Last updated: October 4, 2021
We are Neverest Games, a company under laws of Greece, with registered address at 43 Str. Ipsilantou, 18532, Piraeus, Attica, Greece (“Neverest Games” or “NV” or “We” or “Us”). NV is a developer and publisher of games and mobile applications that are made available via app stores including the Apple Application Store and Google Play Store (our “Games”).
For the purposes of this Policy:
“Our services” refers to the games provided to our users via our providers’ web sites or stores (e.g. Google Play, Apple Game Center).
“Our providers” refers to the providers we have a contract with for the distribution/provision of our games via their web sites and stores (e.g. Google Play, Apple, Amazon, Steam). We are not able to provide the necessary services for the successful operation of our Games by ourselves, so we co-operate with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partner’s advertising campaign performance. See the list of our Providers below in section 6.
- Data Controller
Our company Neverest Games PC, having its registered seat at 43 Str. Ipsilantou, 18532, Piraeus, Attica, Greece, (hereinafter referred to as “Neverest Games”) provides you with our services, either via our website or through various app stores and is therefore considered to be the “Data Controller” of your personal data. Consequently, hereinafter “we”, “us” and “ours”, refers to the Data Controller.
- What personal information is processed and the legal basis of processing
We collect different types of information when you use our services, i.e. when you visit our website, play our Games, or interact with third-party ads in our Games or with our ads in other publisher’s Games. Essentially, we only obtain what is strictly necessary to provide you with our services, no more, no less.
The information that we may collect about you through our services falls into the below mentioned categories:
(a) Information you provide to us voluntarily
When you use our services, you will be asked to provide us certain information. Your Username, Password or Nickname are necessary to be provided in order to create an account and for the provision of our services, as a contractual necessity. This data may be personal or non-personal, at your discretion.
If you would like to contact us through the particular contact form in our website, you have to provide us with your name and e-mail address and other details, that may be necessary to us, in order to satisfy your request. We process these data in order to respond to your queries and provide customer support, as part of the performance of the contract.
Please note that we do not use your information for any other purposes, except for answering any of your queries.
Please note that we do not build your profile or target you via our communication.
(b) Information collected automatically
Moreover, we may also automatically collect information about you and/or your device, which is highly possible that it is considered as “personal information” under data protection laws which apply, such as:
- Data and analytics about your use of our services. For example, information regarding your in-game play progress, games played by you, the length of the session, your preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences or the means by which you were referred to our services.
- Your IP address and identifiers, which relate to your device, such as your Advertising ID (iOS Advertising Identifiers and Google’s Advertising IDs – are identifiers, which are non-permanent, non-personal and uniquely associated with your device and resettable) /Device ID numbers, or to the characteristics of your device, e.g. the type, or the operating system that you use.
How to opt-out of / reset Mobile Advertising IDs
Go to ’Settings’
Scroll down to ‘Privacy’
Scroll down to ‘Advertising’
Shift the ‘Limit Ad Tracking’ slider to the right.
Reset your iOS Advertising Identifier: if at any time you wish to reset your iOS Advertising Identifier, you can do so by replacing the final step with “Click on ‘Reset Advertising Identifier’”.
Go to ‘Settings’
Scroll down and click on ‘Google’
Scroll down and click on ‘Ads’
Shift the ‘Opt out of Ads Personalisation’ slider to the right.
Reset your Android Advertising ID: if at any time you wish to reset your Android Advertising ID, you can do so by replacing the final step with “Click on ‘Reset advertising id’”.
- Your Service communications (e.g. in-game emotion signals which you exchange with other players)
- Broad geographic location (e.g. country or city-level location) based on your IP address.
- Other information, collected automatically, may include, for example, IP addresses or domain names of the computers utilized by you when using our website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and t operating system utilized by you, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.
(c) Information from third-party sources
- Third-party social network/s. There is an option to connect to our services via your social media account, e.g. Google Play Games Service, Apple Game Center, Facebook. In addition to the personal information that we collect directly from you, we may also collect certain of your personal information from third party sources, which may include your basic public profile information such as your username, gender or your friends playing the same Game.
- Please note that the type of information that we receive from your profile depends on the social media privacy settings that you selected.
- Third-party service providers. We may receive personal information about you from third-party sources. For example, we may get your personal information when you installed our Game and prior to installing you have clicked an advertisement for the same Game.
- Advertising partners. We may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement that related to one of our games, such as an advertisement of our game that was displayed in other publisher’s game, we will be provided with information from the type of ad network and advertising campaign the installation came from (See below also “Advertising”).
A list of our current service providers and partners is available below.
(d) No special categories of information
We ensure you that we do not request/ intend to collect any “special or sensitive categories of information” (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
Please be careful about transmitting sensitive information.
- How we use the information we collect
3.1. We will only use your personal information for the following purposes:
We will also use them in order to improve our Games and other products, services, and content, tailoring our products and services. To ensure that you have the best experience when using the Games, we provide Game updates, technical troubleshooting through understanding and analyzing trends in connection with usage of the Games.
3.1.2. To respond to your enquiries and requests for support: We may process information so that we are able to properly respond to your enquiries and support requests.
3.1.3. For Cross-promotion purposes: We use your information in order to promote one of our Games while you are playing a different Game of ours.
3.1.4. Tracking & preventing fraud for advertising purposes: We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.
3.1.5. Analytics and research: We may process information to understand the usage of our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This may include segmenting and analysing users according to various relevant factors, such as geography, gameplay progression and playing behaviour so that we can offer personalised and temporary promotional discounts and offers.
3.1.6. Security purposes: We use your information for safety and security purposes in order to protect our Games, products and services.
3.1.7. For advertising purposes: We use your personal information (a) for displaying our Games’ advertisements in other publisher’s apps and (b) for displaying third-party advertisements in our Games. See more below in section 5.
3.1.8. To comply with legal or regulatory obligations: We process your information for our legitimate interests of carrying out processing for the purpose of managing, operating or promoting our business, ensuring that any use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations.
3.1.9. Contractual reasons: We use your information when we are required to carry out pre-contractual measures, for example, before our employment relationship.
3.2. In-App Purchases
Payment transactions for in-app purchases are completed through the app store via your App Store, Google Play, Steam or Amazon account (payment service providers). When processing such purchases, you are requested to provide your payment information directly to such payment service providers and not to NV. We are not involved in the collection and processing of such information: instead, we will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
- How we share your information
We keep your information confidential, but may disclose it, in order to provide all necessary services for the operation of our Games. Therefore, we co-operate with third-parties, and we may process your personal information for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our advertising campaign performance. In addition, we may disclose your information to the extent that we are required to do so by law and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). We also reserve the right to disclose that information after implementing technical and organizational measures, such as anonymization, for analytical purposes.
We may share such information to:
- Our analytics providers. We use third-party analytics such as Chartboost and Unity (see all providers below) for the purposes of delivering our services, conducting analysis, and research.
- Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform.
- Third-party advertising partners. Please see below in section 5.
- Our tracking and fraud prevention providers. For some of our Games we use tracking and fraud prevention providers, such as AppsFlyer, Tenjin for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes.
The list of our current service providers may change in the future, if we contract with additional partners in order to perform any services in connection with the Games. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.
Kindly note that we reserve the right to disclose your information in order to satisfy our legitimate interests. So, we may disclose that information in response to any legal process that may occur, including litigation and/or requests from public and governmental authorities within or outside your country of residence.
Law enforcement, national security and other public importance purposes are also reasons that allow the disclosure of your information.
We may also disclose your information if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or user experience.
For any additional questions about third-party information collection, please refer to email@example.com.
- Data processed by Advertising Providers
Neverest Games cooperates with advertising (“ad”) providers, who also collect data, each time you use our services, such as: bundle ID, language ID, operating system version, device model, software developer kit (SDK) version, unique device identifier, IP address, media access control (MAC) address. Additionally, if you access a video ad, ad providers may collect additional stats about videos and video play back, such as: start/boot-up information, amount played/session length information, memory on device used for our video cache, videos cashed on a device and complete view event.
Based on the provided services to Neverest Games, ad providers may also collect data such as: how long you play the game (app) and in-app events. Ad providers may use this data to provide you advertising campaign optimization, re-targeting based on your usage patterns.
Ad providers may receive information about you, from advertiser or advertising services companies such as mobile device identifiers, geolocation, IP addresses, website cookie information and usage data. They may also combine this information with additional demographic, geolocation and interest-based segment data, along with cookie information, from third-party providers. This additional information may determine the nature of the ad you see.
The legal basis for the processing of your personal data by the ad providers is your consent to this Policy.
Ad providers may share your information with third parties, for the provision of their services to Neverest Games, and/or in order to assist them analyzing their services, for industry analysis, tracking and conversions, cross-device matching, behavioral advertising or demographic profiling, for advertising purposes. For more information, please read our ad providers’ privacy policies:
AdMob by Google: https://policies.google.com/privacy?hl=en
Appodeal : https://www.appodeal.com/privacy-policy
Facebook Audience Network: https://developers.facebook.com/docs/audience-network/policy/
- Data Processed by our Providers
- How long is your personal data stored for
7.1. We store your personal data until you delete our App.
7.2. Some data may be held for longer in our legitimate interests to protect our business from losses, to exercise our legitimate rights and perform our legal obligations.
7.3. If you are a job applicant and wish to submit your CV to the open position advertised in our website/ in our Facebook account, you may also upload some User Content (including your name, contact details, your CV or portfolio) via our Job applicant’s contact form. NV will keep your CV in its database for one (1) year for future openings.
In case that your application will not proceed further or you will not accept the offer, your CV will be deleted directly from our database in a secure and definitive way. However, you reserve the right to request the deletion of your CV at any time before the expiration date.
If you accept the offer to work with NV, your CV and data, collected before your recruitment, will be part of NV’s employee record and will be kept throughout your cooperation with NV as well as for some more years after the termination of the cooperation between us, in accordance with applicable law. NV does not request or intend to collect any Sensitive information
- Security measures
We are concerned about safeguarding the confidentiality of your information. Therefore, we provide physical, electronic, and procedural safeguards to protect information we store, transmit, maintain or otherwise process from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
We implement all the necessary technical and organizational measures in order to ensure the safety of the personal information we are storing. We encrypt the password created by you at the sign up stage and then store your personal data on secure servers that would prevent unauthorized access or destruction of your personal data.
We limit access to your personal data to authorized employees and contractors who need to know these information in order to operate, develop or improve our services. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
- Information we collect from our website
When you are using our website we may obtain your personal data, from you directly, for example, when you contact us through the from or when you apply for a job position.
Such personal data may include: your name, email and all the information included in your CV. We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.
- Data Subjects Rights
For the purposes of this chapter:
“Data Subject” refers to everyone who uses our services through our website.
“Controller” refers to Neverest Games.
If a Data Subject wishes to avail himself or herself of the following rights, he or she may, at any time, contact the Controller via the following e-mail: firstname.lastname@example.org.
The Data Subject has the following rights:
- Right to withdraw your consent according to Art. 7 par. 3 GDPR. That means that you are able to withdraw your consent for any processing of personal information by NV.
- Right of confirmation: Each Data Subject shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning the Data Subject is being processed.
- Right of access: Each Data Subject shall have the right to obtain from the Controller free information about his or her personal data stored at any time and a copy of this information, such as:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed;
- where possible, the anticipated period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- where the personal data is not collected from the Data Subject, any available information as to their source;
- possible data transfer to another Country;
- the existence of automated decision-making, including Profiling, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the Data Subject.
- Right to rectification: Each Data Subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her.
- Right to erasure (Right to be forgotten): Each Data Subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her, and the Controller shall have the obligation to erase personal data without undue delay, under certain legal prerequisites.
- In case your personal data is erased at your request or in accordance with our data retention policy, we only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.
- Right of Restriction of Processing: Each Data Subject shall have the right to obtain from the Controller restriction of processing, under certain legal prerequisites.
- Right to data portability: Each Data Subject shall have the right to receive the personal data concerning him or her, which was provided to the Controller, in a structured, commonly used and machine-readable format and transmit those data to another Controller.
- Right to object: Each Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her. This also applies to profiling based on these provisions.
- Automated individual decision-making, including Profiling: Each Data Subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her.
- Contact with the Greek Authority: You are able in case of violation of the privacy of your personal data to lodge a complaint before the Greek Data Protection Authority at the following contact details:
Address: Kifissias 1-3, 115 23 Athens, Greece
Telephone: +30-210 6475600
Fax: +30-210 6475628
- Children’s Privacy
We never knowingly collect or solicit any information from anyone under the age of 16. Our services are not directed at nor made look to appeal to such persons. Parents or guardians that believe that we hold information about their children aged 16 and under may contact Us at email@example.com.
- Your Consent
By installing, using, registering to, or otherwise accessing our services, you agree to this Policy and give an explicit and informed consent to processing of your personal data under the Terms of this Policy. If you do not agree with this policy, please DO NOT install, use, register to, or otherwise, access our services.
Should you have any queries of any nature regarding this Policy or have any concerns about privacy, please contact Us to firstname.lastname@example.org.