Last updated on 10/03/2020
Space Dev is aware of your concern about how your personal data is used and shared, and we take your privacy seriously. Please read what follows to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to the fact that we will collect, use, and share your data in the following manner.
OUR GAMES ARE INTENDED FOR INDIVIDUALS 13 YEARS OF AGE OR OLDER IN THE US AND 16 YEARS OF AGE OR OLDER IN THE EU. CHILDREN UNDER THE AGE OF 13 IN THE US OR UNDER THE AGE OF 16 IN THE EU MAY NOT ACCESS THE SPACE DEV SERVICES. ALSO, WE DO NOT KNOWINGLY COLLECT DATA RELATING TO CHILDREN FOR ADVERTISING PURPOSES.
Remember that your use of the Space Dev Services is at all times subject to the Terms of Service which incorporate this Privacy Policy. Any terms used in this Policy without a definition are to be defined pursuant to the definitions in the Terms of Use.
In case of divergence between the translations of this Privacy Policy, the English version shall prevail over other versions.
We collect some of Personal Data from you, such as your first and last names, as well as your email if you use your Facebook account to log into our network. If you provide us with feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We also collect other types of Personal Data that you voluntarily provide us with, such as operating system and version, Game type and version, and other requested information if you contact us via email regarding support for the Games. If you are a beta tester, to improve your in-Game experience, we may also capture your screen actions so we can prevent bugs, glitches and other errors from happening. In addition, we collect Personal Data from you, such as demographic information, via the Games or at other points in our website that state that Personal Data is being collected. Please see section 2.1 below for a full description of the data that we collect.
To make Games more useful to you, our servers (which may be hosted by a third-party service provider) collect Personal Data from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may choose to refuse or disable Cookies via the settings on your browser, however by doing so, some areas of our website may not work properly.
In general, Personal Data you submitted to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the ways set out in the table below, where we also detail the legal basis we rely on to do so:
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Download of the App | Device data: device used, operating system, browser, IP, battery level and language. | Consent |
| Facebook Data* (only when you log in with your Facebook account) | Profile data: permissions referring to your Facebook public profile (full name, age, photograph, gender and other public information, friends list and email address). | Consent |
| Interaction on the games | Open matches, nickname, communications, actions, sessions, matches played, used power ups | Consent and legitimate interest |
| Credit purchase on the games | Your Apple ID or Google ID, product, currency, country. We do not collect your billing data. | Consent, legitimate interest and contractual obligations |
| Game Scoring | Score and performance on the games. | Consent and legitimate interest |
| Access to the Space Dev website | Device data and domain name | Legitimate interest |
| Analytics | Device data | Legitimate interest |
| Advertising | Device data and contact data | Consent |
We may create Anonymous Data records from Personal Data by excluding information (such as your name) which makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Games and improve site navigation. We reserve the right to use and disclose Anonymous Data to Third-Party Companies at our discretion.
If you provide feedback on any of our Games or our website, we may use such feedback for any purpose, provided that we do not associate such feedback with your Personal Data. We will collect any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.
We do not rent, sell or transfer your Personal Data form to anyone except as expressly provided below. We may share your Personal Data with third parties as described below:
Advertisers: We may, from time to time, allow advertisers and/or merchant partners (the “Advertisers”) to choose the demographic data of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the data we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact that you are located in Sao Paulo to show you ads or offers for Sao Paulo businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage data to Advertisers except in an aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach. You may at all times opt out of this type of advertising by contacting us through the email displayed at end of this Policy.
List of Advertisers:
Affiliated Businesses: In certain situations, businesses or third-party websites that we’re affiliated with may, from time to time, sell or provide products to you through or in connection with the Services (either individually or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all policies of such businesses or websites. Affiliated Business is Space Dev.
Our Partners: We employ other companies and people to perform tasks on our behalf and need to share your data with them to provide products to you; for example, we use a hosting service to store our database. Unless we tell you otherwise, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.
Reports/Analytics: Space Dev stores data that are used in the form of aggregated and generic statistics or reports in order to better understand user profiles for the improvement of the Products offered by Space Dev.
List of Analytics Services
Other Partners
User Profiles and Submissions: Certain account data, including your name and location, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Additionally, if you sign into the Services through a third-party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may access certain non-public data you have entered in your Services user profile. Again, we do not control the policies and practices of any other third-party site or service.
Protection of Space Dev and Others: We reserve the right to access, read, preserve, and disclose any data that we believe are necessary to comply with the law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Space Dev, our employees, our users, or others.
Space Dev collects and transfers Personal Information from and to countries located in the EEA, U.S., and Ukraine to companies listed in our list of Partners. If you are a resident of the EEA, please be aware that countries outside of the EEA may not have the same level of data protection as the EEA; however, our collection and use of your data will continue to be governed by this Privacy Policy. By using the Space Dev Services, you consent to such transfers.
You can always opt not to disclose data to us, but keep in mind that some data may be needed to register with us or to use some of our features.
You may add or update data as explained above. When you update data, however, we may maintain a copy of the unrevised data in our records. You may request the cancellation of your account by email at info@spacedev.com or through in-game contact support. Some data may remain in our records after you request for its deletion from your account in the manner described below. We own and may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.
Depending on your country of residence, you may have additional rights relating to our processing of your Personal Data. If you are an EU resident, in addition to your right to be informed in this Policy of how we process your Personal Data, these rights are:
If you have any questions or concerns regarding how to exercise any of your rights, please send us a detailed message to info@spacedev.com, then we will serve you.
If you are a California resident, California law provides you with specific rights regarding your personal information, including the right to request that we disclose certain information to you about the collection and use of your personal information over the past 12 months and the right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions. To make such a request, contact us at info@spacedev.com. Please note that we are only required to respond to two such requests per customer each year.
You also have the right not to be discriminated against if you exercise any of your rights under California privacy law.
Space Dev may have collected the following categories of personal information of California residents in the past 12 months:
This information is collected and used for the purposes disclosed in this Privacy Policy. Space Dev has not sold personal information of California residents in the past 12 months. Space Dev may have disclosed any of the above categories of personal information pursuant to an individual’s consent or under a written contract with a service provider for a business purpose in the past 12 months.
Your account is protected with a password for your privacy and security. If you access your account via a third-party site or service (like Facebook login), you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanism appropriately.
Space Dev is committed to the safety of your information, some measures we take to improve security are:
We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user data at any time.
Space Dev is based in Ukraine and the data we collect are governed by the Ukrainian law. By accessing or using the Space Dev Services or otherwise providing data to us, you consent to the processing and transfer of such data in Ukraine and to other countries.
We will retain your Personal Data only for as long as necessary to fulfill the purposes we collected them for, including for the purposes of complying with any legal, contractual or accountability obligations, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and the sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve such purposes through other means, and the applicable legal requirements.
Although, if you have registered for a Space Dev account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 24 consecutive months. Space Dev retains records of that deletion for 365 days.
Apps made available through the App Store are licensed, not sold, to you. Your license to each App is subject to your prior acceptance of either this Licensed Application End User License Agreement (“Standard EULA”), or a custom end user license agreement between you and the Application Provider (“Custom EULA”), if one is provided. Your license to any Apple App under this Standard EULA or Custom EULA is granted by Apple, and your license to any Third Party App under this Standard EULA or Custom EULA is granted by the Application Provider of that Third Party App. Any App that is subject to this Standard EULA is referred to herein as the “Licensed Application.” The Application Provider or Apple as applicable (“Licensor”) reserves all rights in and to the Licensed Application not expressly granted to you under this Standard EULA.
a. Scope of License: Licensor grants to you a nontransferable license to use the Licensed Application on any Apple-branded products that you own or control and as permitted by the Usage Rules. The terms of this Standard EULA will govern any content, materials, or services accessible from or purchased within the Licensed Application as well as upgrades provided by Licensor that replace or supplement the original Licensed Application, unless such upgrade is accompanied by a Custom EULA. Except as provided in the Usage Rules, you may not distribute or make the Licensed Application available over a network where it could be used by multiple devices at the same time. You may not transfer, redistribute or sublicense the Licensed Application and, if you sell your Apple Device to a third party, you must remove the Licensed Application from the Apple Device before doing so. You may not copy (except as permitted by this license and the Usage Rules), reverse-engineer, disassemble, attempt to derive the source code of, modify, or create derivative works of the Licensed Application, any updates, or any part thereof (except as and only to the extent that any foregoing restriction is prohibited by applicable law or to the extent as may be permitted by the licensing terms governing use of any open-sourced components included with the Licensed Application).
b. Consent to Use of Data: You agree that Licensor may collect and use technical data and related information—including but not limited to technical information about your device, system and application software, and peripherals—that is gathered periodically to facilitate the provision of software updates, product support, and other services to you (if any) related to the Licensed Application. Licensor may use this information, as long as it is in a form that does not personally identify you, to improve its products or to provide services or technologies to you.
c. Termination. This Standard EULA is effective until terminated by you or Licensor. Your rights under this Standard EULA will terminate automatically if you fail to comply with any of its terms.
d. External Services. The Licensed Application may enable access to Licensor’s and/or third-party services and websites (collectively and individually, "External Services"). You agree to use the External Services at your sole risk. Licensor is not responsible for examining or evaluating the content or accuracy of any third-party External Services, and shall not be liable for any such third-party External Services. Data displayed by any Licensed Application or External Service, including but not limited to financial, medical and location information, is for general informational purposes only and is not guaranteed by Licensor or its agents. You will not use the External Services in any manner that is inconsistent with the terms of this Standard EULA or that infringes the intellectual property rights of Licensor or any third party. You agree not to use the External Services to harass, abuse, stalk, threaten or defame any person or entity, and that Licensor is not responsible for any such use. External Services may not be available in all languages or in your Home Country, and may not be appropriate or available for use in any particular location. To the extent you choose to use such External Services, you are solely responsible for compliance with any applicable laws. Licensor reserves the right to change, suspend, remove, disable or impose access restrictions or limits on any External Services at any time without notice or liability to you.
e. NO WARRANTY: YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT USE OF THE LICENSED APPLICATION IS AT YOUR SOLE RISK. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE LICENSED APPLICATION AND ANY SERVICES PERFORMED OR PROVIDED BY THE LICENSED APPLICATION ARE PROVIDED "AS IS" AND “AS AVAILABLE,” WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, AND LICENSOR HEREBY DISCLAIMS ALL WARRANTIES AND CONDITIONS WITH RESPECT TO THE LICENSED APPLICATION AND ANY SERVICES, EITHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES AND/OR CONDITIONS OF MERCHANTABILITY, OF SATISFACTORY QUALITY, OF FITNESS FOR A PARTICULAR PURPOSE, OF ACCURACY, OF QUIET ENJOYMENT, AND OF NONINFRINGEMENT OF THIRD-PARTY RIGHTS. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY LICENSOR OR ITS AUTHORIZED REPRESENTATIVE SHALL CREATE A WARRANTY. SHOULD THE LICENSED APPLICATION OR SERVICES PROVE DEFECTIVE, YOU ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR, OR CORRECTION. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR LIMITATIONS ON APPLICABLE STATUTORY RIGHTS OF A CONSUMER, SO THE ABOVE EXCLUSION AND LIMITATIONS MAY NOT APPLY TO YOU.
f. Limitation of Liability. TO THE EXTENT NOT PROHIBITED BY LAW, IN NO EVENT SHALL LICENSOR BE LIABLE FOR PERSONAL INJURY OR ANY INCIDENTAL, SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, LOSS OF DATA, BUSINESS INTERRUPTION, OR ANY OTHER COMMERCIAL DAMAGES OR LOSSES, ARISING OUT OF OR RELATED TO YOUR USE OF OR INABILITY TO USE THE LICENSED APPLICATION, HOWEVER CAUSED, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, OR OTHERWISE) AND EVEN IF LICENSOR HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU. In no event shall Licensor’s total liability to you for all damages (other than as may be required by applicable law in cases involving personal injury) exceed the amount of fifty dollars ($50.00). The foregoing limitations will apply even if the above stated remedy fails of its essential purpose.
g. You may not use or otherwise export or re-export the Licensed Application except as authorized by United States law and the laws of the jurisdiction in which the Licensed Application was obtained. In particular, but without limitation, the Licensed Application may not be exported or re-exported (a) into any U.S.-embargoed countries or (b) to anyone on the U.S. Treasury Department's Specially Designated Nationals List or the U.S. Department of Commerce Denied Persons List or Entity List. By using the Licensed Application, you represent and warrant that you are not located in any such country or on any such list. You also agree that you will not use these products for any purposes prohibited by United States law, including, without limitation, the development, design, manufacture, or production of nuclear, missile, or chemical or biological weapons.
h. The Licensed Application and related documentation are "Commercial Items", as that term is defined at 48 C.F.R. §2.101, consisting of "Commercial Computer Software" and "Commercial Computer Software Documentation", as such terms are used in 48 C.F.R. §12.212 or 48 C.F.R. §227.7202, as applicable. Consistent with 48 C.F.R. §12.212 or 48 C.F.R. §227.7202-1 through 227.7202-4, as applicable, the Commercial Computer Software and Commercial Computer Software Documentation are being licensed to U.S. Government end users (a) only as Commercial Items and (b) with only those rights as are granted to all other end users pursuant to the terms and conditions herein. Unpublished-rights reserved under the copyright laws of the United States.
i. Except to the extent expressly provided in the following paragraph, this Agreement and the relationship between you and Apple shall be governed by the laws of the State of California, excluding its conflicts of law provisions. You and Apple agree to submit to the personal and exclusive jurisdiction of the courts located within the county of Santa Clara, California, to resolve any dispute or claim arising from this Agreement. If (a) you are not a U.S. citizen; (b) you do not reside in the U.S.; (c) you are not accessing the Service from the U.S.; and (d) you are a citizen of one of the countries identified below, you hereby agree that any dispute or claim arising from this Agreement shall be governed by the applicable law set forth below, without regard to any conflict of law provisions, and you hereby irrevocably submit to the non-exclusive jurisdiction of the courts located in the state, province or country identified below whose law governs:
If you are a citizen of any European Union country or Switzerland, Norway or Iceland, the governing law and forum shall be the laws and courts of your usual place of residence.
Specifically excluded from application to this Agreement is that law known as the United Nations Convention on the International Sale of Goods.
We are constantly trying to improve our Services, so we may also need to change this Privacy Policy from time to time. In the event of significant changes in this Privacy Policy, Space Dev will previously communicate by email to users for whom we have email addresses, indicating the date on which such amendment will become effective. We will also notify users through a pop-up within the app. In order to keep using the Space Dev services, you may accept them with the indication that you agree with all of these changes.
If you have further questions, comments or suggestions regarding the Privacy Policy please don’t hesitate to contact us via email info@spacedev.com.
Space Dev is the Controller and Processor of Personal Data submitted in accordance with this Privacy Policy and is responsible for that Personal Data.
If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please enter in contact with our team at info@spacedev.com.
SpaceDev LLC
Address: Ukraine, Kiev, ul. Panelna 6/112