Privacy Policy

Current version from December 12, 2023

This Privacy Policy defines what data about you and how LCT Studio collects and processes it during your use of the server and services (Legnes), the official websites of the specified https://legnes.com, https://wiki.legnes.com and other websites where this Privacy Policy is posted ("Website"/"Websites"), as well as services related to the above Games (support services, forums, chats, etc.). LCT Studio is hereinafter referred to as the "Administration".

Please read this privacy policy carefully before using the game or the website. By continuing to use the game or the website, you agree to this privacy policy in full.

If after reading this privacy policy you still have any questions or concerns, please contact us by email at support@legnes.com.

1. USER DATA CONTROLLER.

The user data controller is the person who determines the purposes and means of processing your user data.

Name of the controller: LCT Studio.

Email address: support@legnes.com

2. LIST OF DATA ABOUT YOU THAT WE COLLECT.

2.1. Data that you provide to us directly:

2.1. 1. when creating a game account — nickname (name in the game) and email address.

2.1. 2. when you contact support, send messages/comments in game chats, on forums and on Websites — data that you send at your own discretion and/or with your consent;

2.1. 3. when connecting the two-factor authentication service — mobile phone number;

2.1. 4. if a prize or gift that you won is sent to you — data that is necessary for delivery and/or use of the prize/gift;

2.1. 5. if you participate in surveys — data necessary for participation in the survey;

2.2. Data that we may collect automatically:

2.2. 1. IP address of your device;

2.2.2. Technical characteristics and data about the device (operating system, manufacturer, model, screen resolution, interface language);

2.2.4. Account and game progress data;

2.2.5. Traffic source (the source from which the Game was installed on your device);

2.2.6. General location data (usually up to the country and city level, without identifying your specific location);

2.2.7. Data on gameplay and interaction with other players (date of account creation; interface language you have chosen; any and all quantitative and time data on your in-game activity, including game items, completed game tasks, in-game purchases, game results, information on in-game interactions with other players, time of the last game session, information on any requests made using the Legnes application, etc.);

2.2.8. Facts about your contact with support, sending us requests in accordance with this Privacy Policy.

2.3. Data that we may receive from partners:

2.3.2. Data to combat fraud and unfair play;

2.3.4. Data for advertising and analytics in order to more effectively provide our Games and services;

2.3.5. Data from payment partners for sending you invoices when you make donations on the official website https://legnes.com (including your address).

2.4. Publicly available data that we have the right to collect:

2.4.1. Your reviews, comments, opinions about the Games and our services, published by you in the form of texts, audio recordings, videos on publicly available resources.

2.5. Data that we do not collect:

2.5.1. We do not process any data about your payment instruments (in particular, bank card details, etc.).

2.5.2. We do not request or collect any special categories of personal data about you (for example, data about your health, race, religion, political views, etc.). We urge you to be careful when sharing such information about yourself in game chats, comments on websites and forums.

3. PURPOSES OF PROCESSING YOUR USER DATA.

We use the information collected about you and your device to provide you with services and develop the project. The goals and objectives that we follow when processing your user data include:

3.1 Fulfillment of the agreement with you and providing you with the opportunity to play, use the Websites and related services - for this purpose, we carry out the following actions:

3.2 Operating, administering and supporting the server and the Website;

3.2.1 Creating player profiles (accounts), forming and maintaining the player database;

3.2.2 Receiving error messages in the Game, improving the quality of service, developing, finalizing and improving the game, the Website and related services;

3.2.3 Providing you with the opportunity to communicate with other players in the game and on game forums (where available);

3.2.4 Conducting surveys, research, analysis, generalization and using the information received in an anonymous form;

3.2.5. personalization of the Game and Websites for you (including to remember your preferences and settings);

3.2.6. sending you messages to your mobile phone number and/or email address to confirm that you have performed certain actions;

3.2.7. sending you technical messages, service notifications, legal notices (including about changes in regulatory documents), responses to requests to the technical support service, the results of our consideration of your requests in accordance with this Privacy Policy and other mandatory information to your email address.

3.3. Providing you with personalized advertising and direct marketing messages - for this purpose, our Statistics and Analytics Partners (see the definition in clause 5.2.), as well as some of our advertising partners, have the right to track your behavior on the Internet, and third-party advertisers have the right to show you personalized advertising. In addition, we may make you special personalized in-game offers. We also have the right to send you informational emails about updates and changes to Legnes, special promotions and offers, discounts, competitions, etc. For more information on your right to opt out of personalized advertising and direct marketing messages, see Item

3.4. Ensuring security, combating unfair gaming practices – for this purpose, we have the right to monitor and analyze the behavior of players in the game, take action against players who violate the rules of fair play, and take preventive measures.

3.5. Analysis of all collected data, data segmentation and profiling.

3.6. Compliance with applicable laws, fulfillment of legal obligations, exercise or protection of our rights, protection of your vital interests or the interests of others.

4. PUBLICLY AVAILABLE USER DATA.

Some of your user data may be available for viewing by other persons. For example, other players can see the nickname and photo (picture) of your game account (including your profile on a social network, if you have connected a social network to your game account), your game results, messages in chats and on forums, comments on the Websites. In addition, your game nickname and profile pictures may be available in player ratings posted on a variety of Internet resources.

5. TRANSFER OF USER DATA TO THIRD PARTIES.

As a general rule, we do not disclose your user data to anyone and ensure its confidentiality. However, in some cases described in this Privacy Policy, we have the right to transfer your user data to third parties. Below is a closed list of such cases.

5.1. Government agencies. We have the right to provide any and all user data to law enforcement agencies, regulators, government agencies, and the court in order to comply with applicable law and respond to their legitimate requests.

5.2. Statistics and analytics partners. We provide some of your user data to our partners who process your user data for the purposes of statistics, analytics and providing you with personalized advertising on the Internet ("Statistics and Analytics Partners"). Such partners include, for example, Google Analytics, Yandex.Metrica. Your user data is processed by Statistics and Analytics Partners in accordance with their privacy policies, which contain, among other things, information about the data processed about you, we recommend that you familiarize yourself with them. Your data may be published by Statistics and Analytics Partners in aggregate form for the purpose of showing trends in the use of their services, for advertising services and for marketing purposes. We may aggregate this data for testing purposes.

5.2.1. Details of using the Google Analytics service.

The Games and the Website use the Google Analytics web analytics service provided by Google Inc. To learn more about how Google collects and processes your user data, you can visit https://policies.google.com/technologies/partner-sites?hl=ru. To control Google's collection of your data for analytical purposes, you can install the Google Analytics Opt-out Browser Add-On - https://tools.google.com/dlpage/gaoptout.

5.2.2. Details on using the Yandex.Metrica service.

The Games and the Website use the Yandex.Metrica web analytics service provided by Yandex Oy Limited Company - Moreenikatu 6, 04600 Mantsala, Finland (hereinafter referred to as Yandex). The Yandex.Metrica service uses cookie technology - small text files placed on users' devices to analyze their user activity. Information collected using cookies cannot identify you, but it can help us improve the performance of our Games and Website. Information about your use of the Games and Website collected using cookies will be transferred to Yandex and stored on Yandex's server in the EU and the Russian Federation. Yandex will process this information to evaluate your use of the Games and Website, compile reports for us on the activities of our Games and Website, and provide other services. Yandex processes this information in the manner set out in the terms of use of the Yandex.Metrica service. You can opt out of using cookies by selecting the appropriate settings in your browser. You can also use the tool — https://yandex.ru/support/metrika/general/opt-out.html. However, this may affect the operation of some functions of the Game and Website. By using our Games and Website, you agree to the processing of data about you by Yandex in the manner and for the purposes specified above.

5.3. Advertising partners. We may provide our advertising partners with some anonymized user data necessary for the delivery of advertisements and the accounting of the advertising services rendered.

5.4. Operating partners. We may provide any and all of your user data to our partners who provide the following services to the extent necessary to provide the relevant service: hosting, player support, testing the game and related services, conducting statistical and marketing research, and analyzing information.

5.6. Partners providing a two-factor authentication service. We may provide your data (such as a mobile phone number) to partners who provide a two-factor authentication service.

5.7. Payment partners/licensees. When making a donation on https://legnes.com, we transfer the player ID and the payment amount to our payment partners. In some cases, we transfer your email address, nickname, IP address and date of registration in the Game to licensees receiving payments.

In the future, we may enter into contracts with other partners, we will make every reasonable effort to promptly update the list of types of our partners in this Privacy Policy at least once every six months, or more often in the event of a significant change in our data processing practices.

The server is accessible worldwide, and therefore we can transfer your user data to our partners in countries located both in the countries of the European Union and the European Economic Area and outside them. Whenever we transfer your user data outside the European Union and the European Economic Area, we will take reasonable steps to ensure the confidentiality of your user data, including by entering into standard data transfer clauses adopted by the European Commission with partners located outside the European Union and the European Economic Area (a copy of which is available upon request).

6. YOUR RIGHTS

6.1. Right of access.

You have the right to request from us, at reasonable intervals, information about the storage of your personal data by us or a copy of the personal data we have stored about you. To do this, please send an email to support@legnes.com and follow the instructions provided. Please note that in some cases, in order to fulfill your request, we may ask you to provide us with some additional information necessary to identify you as our user. We undertake to comply with your request free of charge within a period of no more than one (1) month from the date of receipt of your request, although in some cases provided by law this period may be extended to two (2) months. We have the right to refuse you to exercise this right or charge a reasonable fee if your request is clearly unfounded or if you send us such requests too frequently.

6.2. The right to opt out of receiving personalized advertising and direct marketing messages.

6.2.1. You can at any time change the settings of your browser and opt out of the use of analytical cookies on your device used to personalize advertising offers for you, in accordance with the recommendations given in section 10.

6.2.2. You also have the right to independently configure the collection of data about you by our Statistics and Analytics Partners in accordance with the instructions contained in clause 5.2.

6.2.3. We have the right to send you targeted in-game offers based on the analysis of your user data (mainly data on your in-game activity) in accordance with certain algorithms. These offers do not significantly affect your rights and interests, they are intended to provide you with timely and interesting, in our opinion, offers. However, if you want to opt out of receiving targeted in-game offers from us, you can opt out through the site settings or by writing a corresponding letter to support@legnes.com.

6.2.4. We have the right to send you direct marketing messages by means of newsletters to your e-mail address, as specified in paragraph (2) of Section 3. You have the right to unsubscribe from such newsletters by following the instructions provided in the e-mail you receive from us. Please note that your refusal to receive direct marketing messages from us will not result in us stopping sending you the e-mails specified in paragraph 1 (z) of Section 3.

6.3. The right to rectification of inaccurate data.

You have the right to request rectification of inaccurate personal data at any time. If any of your personal data processed by us is no longer relevant for you, please let us know by e-mail to support@legnes.com. Please note that in some cases, in order to fulfill a request, we have the right to request from you some additional information necessary to identify you as our user. We undertake to comply with your request for clarification of data free of charge within a period not exceeding one (1) month from the date of receipt of your request and additional information requested by us, in some cases provided by law this period may be extended to two (2) months. We have the right to refuse you to exercise this right or charge a reasonable fee if your request is clearly unfounded or if you send us such requests too frequently.

6.4. The right to erasure of data.

You have the right to request the erasure of your personal data by sending us a corresponding letter to support@legnes.com. Please note that in some cases, in order to fulfill the request, we have the right to ask you for some additional information necessary to identify you as our user. We undertake to comply with your request to delete data free of charge within a period of no more than one (1) month from the date of receipt of your request and additional information requested by us, in some cases provided by law, this period may be extended up to two (2) months.

Please note that complying with the request to delete your personal data will result in the deletion of your game account and/or the fact that all game results and game progress associated with your game account will be irretrievably lost, so take this circumstance into account when deciding to delete data.

Please also note that deleting the application with the Game from the memory of your device does not automatically entail the deletion of your personal data on our game servers.

We have the right to continue to store some of your user data even after complying with your request to delete data if (1) we are required to do so to comply with applicable law, or (2) your user data has been anonymize and is therefore no longer your personal data. data.

6.5. Right to object.

You have the right to object to the processing of your personal data. Please let us know about your objections by email at support@legnes.com.

6.6. Other rights.

If you believe that your rights to the processing and use of your personal data are being violated, please let us know by email at support@legnes.com. You also have the right to contact the supervisory authority with a complaint about the violation of your rights in connection with the processing and use of your personal data in the country of your residence.

7. PERSONAL DATA OF CHILDREN.

We do not collect data from or knowingly collect personal data from children under 16 years of age (or children under the age of consent under applicable law). If we obtain actual knowledge that we have inadvertently collected personal data from a child under 16 years of age (or a child under another age of consent under their personal law) without the consent of their legal representative, we will take all reasonable steps to delete this information as soon as possible. If you learn that your child has provided us with personal data without your consent, please contact us at support@legnes.com. Please ensure that you provide us with convincing evidence in advance that (a) the personal data was provided by a child under the minimum age of consent, and (b) you are his or her legal representative.

7. PERIODS OF PROCESSING YOUR PERSONAL DATA.

Your personal data will be stored and processed by us for as long as your game account is active and as necessary for us to provide you with access to the Games and as long as we retain a legitimate interest in processing your user data, from the moment we receive it until the moment your user data is deleted in accordance with paragraph 6.4. Please note that some data, as specified in paragraph 6.4., will not be deleted even after your deletion request has been fulfilled. We also delete your personal data after achieving the purpose for which we collected it (for example, the data specified in paragraph 2.1.4., paragraph 2.1.5.).

9. INFORMATION PROTECTION

In order to ensure the security of the processing of your personal data, we constantly develop and implement technical and organizational measures to protect your personal data from unauthorized access, disclosure, misuse, modification, loss and destruction.

10. COOKIES

We and our partners (in particular, advertising partners, advertisers, and analytics partners) may use cookies and other similar technologies (web beacons, device identifiers, pixels, etc.) to recognize you and/or your device, provide and personalize the Games, Website, and related services, analyze your use of the Games and Website, send targeted advertising, and prevent fraud. You can find more information about cookies and how to disable them at https://www.aboutcookies.org/. In addition, some third-party advertisers may use cookies in their advertising campaigns within our Games and Websites. Such cookies are used to collect anonymous behavioral information, which advertisers use to provide personalized advertising within and outside of our Games and Website. To disable this feature, visit http://optout.aboutads.info/ and follow the steps described there. You can also disable these and other cookies in your browser settings. However, please note that some features of the Games, Websites and related services may be unavailable to you or may not work properly if you disable certain cookies that are not related to the personalization of advertising offers for you, while the Games and the Website will generally remain available to you.

11. CHANGES TO PRIVACY POLICY

The current version of this Privacy Policy is published on the website https://legnes.com/private-policy

We may make changes to this Privacy Policy at any time. Changes come into force from the moment of publication of the updated version of the Privacy Policy on the above websites, unless another effective date is specified in the text of the new version of the Privacy Policy.