Welcome to the Commando Panda sp. z o.o. Privacy Policy. In this privacy policy, we seek to clearly explain to you how we collect, use, process, and share your information. Please read this privacy policy carefully; it will help you make informed decisions about sharing your personal information with us. If you have any questions or concerns about this policy or our practices with regards to your personal information please contact us at contact@commandopanda.com.
Personal data information
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
The controller of the personal data you provide is Commando Panda spółka z ograniczoną odpowiedzialnością based in Warszawa (02-495), having Tax Identification Number (NIP number: 5223264603 and REGON number: 525859919).
Commando Panda sp. z o.o. (“Commando Panda”, “Data controller”, “us”, “we”, or “our”) operates the mobile applications (hereinafter referred to as the “Service”).
1. Which personal data do we process?
We process only the basic personal data such as your nickname, device ID, your IP. Sometimes you can also give us other details – e-mail address, gender, first name, surname. Remember that when you are using your Facebook account to log in, we are getting more information about you and more data.
1.1 Usage data
When you access our servers via mobile app, we may automatically log the standard usage data provided by your device. This data may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information that may ¬have contributed to the problem.
1.2 Device data
Our app may also access and collect data via your device’s in-built tools, such as:
• Your identity
• Notifications
What we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
1.3 Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
• Name and last name
• Email address
• Social media profiles
• Mailing address
1.4 Business data
Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.
2. The purposes of the processing
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
The main purpose for which we process your data is the implementation of our basic service – games. Thanks to the fact that we have your data, you can play our games.
If you have agreed to this, your data you gave us will be used for marketing purposes. We will send you messages containing information about available promotions, events, competitions and bonuses. If you have provided data other than an email address, we will be able to personalize offers and messages especially for you. Thanks to this you will receive information corresponding to your interests and preferences. No one likes vague spam.
In order to be able to constantly improve our service, we process the data you provided to us for statistical and research purposes. We want to be better and better, that’s why we need to know our users perfectly.
To ensure the highest quality of the services we provide, we have created a system that allows us to prevent fraud. There is no place for dishonest players in our service. That’s why we process personal data to ensure your security and protect you from fraudsters.
Collection and use of information
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
• for technical assessment, including to operate and improve our app, associated applications and associated social media platforms;
• to provide you with our app and platform’s core features;
• to process any transactional or ongoing payments;
• to contact and communicate with you;
• for internal record keeping and administrative purposes;
• for analytics, market research and business development, including to operate and improve our app, associated applications and associated social media platforms;
• to run competitions and/or offer additional benefits to you;
• for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
• to comply with our legal obligations and resolve any disputes that we may have.
3. The basis of processing
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
The data you provide by registering in our game, we process on the basis of the contract we conclude with you.
The data you provide voluntarily for marketing purposes is processed by us based on your consent, which can be withdrawn at any time.
The data you provide voluntarily is also used for statistical and research purposes. The basis for their processing is our legitimate interest. We need to know what is happening in our service and we try to constantly improve it.
The data we process for security purposes, i.e. the activity of players, their logins, e-mail addresses and other data if provided, we process based on our legitimate interest. We want to prevent fraud. In this respect, we use profiling but as a result, no automatic decisions are made. The last word is always left for human.
If you are from the European Economic Area (EEA), Commando Panda sp. z o.o. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Commando Panda sp. z o.o. may process your Personal Data because:
• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law
4. Who get your data from us?
4.1 General information
To ensure the highest quality of services, we use the services of external suppliers. We choose our partners extremely carefully. We may give your data to hosting companies, IT companies, statistical and research apps, support apps and other providers. We may disclose personal information to third party service providers for the purpose of enabling them to provide their services, including h IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators.
4.2 International transfers of personal information
We transfer your data to processors established in countries outside the European Union. Data protection standards in these countries are high. By providing us with your personal information, you consent to the disclosure to these overseas third parties.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
4.3 Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
4.4 Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
4.5 Advertising
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
4.6 Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
4.7 Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
4.8 Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Commando Panda sp. z o.o. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Commando Panda sp. z o.o. may disclose your Personal Data in the good faith belief that such action is necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of Commando Panda sp. z o.o.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
5. Your rights
Remember that:
• you have the right to withdraw your consent at any time. It will not have negative consequences for the game itself, We will simply stop sending marketing messages to you. Withdrawal of consent is, of course, without any impact on the processing based on given consent. If you want to withdraw consent, edit your profile details or write to us.
• you have the right to request access to your personal data;
• you have the right to rectify your personal data and even delete them. Deleting data that is necessary to provide the service means that you delete the account.
• you have the right to object to the processing of data and demand a restriction of this processing;
• in relation to data whose consent is based on consent, you have the right to request their transfer;
• you have the right to lodge a complaint with a supervisory authority;
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
If you have any doubts, questions or would like to learn more, write to us. You can contact us via email.
6. How long do we store your data?
As long as you are with us, your data is processed by us. When you delete your account, your data will still be stored by us only during the period of limitation of claims.
Commando Panda sp. z o.o. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Commando Panda sp. z o.o. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
7. Other
7.1 Children’s Privacy
We do not knowingly collect personally identifiable information from anyone under the age of 16 without consent from a child’s parent. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data without your consent, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
7.2 Changes to this policy
At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our app or app delivery service. Your continued use of our app after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.
If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.
7.3 Limits of our policy
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
7.4 Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
8. Advertisements
8.1 Advertisements general
In addition to ads for our Services, we accept advertisements, in various formats (such as banners, interstitials, rewarded videos, etc.) from third-party ad networks that may be displayed in our Games. These third-party ad networks may collect and use information about your interaction with our Services in connection with such marketing, sales and advertising activities; geographic tracking and carrier network preferences; and information, such as age and gender logged from your device to ensure that appropriate advertising is presented within the Game and calculate or control the number of views of an ad, and/or deliver advertisements relating to your interests, and measure the effectiveness of advertisements campaigns.
Note that if you click on any of these advertisements, the advertisers may use cookies and other web-tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) on your device to collect data regarding advertisement performance, your interaction with such advertisements and our Services, and your interests in order to serve you advertisements, including targeted advertisements, and for the legitimate business interests of such third-party ad networks. This data may include your personal information such as device and network information, unique identifiers, gender, age, and geo-location. We recommend that you review the terms of use and privacy policy of any third-party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.
8.2 Links to third parties
We may insert links to third parties on the Website and in our Games. This Policy does not apply to such third-party websites. These links take you outside our Services and are beyond our control. This includes links from partners that may use Iron Horse’s logos as part of a co-branding agreement. The sites those links take you to have their own separate privacy policy and although we seek to protect the integrity of our Website, Commando Panda sp. z o.o. is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.
8.3 Ad identifiers, cookies, other tracking technologies
To provide our Games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. Please read this section to understand our use of these technologies and how you can manage your preferences.
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
A cookie is a small string of information that a website you visit transfers to your device for identification purposes. Cookies can be used to follow your online activity on the website and that information helps us to understand your preferences and improve your experience. Cookies are also used for such activities as remembering your user name and password, if such feature is available and you choose to use it.
Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
• recognize you and your device;
• provide interest-based advertising to you;
• allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
• enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.
You can turn off all cookies, in case you prefer not to receive them. You can also have your device warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the Services’ functionality and you may lose access to some of its features.
8.4 Adjusting interest based advertising preferences
You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings.
If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices(for Canadian users). You can also click on the AdChoices logo within an advertisement (where available). If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.
Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).
9. Information for EU Citizens
You have the right to request & obtain deletion of your personal information collected through our Services.
If you would like to exercise the right, please send your request at contact@commandopanda.com (please note that if your request is sent to any other Commando Panda email, we are unable to guarantee its receipt & further processing). We will aim to respond to your request within 30 days from the initial receipt of the request. In order to realize your right, we need to identify you as the original account owner. You acknowledge and agree that for this purpose we shall request additional personal information from you, such as photos and copies of your documents that you will need to provide. Provision of these documents is obligatory to avoid fraud and make sure your account is secure from possible damage.
Please note that deletion of your personal data will be followed by deletion of the related information, such as your in-game progress, including your level, purchased content licenses (including real money purchases) and any in-game content associated with the account. The restoration will be impossible. By requesting to delete your personal data, you acknowledge and accept this fact and approve the deletion of this related information.
Please note, that in case your consent to processing is withdrawn by you, you may still not be able to access Commando Panda Services anymore.
Please keep in mind that all correspondence regarding the personal data deletion can only be held in English.
CONTACT US
You can always contact us. We will try to help you!
If you have any questions about this Privacy Policy, please contact us:
By email: contact@commandopanda.com
