide personal information to third parties for purposes other than as described above, including to complete transactions and provide the Services.

5. Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.

Some examples include:

• Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.

• Logging-In. We may allow you to log-in or create an account through social media or another platform, such as through a Google, Facebook, Apple, Twitter, Line or Vkontakte account. If you choose to engage with such integration, we may receive information from the platform that you have authorized to share with us, such as your public profile name, email address, and internal identification information. Please note that the platform may independently collect information about you through the integration.

• Brand Pages. We may offer our content through social media. Any information we collect from your engagement with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Zenova Interactive OOO or the Service in a tweet or post), we may use your reference on or in connection with our Service. Please note that the social media provider will use your information in accordance with their privacy policy.

• Platform Linking. We may offer you the ability to link your Zenova Interactive OOO account to another service in order to retrieve certain data about your account on that service. For example, if you link your account to a gaming platform such as Steam or Twitch, the linking may allow us to obtain information such as your gaming username, email address, photo, game performance, and high scores. For more information about how these platforms handle information about you, please refer to their respective privacy policies and terms of use.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics and Advertising

We use analytics services to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our Websites, Apps and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices.

A. Account Information.

• You may access, update, or remove certain information that you have provided to us through your Zenova Interactive account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to confirm your identity. Please note that we will retain and use information about you as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

B. Tracking Technology Choices.

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser to decline or delete cookies by changing its settings. If you use multiple browsers, you will need to set each separately. Your ability to limit cookies depends on your browser’s settings.
• Do Not Track. Your browser may send a “Do Not Track” signal, but there is no industry consensus on how sites should respond. Until legally required, we do not monitor or act on such signals. For more info, visit http://www.allaboutdnt.com.
• App and Location Technologies. You can stop information collection by uninstalling the App or resetting your device’s Ad Id via device settings. You can also withdraw consent for precise location data.

Please be aware that disabling tracking technologies may affect some Service functions.

C. Analytics and Interest-Based Advertising.

• Google provides tools to opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout and for Display Advertising at https://www.google.com/settings/ads/onweb/.
• Our advertising partners provide opt-out options via Digital Advertising Alliance (DAA) and Network Advertising Initiative (NAI):
  • https://www.aboutads.info/choices (web)
  • https://www.aboutads.info/appchoices (app)
  • https://www.networkadvertising.org/choices/ (NAI)
• To opt out of matched ads using your hashed email, contact us as in “Contact Us.”

D. Communications.

• E-mails. You can unsubscribe from promotional emails by following instructions in the email or emailing us with “UNSUBSCRIBE” in the subject line. Non-promotional emails (e.g., account notices) cannot be unsubscribed.
• Push Notifications. Opt out by adjusting device permissions or uninstalling the app.
• Text Messages and Calls.
  • Text “STOP” to opt out of texts.
  • Request opt out during calls or contact us as below.

Note: Opt-outs apply only to the specific contact method used.

8. Children.

• The Service is not directed at children under 13. We do not knowingly collect personal information from children under 13. If discovered, such data will be removed in compliance with COPPA.
• For California residents under 18, you may request removal of your content by emailing us with “California Under 18 Content Removal Request.” We will make reasonable efforts to remove content from public view but may retain data as required by law.

9. Data Security

• We implement reasonable administrative, physical, and technical safeguards to protect your information from loss, misuse, or unauthorized access. However, internet transmission is not completely secure, and we cannot guarantee absolute security.

10. International Transfer.

• Information collected may be transferred, processed, and stored in countries other than your residence, including Russia and others. Data protection laws may vary by jurisdiction. Your use of the Service constitutes consent to these transfers. For data transferred from Europe, the UK, or Switzerland, we provide appropriate safeguards such as standard contractual clauses.

11. Changes to this Privacy Policy.

• We reserve the right to revise this Privacy Policy at any time. Changes are effective immediately upon posting. Continued use of the Service indicates acceptance of the revised Policy. For material changes, we may provide additional notice via email.

12. Contact Us.

If you have questions about this Privacy Policy or our data practices, please contact us:

By email:
CreditZenova@vertelcorp.com (PC Game)
MobileZenova@vertelcorp.com (Mobile Game)

By mail:
Tower A, Sberbank City, Kutuzovsky Avenue 32, Moscow, Russian Federation

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at privacy@vertelcorp.com

13. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain personal information collected or to be collected. A sale under Nevada law is exchanging personal information for monetary consideration to a third party who may license or sell it further.

If you are a Nevada consumer and wish to submit such a request relating to our compliance, please contact us at:
CreditZenova@vertelcorp.com

14. Additional Disclosures for California Residents.

These disclosures apply only to California residents under the California Consumer Privacy Act (CCPA).

A. Notice of Collection.

In the past 12 months, we have collected categories of personal information including:

• Identifiers (name, postal address, email, phone, IP address, driver’s license, passport, etc.)
• Customer records
• Protected classifications (gender, birthdate, country of residence)
• Commercial or transaction info (purchases, rewards, promotions)
• Internet activity (browsing, search, interaction with website/app/ads)
• Geolocation data
• Inferences about your characteristics and preferences

Details on sources and purposes are in the “Information Collection” and “Use of Information” sections above.

B. Right to Know and Delete.

You may request details about the personal information we collected, sources, disclosures, sales, purposes, and specific data. You also have the right to delete your personal information.

To exercise these rights, email:
CreditZenova@vertelcorp.com
Include which right you want to exercise. We will respond within 10 days and may ask for identity verification.

C. Right to Opt-Out.

If we sell your personal information as defined by CCPA, you may opt out anytime by emailing:
CreditZenova@vertelcorp.com

D. Authorized Agent.

You may designate an authorized agent to submit requests. We require written permission and may verify your identity.

E. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment for exercising your rights.

F. Shine the Light.

California residents may request a list of personal information disclosed for third parties’ direct marketing and a list of those third parties by emailing us with subject “California Shine the Light Request.”

15. Additional Disclosures for Data Subjects in Europe.

A. Roles.

Under European law, “controllers” determine how personal data is processed, and “processors” act on behalf of controllers. Zenova Interactive OOO acts as a controller for data collected via our websites, emails, and ads.

B. Lawful Basis for Processing.

Processing is based on:

• Your consent,
• Contract necessity,
• Legal obligations, or
• Legitimate interests balanced against your rights.

Transfers to third countries (e.g., Russia) use appropriate safeguards like standard contractual clauses.

C. Your Data Subject Rights.

You have rights to access, correct, delete, restrict, object to processing, data portability, and withdraw consent for marketing.

To exercise rights, contact us at:
CreditZenova@vertelcorp.com
We respond within 30 days and may verify your identity.

D. GDPR – European Representative.

Zenova Interactive OOO has appointed European Data Protection Office (EDPO) as GDPR representative in the EU. Contact EDPO via:

• Online form: https://edpo.com/gdpr-data-request/
• Mail: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

E. UK GDPR – UK Representative.

Zenova Interactive OOO appointed EDPO UK Ltd as UK GDPR representative. Contact via:

• Online form: https://edpo.com/uk-gdpr-data-request/
• Mail: 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

16. Additional Disclosures for Taiwan Citizen or Data Subject in Taiwan

These disclosures apply only to Taiwan citizens or data subjects as defined under Taiwan law.

A. Your Data Subject Rights.

Taiwan’s Personal Data Protection Act (“PDPA”) provides the following rights:

• Right to inquire and review your personal data;
• Right to request a copy of your personal data;
• Right to correct or supplement your personal data;
• Right to demand cessation of collection, processing, or use of your personal data;
• Right to delete your personal data.

We may charge a fee for access. To exercise these rights, submit a request to:
CreditZenova@vertelcorp.com

B. Retention Period for Your Personal Data

We process and use collected data as described in the “Information Collection” and “Use of Information” sections for the necessary duration.

C. Territory in Which Your Personal Data Will Be Used

Data is processed and used where the parties in “Sharing of Information” are located and any necessary territory to achieve the purposes in “Use of Information.”

D. Consequences of Not Providing Your Personal Data

Refusal to provide data may limit or prevent use of some or all services, products, or promotional offers.

17. Additional Terms for Residents in Japan

A. Parental Consent

If you are 15 years old or younger, please obtain consent from your parents or legal representative before agreeing to this Privacy Policy.

B. Sensitive Information

We do not collect or share “special care-required personal information” without consent, including race, creed, social status, medical or criminal history, disabilities, medical check-ups, juvenile protection info, or related data.

C. International Transfer

Your information may be transferred to, processed, stored, and used by third parties outside Japan including Russia, U.S., Korea, Singapore, Hong Kong, Thailand, Philippines, Indonesia. Using the Service or providing data constitutes consent to such transfers and processing. If you disagree, please do not use the Service or provide information.

18. Additional Disclosures for Data Subjects in Russian Federation

A. Definitions.

• “Personal data”: information relating to identified or identifiable individuals;
• “Processing”: any operation on personal data (collection, storage, use, transfer, deletion, etc.);
• “Operator”: Zenova Interactive OOO, operator of personal data;
• “User”: individual who agreed to Terms of Use.

B. Purposes of Personal Data Collection.

Data is collected to provide services under the Terms of Service and End User License Agreement, per the “Use of Information” section.

C. Legal Basis for Processing.

Processing is based on:

• Contract execution (Terms of Service);
• Consent given by the User;
• Legal obligations;
• Protection of rights and legal interests of Zenova or third parties, or public interest without violating User rights.

D. Procedure and Conditions of Processing.

Actions performed: collection, recording, systematization, storage, updating, extraction, use, transfer, depersonalization, blocking, deletion, destruction.
Processing methods: automated, mixed, non-automated.
Inaccuracy in personal data will be updated.

E. Retention Period.

Data is processed as described in “Information Collection” and “Use of Information” for necessary periods.

F. Termination Conditions.

Processing ceases if:

• User withdraws from Terms of Service;
• User withdraws consent;
• Processing purpose is fulfilled;
• Consent period expires;
• Unauthorized processing detected.

G. User Rights.

Users have the right to access, correct, block, or delete data if incomplete, outdated, inaccurate, illegally obtained, or unnecessary. Users may receive information about data processing and protect their rights legally.
Users may refuse data processing anytime by contacting Zenova via any communication channels listed in “Contact Us.”