Privacy Policy

INTRODUCTION

Netigen Kluzowicz sp. j. (“Company” or “We”) provide internet and mobile app-based services including games and apps linked below ("Mobile Apps"):

Netigen Utilities  https://play.google.com/store/apps/dev?id=4882285065316981984

Netigen https://play.google.com/store/apps/dev?id=6225048255144253010

Netigen Tool https://play.google.com/store/apps/dev?id=8393924255291119513

Netigen Music Tuners https://play.google.com/store/apps/dev?id=7420477601195733723

Real Drums https://play.google.com/store/apps/dev?id=8741035511168472898

Netigen Games https://play.google.com/store/apps/dev?id=9071744231135171838

Netigen Unicorns https://play.google.com/store/apps/dev?id=7501858847402947482

Netigen Entertainment https://play.google.com/store/apps/developer?id=NETIGEN+Entertainment
iTunes account: https://itunes.apple.com/us/developer/netigen-kluzowicz-sp-j/id892331873?mt=8

NETIGEN Kluzowicz respect your privacy and are committed to protecting it through our compliance with this Policy.  Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified at the time that we collect the information from you or as otherwise described in this Privacy Policy.

This Privacy Policy („Policy”) explains what information is collected and what are your legal rights. In order to use our apps or games („Services’) and for us to process your orders and requests, you do need to give us some personal information. However, we want you to know what information we need and why we need it. By accessing any of Company Services, you agree to the terms of this Policy (and any updates thereto). By so agreeing, you authorize us to collect and use your information as outlined below. In the event you do not agree with this Policy (and any amendments which may be adopted by us), your only recourse is to cease use of our Services.

 

Note to Residents of the European Union

In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

 

Note to Residents of the California Residents

We do not sell your Personal Data. If you are a California resident and the processing of Personal Information about you is subject to the California Consumer Privacy Act (CCPA), you have the right to access the personal information we’ve collected about you during the past 12 months and information about our data practices. You also have the right to request that we delete the Personal Information that we have collected from you.

You can exercise your CCPA rights by submitting your request to mobile@netigen.pl.

 

1. WHICH PERSONAL DATA WE COLLECT?

"Personal Data" is information that can be used to identify you, directly or indirectly, alone or together with other information. This may includes things such as your device IDs, certain cookie and network identifiers as well as location.

This may includes things such as your full name, email address, phone number, device IDs, certain cookie and network identifiers as well as location.We access geo-location information from your mobile device to help us share where you are in the world, provide locations to your posts and content, and display local activities and content based on your current location. You can control the collection of geo-location information through your device.

Netigen Kluzowicz sp.j. collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for purposes related to advertising, marketing (as further described in this Privacy Policy) as well as  attribution (e.g., measuring ad performance) analytics and research. This Privacy Policy relates to data about you, your devices, and your interaction with our Services.

NETIGEN Kluzowicz sp. j. and its partners also collect data to assess general information about the use of products, such as the number of visitors to our sites and services and which sections of a site or service are popular. We also use this data to provide contextually-relevant advertising to users, to prevent users from seeing the same ad repeatedly, and to allow users to personalize their experience on the site or service (for example, to save a high score in a game). NETIGEN Kluzowicz sp. j. and its partners may also use cookies, pixels, hardware-based identifiers, operating system-based identifiers, and software-set identifiers, to manage and measure the performance of advertising.

We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

 

2. HOW WE COLLECT AND USE PERSONAL DATA?

We collect your Personal Data in a number of ways and for various purposes, including:

  1. When you register for an account or interact with our Services.

We collect Personal Data when you use or interact with our Services, including when you register with us. This Personal Data may include name, address, phone number, username and password, email address, date of birth, photo and Location Data. "Location Data" means either approximate location or, with your consent, precise location. We use this data to create your account, enable your activity within our Services, and to provide the services generally, including to develop, enhance, and improve our Services and your experience. We also use this data for internal purposes related to certain research, analytics, innovation, testing, customer communication.

 

  1. When you communicate with us or sign up for promotional materials.

We collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages - including email address, etc.

If you consent to such messages, we may use your Personal Data and other information to communicate with you about Netigen products or Services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of Services we think may be of interest to you; and, for other marketing purposes.

 

  1. When you engage with our online communities or advertising.

We may collect your Personal Data when you engage with our online communities. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields.

 

  1. When you connect with us through social media.

You may choose to enable, log into, or sign on to the Services through various social media or social networking services, such as Facebook, Google+ or Twitter ("Social Networking Service" or "SNS"). When you connect using your SNS accounts, we may collect Personal Data that you have provided to that SNS. For example, when you log in with your Facebook credentials, with your consent, we may collect Personal Data from your Facebook profile that is permitted under Facebook's Terms of Use - such as your email address, profile picture, and friend list. We use this data to provide, enhance, and personalize the Services (e.g., to help connect you with or suggest friends within our Services). If you do not want to provide us with this data, you need to adjust the privacy settings on your SNS account.

 

  1. When we leverage and/or collect cookies, device IDs, Location and other tracking technologies.
    We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.

 

  1. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes.

We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

 

3. WHEN WE DISCLOSE PERSONAL DATA

We will not share any Personal Data that we have collected from or regarding you except as described below:

 

  1. To other Users/Registered Users in Netigen’s applications

With other users in the context of specific Services that are social in nature. In these cases, we disclose social data by default because the service being provided is one of social interaction.

 

  1. For Advertising and Marketing

With advertising and marketing partners for advertising and marketing purposes on Netigen’s behalf and on behalf of third parties. Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent.

 

Our current partners include:

  • MoPub, whose Privacy Policy can be found here.
  • Google Ad Mob - link to their Privacy Policy is here.
  • IronSource - here
  • Unity Ad - here

In addition, with your consent, we may share your precise Location Data with Third Parties for on and off platform personalization and curated marketing and advertising purposes.

 

  1. For Certain Analytics and Improvement

We are using certain analytic solutions such as for purpose of improvement of the Services.

 

  1. For Legal Compliance, Law Enforcement, and Public Safety Purposes

With law enforcement, government or regulatory bodies in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

 

  1. Vendors, Consultants and Other Service Providers.

We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

 

4. YOUR RIGHTS AND MANAGING PERSONAL DATA

In relation to the processing of your Personal Data, you have the right to:

  • requests from Company to access your Personal Data,
  • require Company to correct your Personal Data,
  • requests from Company to delete your Personal Data,
  • requests from Company to limit the processing of your Personal Data,
  • object to the processing of your Personal Data,
  • transferring your Personal Data,
  • lodge a complaint with a supervisory authority.

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your request. We offer the ability to correct, update or delete the collected information by contacting us via our email address mobile@netigen.pl.

 

5. THIRD PARTIES

Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage.

We may allow you to register and pay for third-party products and services or otherwise interact with another website, mobile application, or Internet location (collectively "Third Party Sites") through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services. We may share your Usage Data with third parties for the purposes described above.

Please be aware that if you are using our Services through a social network, platform or applications provider (“Third Party Service”) (e.g., iTunes, Google Play, Analytics etc.), any activities provided by such third party beyond NETIGEN Kluzowicz sp. j.’s Services are governed by that Third Party Service’s policies. We consider it a best practice for you to review the privacy policy of each website you frequent (as well as the privacy policies of any partners we may work with including advertisers) in order to be an informed consumer and to fully understand how your personal information is being handled.

We use the services of third parties who will have limited access to your Personal Information to be used for specific purposes. These purposes may include credit card processing, prize delivery, marketing assistance, customer service, and data analysis. The third parties we contract with for these purposes will be authorized to use your Personal Information only for the purposes for which the party was engaged. In addition, Non-Personal Information in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, and optimization.

We follow generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in our possession.

Links to Other Websites

Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.

 

6. IN APP PURCHASES

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the Google Play store via your account. All operations after purchase are controlled by Google Play store and are subject to specific terms of its.

If user is not satisfied by downloading our paid application, he has 24 hours (from the moment of payment) to send us information on our email address: mobile@netigen.pl about problems with app and demanding to get refund. We will return the money only when in app purchase is not working. When 24 hours pass, Netigen doesn't return money.

 

7. HOW DO WE PROTECT USER INFORMATION?

We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
We will not store your credit card information. In order to process credit card payments, we will use the service of a secure, third-party credit card processor.

 

8. HOW DO WE PROTECT CHILDREN’S PRIVACY?

This policy is prepared in accordance with the Children’s Online Privacy Protection Act (“COPPA”).  The Federal Trade Commission, the US nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of online services must do to protect children's privacy and safety online.

NETIGEN Kluzowicz sp. j. does not knowingly collect personal information from children under 13 years of age. If we learn that we have inadvertently gathered Personal Data from children under 13 years of age, NETIGEN Kluzowicz sp. j. will take reasonable measures to promptly delete such Personal Data from our records.

 

NETIGEN Kluzowicz sp. j. does not direct any interest-based advertising to children under 13 years of age.  All displayed ads are appropriate for children, and coming from Google Play certified ad networks.

If you are a parent of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at mobile@netigen.pl and we will delete the information from our system.

NETIGEN Kluzowicz sp. j. and its partners do collect non-personally identifiable data from children. This includes, for example, mobile device identifier, the frequency with which the child visits our applications, information regarding the mobile service provider or collection of IP-based geolocation data to ensure that the product, service or features served comply with applicable laws of that nation.

This information is collected to make applications more interesting and useful to children. This information may be collected by NETIGEN Kluzowicz sp. j. or by a third party. This data is used for own purposes only, in order to:

  • provide children with access to activities in our applications
  • develop content of Netigen applications
  • analyse the functioning of apps

 

9. POLICY CHANGES

We reserve the right to change this Privacy Policy at any time. In the event we make material changes to this Policy, such policy will be re-posted in the "Privacy" section of our Websites/Apps with the date such modifications were made indicated on the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to this Privacy Policy. Your continued use of the Websites/Apps after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Websites/Apps or opt out by sending us an appropriate notice.

 

10. COOKIES   

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile device (referred to here as a "device") browser from a website's server and is stored on your device's hard drive. Each website or third-party service provider used by the website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website or third-party service provider to access the cookies it has already sent to you, not the cookies sent to you by other sites or other third-party service providers. A cookie will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences.
 

What do cookies do?

Cookies record information about your online preferences and allow us to tailor the websites to your interests. Information supplied by cookies can help us to analyse your use of our sites and help us to provide you with a better user experience. For example, you may choose to personalise the content of a website in order to see the latest news and weather for your region. In order to do this, a cookie is placed on your device to remember where you live so that we deliver the information that has been requested by you. This is a prime example of how cookies are used to improve your experience of a website.
 

How do we use cookies?

Cookies enable us to identify your device, or you when you have logged in. We use cookies that are strictly necessary to enable you to move around the sites or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us to improve the performance of our sites to provide you with a better user experience.
Typically, we use cookies to deliver the following services throughout the pages of our sites:

- To enable us to recognise your device so you don't have to give the same information repeatedly;

- To recognise that you may have requested that we remember your username and password so you don't need to enter your details each time you visit a site;

- To record what people like and don’t like on the site and the popularity of various elements of the site so that we can ensure that it works properly at points of high usage.

 

11. CONTACT

If you have any questions or requests regarding this Privacy Policy you may contact us using the information below:

Email: mobile@netigen.pl

Postal address: Netigen Kluzowicz sp.j., ul. Dobrego Pasterza 19A/U3, 31-416 Kraków.