Privacy Policy

 

This document “Privacy Policy” (hereinafter referred to as “Policy”) is the terms and conditions for collection and use of the Personal information of the User (hereinafter referred to also as “You”) by Code Prime FZ-LLC (hereinafter referred to as “Code Prime”) during download, installation and use of the mobile application Drag Racing (hereinafter referred to as “Mobile application”).

 

USER’S CONSENT:

By accepting this Policy you (hereinafter also referred to as “User”) with your own free will and for your benefit give your written consent to the processing of User’s Personal Information for the purposes and under the terms and conditions stipulated by this Policy.

In case you are minor this Policy must be accepted and the consent to the processing of your data must be given, depending on your age, either by you subject to consent of your parent/guardian or by your parent/guardian on your behalf.

 

1. General Provisions

1.1. This Policy is an integral part of the End User License Agreement for the Mobile application (hereinafter referred to as the “EULA”). Therefore, when executing the above said EULA by methods defined therein including by downloading, installation and using the Mobile application you fully accept the terms of this Policy.

1.2. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.

 

2. Personal Information

2.1. Personal information in this Policy means as follows:

2.1.1. Information that the User provides about him/her upon registration or authorization as well as during further use of the Mobile application.

2.1.2. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software.

2.2.  Code Prime is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Mobile application. If certain information is not marked by Code Prime as mandatory, it is provided or disclosed by the User at his/her discretion.

2.3. Registration and authorization with the Mobile application is implemented with use of authentication services of Facebook, Vkontakte, Odnoklassniki, Play Games (Google), Huawei ID, Apple ID. Upon registration User through use of such authentication service or on its own provides Personal information as follows: name and photo (avatar).

Upon the registration the User’s account with unique identifier (ID) is created. Such User’s account contains, in addition to the information provided at registration, also information on the User’s game process (in-game resources, achievements, awards, etc.)

2.4. User acknowledges and accepts the possibility of using third party software in the Mobile application and/or the Service; as a result, Code Prime and such third parties can receive and transmit the data indicated in clause 2.1.2. in a depersonalized form.

The aforementioned third party software includes the following analytics services:

‘Google Analytics’ that collects and processes data according to privacy policy available at: https://policies.google.com/privacy;

‘Flurry’ that collects and processes data according to privacy policy available at: https://legal.yahoo.com/us/en/yahoo/privacy/index.html;

Such data collected with third party software may include:

User’s device data, including unique identifiers of User’s device, its location (country and city), operating system data (type, version, screen resolution) and so on;

query data (time, source, IP address);

other information about User’s activity in the Mobile application.

The scope and conditions for collection and use of impersonal data by such software’s titleholders are determined directly by its titleholders and governed by documents available at their websites.

Accepting this Policy as well applying certain setting in his/her software including device’s operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.

2.5.  Code Prime will not verify the reliability of the provided Personal Information and whether the User has the necessary consent for the processing thereof in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to keep such information up to date and obtain all necessary agreements of the subjects of personal data.

 

3. Legal basis of processing of Personal information

3.1. The legal basis on which Code Prime relies for the use of Personal information includes:

3.1.1.Processing of Personal information where User has given consent for one or more specific purposes;

3.1.2.Processing of Personal information that is necessary for performing a contract to which User is a party;

3.1.3.Processing of Personal information that is necessary for pursuing the legitimate interests of Code Prime. Specifically, the legitimate interests of Code Prime consist of ensuring safety and improving functionality of the Mobile application; of data analysis; of protection of Code Prime and the Users from fraud.

 

4. Purposes for Personal Information Processing

4.1.  Code Prime is entitled to use the Personal Information for the following purposes:

4.1.1. Identification of the User for establishing of and access to the User’s account in the Mobile application.

4.1.2. Fulfillment of obligations under the EULA, including provision the User with access to the functionality of the Mobile application. Within the scope of the relevant functionality of the Mobile application Code Prime stores, organizes and displays in the Mobile application the information added by User to the User’s account.

4.1.3. Communication with the User for the purpose of technical support and improving the quality of the Mobile application;

4.1.4. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 2.4. hereof for the purpose of improvement of the Mobile application and/or the Service.

 

5. User’s Rights to User’s Personal Information

5.1. Subject to specific provisions of applicable law, the User has the right:

5.1.1. To be informed about the collection and use of his/her personal data.

5.1.2. To access his/her personal data and have it corrected if it is wrong or incomplete.

5.1.3. To restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Code Prime no longer needs the personal data for the purposes for which Code Prime has processed it.

5.1.4. To object to the processing of his/her personal data and also restrict its processing in those instances where Code Prime undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.

5.1.5. To withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Code Prime that is based on the consent User had given before he/she withdrew it.

5.1.6. To obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.

5.1.7. Not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.

5.1.8. To receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Code Prime processes by automated means personal data that User has provided.

5.2. These rights may be exercised by contacting Code Prime with specific request through the methods described below. Code Prime will address any such requests in a timely manner and according to applicable law. In certain cases, Code Prime may ask User to verify identity before acting on User’s request. If User is unsatisfied with the response of Code Prime, User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.

 

6. Personal Information Storage Retention

6.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Code Prime will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Code Prime, whether or not any requests made by User from Code Prime have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Code Prime, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, Code Prime will update its systems.

 

7. Requirements for the Personal Information Protection

7.1.  Code Prime stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.

7.2. With regard to the User’s Personal Information, its confidentiality is protected, except for the cases when the technology of the Mobile application or the configuration of the User’s software provides for an open exchange of information with other Users of the Mobile application or third parties via Internet.

 

8. Transfer of the Personal Information

8.1.  Code Prime is entitled to transfer Personal Information to third parties in the following cases:

8.1.1. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that specifically allow or do not limit the provision of certain information;

8.1.2. The transfer is performed as relevant function of the Mobile application;

8.1.3. In connection with use in the Mobile application of third party software for collection and processing of User’s data. Specifically, Code Prime may use the third party software for collection and processing of User’s data according to clause 2.4. of this Policy.

8.1.4. In connection with use of the services of third party providers by Code Prime. Such third party providers receive Personal Information solely for the purposes of rendering services for Code Prime. Specifically, User’s Personal information may be stored and processed by third party cloud platforms, such as Apple iCloud, Google Cloud Platform, Amazon AWS, etc.

8.1.5. Due to the transfer of the Mobile application to the possession, use or property of a third party, including the assignment of rights under contracts concluded with the User in benefit of such third party;

8.1.6. Upon request of a court or other state authority within the procedure established by law;

8.1.7. To protect the rights and legitimate interests of Code Prime in connection with breach of the agreements entered into with the User.

 

9. Amendments to and deletion of the Personal Information

9.1. The User is entitled at any time to independently delete or change, within the functionality of the Mobile application, his/her the Personal Information in his/her account.

9.2. The User is entitled to delete his/her own account as well as to exercise rights related to the processing of his/her personal data including right to erasure by sending to Code Prime a request at the address indicated below.

 

10. Amendments to the Privacy Policy

10.1. This Policy may be amended or terminated unilaterally by Code Prime without prior notice to the User.

10.2. The new version of the Policy becomes effective upon its publishing, unless otherwise is provided for by Code Prime for the new version of the Policy.

10.3. The current version of the Policy is available at: http://code-prime.org/legal/policy.html

 

 

Code Prime details

FZ-LLC “Code Prime”

License ¹ 100247

Address: Dubai, Dubai Internet City, Bldg 10

email: support@code-prime.org

 

The current version of the Policy of 12 October 2022