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 Overmobile Limited Liability Company (hereinafter referred to as “Overmobile”) when you use the gaming software “Pocket Tower” that is comprised of the software programs and databases having the form of: i) software application for Android and IOs mobile devices (hereinafter – the Mobile application); ii) the set of websites, forums, chats available at the sections and sub-domains of the common domain at https://tower.game; iii) gaming applications available within social networks and other third party online-resources;

USER’S CONSENT:

By accepting this Policy, you 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.

1. General Provisions

   1. This Policy is an integral part of the License Agreement for the Game that is posted and/or available on the Internet at https://appru.nebo.mobi/nebo-support/license-en.html (hereinafter referred to as the “Agreement”). Therefore, when executing the above said Agreement by methods defined therein including by starting the use of the Game you fully accept the terms of this Policy.

   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 (distribution, provision, access) including transfer to the territories of the foreign countries, depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.

   3. The terms and definitions provided for by the Agreement are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.

2. Personal Information

   1. Personal Information in this Policy means as follows:

      1. Information that User provides about him/her upon authorization as well as during further use of the Game.

1. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software including operating system of User’s device.

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

3. To use the Game, the User doesn’t have to perform authorization and provide information about himself/herself.

Registration and authorization with the Game is implemented with use of such authentication services as Facebook, Vkontakte, Odnoklassniki, Google Play, Apple Sign in, etc. Upon authorization User provides personal information through use of such authentication service as follows: identifier in relevant authentication service . In order to fill out an account in the Game, the User can also provide the following personal data about himself/herself: nickname.

To pay for the license to the Extended version of the Game via mobile operator, the User provides mobile phone number.

The User’s activity in the Game is recorded in the Game’s databases and server logs.

4. User acknowledges and accepts that at use of the Game depersonalized (anonymous) data may be collected automatically, including by the third party software in the Game.

The aforementioned third party software may include following analytic systems:

• App Center, that is a software product of Microsoft, that collects and processes data according to privacy statement available at: https://privacy.microsoft.com/ru-ru/privacystatement ;

• Firebase, that is a software product of Google, that collects and processes data according to data use policy available at: https://policies.google.com/privacy;

• Facebook Analytics, that collects and processes data according to data use policy available at: https://web.facebook.com/full_data_use_policy?_rdc=1&_rdr

• Devtodev, that collects and processes data according to privacy policy available at: https://www.devtodev.com/policy;

• IronSource, that collects and processes data according to privacy policy available at: https://www.ironsrc.com/wp-content/uploads/2017/01/ironSource-Privacy-Policy.pdf

The above mentioned list of the third party software is not limiting. Overmobile may use other similar services (software) and/or cease the use of the listed one.

Anonymous data collected with such third party software may include:

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

• query data (time, source, IP address);

• other information about User’s activity in the Game.

The scope and conditions for collection and use of anonymous data by such software’s titleholders are determined directly by their 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.

5. Overmobile 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

The legal basis on which Overmobile relies for the use of Personal information includes:

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

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

3. Processing of Personal information that is necessary for pursuing the Overmobile’s legitimate interests. Specifically, the Overmobile’s legitimate interests consist of ensuring safety and improving functionality of the Game; of data analysis; settlement of conflicts during the gaming process, protection Overmobile and the Users from fraud.

1. Policy with regard to children

   1. Overmobile does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Game. If Overmobile gets to know that the information was collected from a child under 16, Overmobile shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail indicated herein.

2. Purposes for Personal Information Processing

   1. Overmobile performs processing, including collection and storage only personal data that is required for entering into and executing agreements with the User.

   2. Overmobile is entitled to use the Personal Information for the following purposes:

1. Identification of the User within the fulfillment of the Agreement.

Registered and authorized User is identified by identifier in relevant authentication service. The User that paid for the license to the Extended version of the Game is identified by mobile phone number.

2. Fulfillment of obligations under the Agreement, including providing the User with an opportunity to use the Game.

Within the scope of the relevant functionality of the Game Overmobile stores, organizes and displays in the Game the profiles of registered Users.

Payment for the license to the Extended version of the Game via mobile operator requires the User’s mobile phone number.

3. Communication with the User as informational servicing within the Agreement and/or improvement of the Game’s quality;

User may be served with informational SMS to the mobile phone number. User has the right to give up on such communications at any time and turn them off by following the instructions in SMS or by sending relevant request at pt.support@overmobile.net

4. Marketing, statistical and other research based on anonymous data from the analytics systems stipulated in the paragraph 2.4 hereof.

Anonymous data stipulated in the paragraph 2.4 hereof is collected and analyzed to get an insight on the Users’ interests and preferences.

5. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 2.4 hereof.

Anonymous data stipulated in the paragraph 2.4 hereof may be used to provide advertisements which you can be interested in.

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

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

1. to be informed about the collection and use of his/her personal data.

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

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 Overmobile no longer needs the personal data for the purposes for which Overmobile has processed it.

4. to object to the processing of his/her personal data and also restrict its processing in those instances where Overmobile 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. 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 Overmobile that is based on the consent User had given before he/she withdrew it.

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.

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.

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

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

1. Personal Information Storage Retention

   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, Overmobile 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 Overmobile, whether or not any requests made by User from Overmobile have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Overmobile, 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, Overmobile will update its systems.

2. Requirements for the Personal Information Protection

   1. Overmobile stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.

   2. With regard to the User’s Personal Information, its confidentiality is protected, except for the cases when the technology of the Game or the configuration of the User’s software provides for an open exchange of information with other Users of the Game or with any Internet users.

3. Transfer of the Personal Information

   1. Overmobile is entitled to transfer Personal Information to third parties in the following cases:

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

2. The transfer is necessary in the context of the User’s use of the Game’s functionality;

3. In connection with the Overmobile’s use of the services of third party providers. Such third party providers receive Personal Information under the confidentiality conditions and solely for the purposes of rendering services to Overmobile.

4. In connection with use in Game of third party software for collection and processing of User’s data. Specifically, Overmobile may use the third party software for collection and processing of User’s data according to clause 2.4. of this Policy.

5. Due to whole or partial transfer of Overmobile’s assets to the third party, including assignment of rights under agreements concluded with the User in benefit of such third party;

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

7. To protect the rights and legitimate interests of Overmobile in connection with failure to comply with the agreements entered into with the User.

10. Amendments to and deletion of the Personal Information

1. User may send request for amendment or deletion of the Personal information to Overmobile to the email address stated below in this Policy.

2. Any questions and requests related to this Policy, use, amendment, deletion of the User’s Personal Information and/or exercising of any User’s rights with respect to the Personal Information can be mailed to Overmobile to the email address stated below.

11. Amendments to the Privacy Policy

1. This Policy may be amended or terminated unilaterally by Overmobile without prior notice to the User. The User is recommended to read this Policy in the current version regularly.

2. The new version of the Policy becomes effective upon its placement, unless otherwise provided for by the new version of the Policy.

3. The current version of the Policy is available at: https://appru.nebo.mobi/nebo-support/policy-en.html

12. Advertising

1. We use advertising to fund our Services and to make our games available for free. We offer our Games for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our website and Games and – at the same time – keep our Games free for a wide player base. As a European-based company, when you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at relevant button at loading of the Game. The purpose is to improve our Games and provide the player with more relevant ads. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you ACCEPT to show you personalized ads at loading of the Game. The legal basis to show personalized ads is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Game settings and clicking the terms & Privacy button therein, in section ‘Personalized Ads Consent Withdrawal’ of the Privacy Policy you will be able to manage your preferences by choosing to which advertising you would like to get. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using. In-game advertising (i.e. when you view ads in Our Games) To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks).

2. Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:

   ● limit the number of times you see the same ad;

   ● ensure they are dealing with humans with real devices and not ‘automated’ bots;

   ● serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;

   ● keep track what games you have used to market you similar kind of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).

Overmobile LLC

Address: Russia, Novosibirsk city, Mysi Djalilya street, building 3/1, office 507, P.O. 630055.

State registration number (OGRN): 1115476129603. Tax registration number (INN): 5408290672

e-mail: pt.support@overmobile.net

The current version of the Policy of March 22nd, 2024