Privacy Policy

1. INTRODUCTION

AG Softworks LLC (ʺweʺ, ʺusʺ or ʺourʺ, ʺcompanyʺ, EI DZHI SOFTVORKS, OOO in Apple Store account, AG Softworks - here), respects your privacy and understands that you care about your personal information and how it is used. 

This Privacy Policy (ʺPrivacy Policyʺ) clarifies our privacy practices and describes how we collect, use, disclose and otherwise process your personal information when you install and/or use our Mobile App (hereinafter, ʺthe ʺAppʺ) and explains the rights and choices available to you concerning your personal information. When adults or parents visit https://www.agsoftworks.com/  (the “Website”), we may also collect information on the usage of our website by adults and parents.

When we refer to personal information (or personal data) we mean any information of any kind relating to you as an identified or identifiable natural person. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or one or more factors specific to your physical, physiological, mental, economic, cultural, or social status. And namely personal information identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

For the purposes of the CCPA/CPRA, Personal data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, AND YOUR CHOICES REGARDING YOUR PERSONAL DATA, CAREFULLY. WHEN YOU USE THE APP(S) OR THE WEBSITE YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

We support the Children's Online Privacy Protection Act (“COPPA”) and other frameworks like the General Data Protection Regulation and the so-called UK GDPR.

Following the EU General Data Protection Policy (EU-GDPR) and the UK General Data Protection Regulation (UK-GDPR), we are the data controller unless otherwise stated.

If you have any questions or concerns, send us an email via hello@agsoftworks.com, we are here to help.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to AG Softworks LLC, 20/11 Olshevskogo str., room 23, office 6, 220073, Minsk, Republic of Belarus.

2. INFORMATION WE PROCESS AND HOW WE DO THE PROCESSING

How we collect and use Personal Information of a Child

We does not knowingly collect any personal information from children or within the child-directed portions of our the App except as otherwise outlined in this Privacy Policy. If we were to collect and store personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exception that is permitted under COPPA.

AG Softworks does not permit behaviorally-targeted advertising to children in the Service where we have actual knowledge that the user is under the age of 13.

Parental Choices and Controls

As part of the verifiable parental consent process, where applicable, parents and legal guardians will have the choice of consenting to our collection and internal use of their child's personal information but prohibiting us from disclosing that information to other entities (except to the extent such disclosure is integral to our Apps). Please note that exercising these choices may restrict your child's ability to access certain functionality of the Apps. 

Personal Information. We do not collect Personal Information.

Non-personal Information (Automated Processing).  We do not collect your non-personal information when you use the App.  Unity as our Service provider collects IP address to provide a compliant experience suitable for the User’s region. It is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, access may be only in aggregated form. This information need for improving our App and giving our users the best experience. We use Adapty Service provider for the correct mobile app operation and for improving our App. We do not send or share any user’s information with the Adapty Service provider. You can read Adapty Service's privacy policy here.

Information you provide. We may collect your contact information (name, e-mail address, and any information that you provide, including the contents of the messages or attachments) which you send us via email or contact form when it is necessary for the adequate performance of the contract between you and us. We use such information to respond effectively to your inquiry, fulfill your requests, and send you communications that you request and perform the requested services.

Payment information. We cannot access or use your credit card or debit card information. That information is provided directly to Our third-party payment processor Apple whose use of your personal information is governed by their Privacy Policy (can be viewed at https://www.apple.com/legal/privacy/en-ww/)

3. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

 (a)  To provide the App, maintain, improve, test, and monitor the effectiveness of our App. We use information you provide to us directly and information that is processed automatically to provide and deliver the App to you as well as to better understand User behavior and trends, detect potential outages and technical issues, support the existing functions of the App, and to add new features and services to the App.

 (b)   To communicate with you. We may use information that is processed automatically to send you push notifications with technical notices, updates, security alerts, and support and administrative messages. Similarly, we use your contact information to respond to you when you contact us.

 (c)  To prevent fraud and spam, and to enforce the law. We aimed our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.

If any new purposes for processing your personal data arise, we will let you know we start to process the information for that other purpose by introducing the corresponding changes to this Privacy Policy.

4. INFORMATION SHARING AND DISCLOSURE

We will share your information with third parties only in the ways that are described in this Privacy policy.

To help us provide you with the best service, we work with third party analytics providers. This information is for internal use only and can´t be shared. It´s just for us to help us improve our services for you. We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, device identifiers, and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.

Unity, Unity Analytics and Unity IAP by Unity Technologies. It collects analytical information to better understand your use of our Apps. We have explicitly indicated to Unity that our products are aimed at children under 13 (which means Unity is aware that the handling of information should be COPPA compliant). For more information on Unity please see the privacy policy here: http://unity3d.com/legal/privacy-policy

• You can prevent Unity Analytics from using your information by opting-out. To opt-out of Unity Analytics, please visit this page: https://unity3d.com/legal/privacy-policy
• You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS). See Your mobile device Help system for more information.

If you have any questions about our collection and use please contact us at hello@agsoftworks.com

Firebase AnalyticsWithoutAdIdSupport (without the ability to collect IDFA), Firebase Crashlytics  by Google Inc. We don’t collect IDFA or any other personal information by default settings. We can collect certain anonymous information (device model and type of OS) when you use our App. We use these tools to automatically analyze in-App information (tutorial steps, custom events events, progression events and so forth) and collect crash reporting data to track, prioritize, and finally fix stability issues to improve our app functionality and quality. For more information on Firebase please see the privacy policy here: https://firebase.google.com/support/privacy/dpo?hl=ru

We may disclose information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

5. RETENTION OF PERSONAL DATA

We will retain Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Personal Data for internal analysis purposes. Personal Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the App or website, or we are legally obligated to retain this data for longer time periods.

6. TRANSFER OF PERSONAL DATA

We work in the cross-border area and provide our App to our Users around the world.

We and the legal entity that provides automatic data processing technologies for the App may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Please note that we may transfer information, including personal data, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country, or to an international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

We try to make sure that the recipient of any personal data provides proper protection of the personal data received, following the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country, or to the international organization.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

7. EMAIL MARKETING

We may use parental/adults Personal Data to contact to them with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use email Marketing service providers to manage and send emails to you.

 MailJet. For more information, please see their privacy policy here: https://www.mailjet.com/legal/privacy-policy/‍

8. WEB-SITE

Our Website doesn’t collect any information.

9. YOUR EUROPEAN PRIVACY RIGHTS

If you are a data subject in Europe, you have the right to:

• receive information regarding the processing of your personal data (Data Access and Portability). 

• change or correct data. 

• delete personal data. The specific retention time may vary depending on the context of the processing being performed. You have the right to request the deletion of all or some of the personal data held about you.

• restrict the processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

• receive information about sharing personal data to third parties. 

• withdraw consent to the personal data processing. 

You can send request by email: hello@agsoftworks.com

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you
• We will disclose and deliver the required information free of charge within 1 month of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 2 months when reasonably necessary and with prior notice.
• For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

10. YOUR RIGHTS UNDER THE CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about collection, use, sale, disclosure for business purposes and share of personal information. 
• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell your personal information. 
• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm Your request, we will use commercially reasonable.
• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information 
• The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• The right not to be discriminated against.

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us:

• By email: hello@agsoftworks.com
• By visiting this page on our website: https://www.agsoftworks.com/

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you
• We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
• For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

11. CHILD-FRIENDLY SUMMARY PRIVACY POLICY

This is the child-friendly summary of our privacy policy.

These are the key facts:

• We do not collect personal information of a child we know to be under 13 without the consent, and active participation, of a parent.
• We do not display targeted ads to you.
• We believe that parents should have control over their child’s data.

You can always:

• Ask us for a copy of the information we have got about you
• Change the information we have got about you, or bring it up to date, if it is wrong
• Change how you’d like us to get in touch with you
• Ask us to delete all the information we have got about you (we will then do that, and just keep your name on a list of people we won’t get in touch with again)
• Tell us we can’t use information about you for anyone to sell you anything
• Tell us if you are worried about the way we are keeping or using information about you, and want to make a complaint about this.

The email is hello@agsoftworks.com

We will get back to you in a month – or sooner.

We will always:

• follow the law on how we can keep and use the information we have about you
• make sure our policies are the best they can be

We will never:

• give the information we have about you to anyone else, unless…

…you tell us we can

…we think that doing so will protect you from harm

…the law says we have to (e.g. to prevent a crime)

• tell people about our work with you in a way that you can be identified, unless you have told us we can
• use the information you have given us to sell you anything, unless you have told us we can

We do our very best to keep the information we have about you safe and private.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right, at any time, to modify or replace this Privacy Policy.

The date of the Privacy Policy most recent version is given under the “Effective Date of this Privacy Policy” text. We may also notify you via e-mail or other electronic communication method about any changes that, in our sole discretion, can materially impact your work with the App or your personal data treatment.

13. CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

• By email: hello@agsoftworks.com
• ‍By visiting this page on our website: https://www.agsoftworks.com/‍