This information on the processing of personal data is addressed to the customers (players) of Flyboys Games s.r.o., who are primarily users (“Players”) of our software products (“Games”). Our company is committed to the proper processing of its customers’ personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council (General Data Protection Regulation, referred to as “GDPR”) as well as California’s Assembly Bill No. 375 (California Consumer Privacy Act, referred to as “CCPA”) and relevant Czech legislation.
Please, follow the text below to acquaint yourself with the processing of your personal data. The purpose of this document is to provide you with a clear understanding of why we process your personal data, how we process it, your rights in relation to this processing, and other relevant information.
A. Terms related to the process of assessment of personal data B. Who is the controller of your personal data? C. Which personal data are we processing? D. From which source are we collecting your personal data? E. What are the main purposes for processing your personal data? F. To whom can your personal data be provided? G. Where are your personal data being processed? H. How long do we keep your personal data? I. Profiling and the process of an automated decision J. Your rights related to processing of your personal data K. Inappropriate behavior and rule violations L. How can you get more information and enforce your rights?
Please familiarize yourself with the basic terms listed in this document, which can be useful for a better understanding.
The controller of your personal data is Flyboys Games s.r.o. with registered residence: Chomutovská 215, Klášterec nad Ohří, Czech Republic, IČO: 24689599, registered in the Commercial Register of the District Court KSUL Krajský soud v Ústí nad Labem, insertion no. C 35979 (hereinafter referred to as “Company”). The Company determines the purpose and methods of processing your personal data.
Basic information about Company: Chomutovská 215, Klášterec nad Ohří, Czech Republic.
For questions concerning the processing of your personal data by the Company, feel free to contact us via [email protected].
The Company collects and processes personal data necessary to provide you with products and services or, where appropriate, to protect itself and its legitimate interests. The Company primarily processes the following categories of personal data about its customers (Players):
The listed categories are also the types of personal information that the Company has collected from its customers within the last twelve (12) months.
The Company collects your personal data primarily from you, especially when accepting the mutual (contractual) agreement about software use (EULA), completing surveys, or contacting us through player support requests or customer service. Your personal data can also be collected from other subjects – third parties, e.g., Facebook, Google, Apple, Amazon, Steam, Samsung, WizQ, but only based on your authorization provided to these subjects to grant your data to the Company.
For the purpose of concluding and fulfilling the contract
Due to the process of conclusion and fulfillment of the contract, the Company processes your personal data to provide access to the software (Games) of the Company for the user (Player), to provide player support and improve the quality of services provided by the Company, necessary for the proper function through updates and enhancements, enhancing the game environment, and providing new functionalities. For this purpose, the Company may follow your interactions with the Company, monitor different areas of your interest, and use your information to personalize our communication with you, including offering in-game surveys. The collected data can also be used for purposes of optimizing and improving the content of services provided to you by the Company as part of the software and to detect potential malfunctions and errors.
Collected and processed data by the Company may also be used to compile and publish general statistical reports to extend and customize services provided to players, appealing to their preferences. These data do not contain information that could lead to the identification of any individual.
Data collected by the Company for the designed purposes are processed based on the contractual agreement between the Company and end-users – Players – in the form of defined licensing terms and agreements about the use of products and services provided by the Company (EULA).
The EULA is a contract in accordance with Article 6, point 1, letter b) GDPR for determining the legal basis for processing personal data.
For the needs of the above-defined purposes, the Company processes personal data mentioned in Section C of this Policy, as well as the following personal data of the players:
For the purpose of direct marketing
Under the conditions of its software (game), the Company also uses the functionality of so-called “banners,” through which the player is offered “gems” (a specific kind of payment under the conditions of each game). This menu is displayed to the players while using software (playing the game) as one of the options within the game settings or menu. The player can purchase additional options, extensions, accessories, or other functionalities within the terms of a specific game through these menus.
Based on a similar approach, various limited offers (so-called “premium items”) are promoted to purchase special editions of particular elements under the conditions of the software.
These activities represent the form of direct marketing used by the Company (in relation to aforementioned regulations) oriented at specific players and addressing their potential needs.
The Company implements these activities only under the conditions of the software (game) itself. The use of these activities does not lead players to the process of purchase, nor does it limit them in common use of the game.
According to GDPR, the legal basis for processing your personal data in terms of this form of marketing is the legitimate interest of the Company in accordance with Article 6, point 1, letter f) and in accordance with section 47 of the GDPR.
For the direct marketing purposes, the Company processes the following personal data of players:
In-App Purchases
All in-app purchases must be made through the official platforms provided by Google or Apple. Any purchases made through unofficial platforms will be considered a violation of the terms and may result in the termination of the player's account.
We process your personal data to the fullest extent possible internally within the Company. Your personal data is provided to other subjects only when necessary to achieve the purpose of processing.
We do not sell your personal data to other businesses. Your personal data might, in some cases, be disclosed to and processed by our intermediaries for business purposes (see below); however, personal data is not shared
for monetary or other valuable consideration.
In the preceding twelve (12) months, we have not sold personal data. Our policy is that we do not and will not sell the personal data of our customers (Players).
Intermediaries
The Company cooperates with external subjects, which process personal data under the name of the Company (“Intermediaries”). Intermediaries process personal data based on a contract between the Company and the intermediary. Current company intermediaries include:
The purpose of intermediaries’ services is to collect, store, and provide data necessary for the basic and distributed operation of services provided by the Company within the offered software, as well as providing the basic infrastructure for the operation of specific functionalities and software components.
In the preceding twelve (12) months, we have disclosed the following categories of personal information to our intermediaries for business purposes:
Public authorities
Your personal data can be provided to public authorities in case of imposition by law or if this advance is necessary for the fulfillment of legal obligations. Public authorities include courts and authorities involved in criminal investigations, etc.
Your personal data is processed on servers within cloud services provided by third parties based on a contract between the Company and the particular third party. These companies are considered intermediaries from the perspective of personal data processing.
The Company processes your personal data for as long as necessary for the duration of the EULA’s contractual relations.
The Company applies the principle of minimization, which means that after the processing duration expires, the personal data will be anonymized or deleted from databases and information systems of the Company, at the latest ten years after the termination of a contractual obligation of EULA.
The Company does not implement automatic individualized decision-making, including profiling, that could cause legal effects on you.
You have the following rights concerning the processing of your personal data:
Flyboys Games s.r.o. maintains a strict policy against inappropriate behavior and violations of our rules, including but not limited to:
Violating any of these rules may result in the termination of your account without prior notice. Flyboys Games s.r.o. reserves the right to enforce these rules at its sole discretion.
If you have questions about the processing of your personal data or want to know more information, you can contact us by writing to Flyboys Games s.r.o., Chomutovská 215, Klášterec nad Ohří, Czech Republic, or by e-mail at [email protected].
This document will be regularly updated. Status as of 1.1.2023.