Privacy Policy

Scope of this Privacy Policy

For personal data collected and further processed in line with this Privacy Policy, the data controller is Digital-Arrow doo Novi Sad. 

Digital Arrow (“Digital-Arrow doo Novi Sad”, “controller”, “us”, “our” or “we”) is dedicated to protecting the privacy rights of the users of our games and other services (further below referred to as the  “users”, “you” or “data subjects”). This Privacy Policy describes how we and our partners process the information about you.

This Privacy Policy applies to all of our games, played on mobile devices, our website, PCs or on other platforms , such as Facebooak, as well as our marketing and/or advertising activities on all platforms. We refer to our games, our games’ online functionalities, our mobile apps, our marketing and advertising activities, our websites and our other services collectively as our “Services” in this Privacy Policy.

We process your personal data in line with this Privacy Policy and the Serbian Law on Personal Data Protection, EU General Data Protection Regulation and all other applicable national data protection regulations.

By downloading and playing our games or interacting with our other Services you confirm that you have been properly informed about the processing of your personal data in line with this Privacy Policy. If you have any concerns about providing information or it being used as described in this Privacy Policy, or disagree in any other way, please do not use our games or other Services.

Types of personal data processed and the manner of processing

Personal data means any information relating to an identified natural person or a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We process your personal data when you download and/or play our games or use any of our other Services. Personal data we process may be obtained from the following sources:

1. from you directly (through the game, website or online forms); 
2. from your device or browser; and/or
3. from advertising platforms (such as information about your interests) or any other third parties, service providers that are assisting us in providing you with a service, or from your social networks accounts you used to sign in to our online services (for example, Facebook or Google).

We may process the following types of your personal data, depending on which of our Services you interact with:

1. contact information (such as name or nickname or email you submit when you register or log-in for our Services or via social networks);
2. data about your account and game progress;
3. your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
4. data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language;
5. preferences regarding online marketing;
6. broad location data (e.g. country or city-level location);
7. geolocation data (GPS, with your consent);
8. data we collect through the use of cookies and similar technologies;
9. data (such as your nickname, profile picture) we receive if you link a third party tool with the Services (such as Facebook or Google);
10. details of orders (amount spent, date, time, vouchers or offers used);
11. billing information (payment card number, payment account details and shipping address);
12. data to fight fraud (such as refund abuse in games or click fraud in advertising);
13. data from platforms that the games run on (such as to verify payment);
14. data for advertising and analytics purposes, so we can provide you with better Services;
15. your messages to the Services (such as chat logs and player support tickets) any feedback you submitted about your experience with us; and/or
16. other data you choose to give us.

All this information will be processed as described in this Privacy Policy.

You are responsible for any personal information of third parties obtained, published or shared through our games and confirm that you have the third party’s consent to provide the information to us.

Minors’ personal data

We do not knowingly collect personal data about or direct or target interest based advertising to anyone under the age of 15 or knowingly allow such persons to use our Services. If you are under 15, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 15 may provide any personal data. If we learn that we have collected personal data about a child under age of 15, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 15, please contact us by using the e-mail specified in CONTACT US Section below

As far as is permitted by applicable legislation, we accept no responsibility regarding any activities which may be conducted by minors without the consent of their parents or legal guardians, when such consent is legally required. In all cases, use of the Services by minors must take place under the responsibility of their parents or legal guardians and any use of the Services is assumed to have been validated by them. If you are a parent or guardian, we recommend that you monitor your children’s gaming activities, in particular online and that you familiarize yourself with the parental controls that may be made available by us and/or our partners. 

If you are a parent or legal guardian and you give your permission for processing of personal data of your child, you thereby agree to the processing of their personal data in line with this privacy policy.

Why do we collect your personal data and what are our lawful bases for it?

We may use your personal data to:

1. provide you with our products or services (for example, play one of our online games and make online purchases);
2. to optimize provision of our Services for you and the device you are using;
3. learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us);
4. ensure confidentiality of personal information or prevent unauthorized access and modifications to our systems or prevent fraud;
5. with your explicit prior consent, let you know about our products, services and events that may be of interest to you by email or other forms of electronic communication.
6. Legal basis for the processing of your personal data differs from case to case, but it usually includes one of the following:
7. performance of a contract or performance of activities prior to conclusion of the contract at your request – for example, we use this legal basis when processing your personal data which is necessary for provision of our Services, such as your contact information;
8. fulfilment of our legal obligations (e.g. to report any criminal activity we learn about in relation to our Services, in accordance with applicable laws);
9. pursuing our legitimate interests or legitimate interests of a third party, under the condition that your interests or fundamental rights and freedoms do not override those interests – e.g. we use this legal basis when processing your information which is necessary in order to optimize our services, such as data about your device or data for advertising and analytics purposes;
10. your consent – e.g. for direct marketing purposes.

Where we use your consent as the legal basis for personal data processing, you have the right to withdraw the provided consent at any time. Upon withdrawal, we will cease with the processing of personal data we processed on the basis of your consent. However, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

How long do we keep your personal data?

We will keep your personal data only for as long as necessary for the realization of the aforementioned purpose(s) of the personal data processing or until withdrawal of consent for the processing of the personal data if consent is a legal basis for a particular processing and the person to whom the particular personal data relates decides to withdraw his/her previously provided consent. If consent is the legal basis for personal data processing in the particular case, we will, in the case of its withdrawal, terminate the processing upon the respective withdrawal, unless there is another statutory ground for the particular processing.

Who do we share your personal data with?

We do not share your personal data except as approved by you or as described below:

1. With your consent, for example, when you agree to our sharing your information with third parties for their own marketing purposes subject to their separate privacy policies.
2. We may engage other companies and individuals to perform services on our behalf. Example of these services include analyzing data. These agents and service providers may have access to your personal data in connection with the performance of services for us.
3. We may release your information as permitted by law or when we believe that release is appropriate to comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
4. We may share your information to our affiliates and in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company.
5. We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

We may transfer information that we collect about you to affiliated entities, or to other third parties, which may also be located out of the Republic of Serbia and/or European Economic Area. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. In cases where your personal data is transferred to one of the countries which do not ensure an adequate level of personal data protection in accordance with the applicable laws, we implement these appropriate safeguards, including by using standard contractual clauses, binding corporate rules, codes of conduct, certification mechanisms, approvals issued by the data protection authority and similar. You may request further information about these measures and obtain copies thereof by contacting us using the e-mail specified in Contact us Section below.

Your rights

You are entitled to obtain information from us on how we handle your personal data, to obtain copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also restrict or object to the processing of your personal data.

We do not carry out any decision-making based solely on automated processing, including profiling.

If you gave us your consent to use your personal data, e.g. so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.

You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so or legitimate interests of third parties. We explained the legitimate interests we rely on in sections ‘Why do we collect your personal data and what are our lawful bases for it?’ above.

In case you think that we do not process your personal data in line with the applicable laws, you have a right to the legal protection, including the right to lodge a complaint to the Serbian Commissioner for Information of Public Importance and Personal Data Protection and/or another relevant national data protection authority, as well as the right to reach out to a court in order to protect your rights.

If you would like to exercise any of your above rights, contact us using the contact details specified in Contact us Section below.

Changes to this Privacy Policy

This Privacy Policy may be updated from time to time and it will be posted on this page. Please make sure to be familiar with the latest version of this Privacy Policy by checking this page regularly. Please note that any new policy will be effective from the date it is published by us. Your usage of the Services or continuance to use the Services after such publishing shall be understood as your acceptance of such new Privacy Policy.

Contact us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, you can contact us via email gordana.buhac@digital-arrow.com .

Privacy Policy was last updated on 06.04.2021.