Privacy Policy
Last modified on: 25.02.2025
QuartSoft (“we”, “Company”, “us”) is the owner of the Services and is committed to being fully transparent while operating them, as regards our privacy practices.
The Services include the website https://play.quartsoft.com, our Games available via our Website and mobile applications belonging to the Company (“Games”), hereinafter collectively referred as the “Services”.
We developed this Privacy Policy to inform you (“you” or “user”) how your personal data may be processed. We tried to write this Privacy Policy in clear and plain language for your better understanding of the complicated legal stuff. By doing so we hope you will get all needed details to be assured your personal data is safe with us.
The Privacy Policy defines:
- what personal data we process;
- the legal basis for processing personal data;
- what are the purposes of such processing;
- what rights the user has concerning such data;
- whether the data is transferred to third parties;
- what measures we take to protect personal data;
as well as other details of personal data processing.
This Privacy Policy is the integral part of our Terms. Please make sure you read them carefully.
If you have any questions about the Privacy Policy, the processing of your personal data by the Company, or the exercise of your rights as a personal data subject, send us a request to play@quartsoft.com.
1. What is Personal Data?
Personal data (or data) is any information relating to you, and that alone or in combination with other pieces of information allows the person who collects and processes such information to identify you as an individual. In general, these could be your name, email-address, location data etc.
Personal data could also include such technical information as MAC-addresses, IMEI, IP-address, both static and dynamic, browser, and system information.
Personal data processing means any action with it, for example, collection, recording, organizing, structuring, storage, use, disclosure by any means, and so on.
As to the residents of California, the personal data shall mean the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
As to the residents of California, “Sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
Sensitive personal data is a specific set of “special categories” that must be treated with extra security. Depending on the applicable law, this could include information pertaining to:
- Racial or ethnic origin;
- Political opinions;
- Membership of a political association;
- Religious or philosophical beliefs;
- Professional or trade union membership;
- Genetic data;
- Sexual orientation;
- Criminal records;
- Genetic information (that is not otherwise health information);
- Health information;
- Biometric data (where processed to uniquely identify someone), etc.
Other terms used in this Privacy Policy have the same meaning as in our Terms. and the Regulation (EU) 2016/679 known as General Data Protection Regulation, or GDPR.
The Company is the controller of the personal data collected within the Services.
2. What Data Do We Collect?
The categories of personal data are divided into separate subsections based on the specific Services that you consume. Please be aware that we do not purposely collect and process any of your sensitive information.
a. The Website
- Data related to your requests
When you send any request or message to the Company's email address or application form that are placed on the Website, we collect and process the data you voluntarily provide to us (e. g. your name, surname, email address). You can also specify other personal data in the request. Additionally, we may collect your browser version. We ask you not to provide us with excessive personal data, including the personal data of any third parties or sensitive data.
- Automated collection (cookies and similar technologies)
The cookies are tiny pieces of code that may remain in your device after you have visited some website. Cookies and similar web technologies help us to automatically receive the information from your device and send the information back to improve your interaction with the Services and ensure its effective functioning.
To manage your preferences, we use Consent Management Platforms (e.g., SFBX or Google Consent Mode via Playwire), which allow you to control how your data is collected for analytics and advertising. We may also collect information about your activity on the Services to run the analytics and provide you with more relevant advertisements. On certain domains, if you decline consent, we may still process non-identifying signals (via Google Consent Mode) to ensure basic service measurement without identifying you personally.
Please refer to our Cookies Policy to find more details.
b. The Games
- Account data
There are a few ways you can create an account for using the Services. The information received during registration of an account shall be referred as an “account data”.
Firstly, you may register an account on the Services by entering an email address and creating a password. In case of registration with an email address we will send you an email confirmation. If you click on the link in accordance with the provided instructions, this indicates your acceptance of the Terms and entering into the Agreement with the Company. With your consent, we may also collect information regarding the country in which your user account is registered.
You may also create an account by authorizing through a valid account on the social networking Services (“SNS”), such as Facebook. In such a case you allow us to access certain information from your profile on that SNS.
The information you allow us to access varies by game and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games.
For example, we may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
- your first and last name
- your profile picture or its URL your user ID number, which is linked to publicly available information such as name and profile photo
- the user ID numbers and other public data for your friends
- the login e-mail you provided to that SNS when you registered.
- Third-parties’ data
When using the Services, you may voluntarily provide us with the SNS account data of the third party or the ID in the Game of third party to add that account owner to the list of your friends. We collect and further process this data without the consent of such a person but to offer them our Services. Please note that by providing us with the third party’s data, you confirm that you received their clear and unambiguous consent to transfer that data to us. The third party has the right to dismiss the invitation to join the Game and to inform us that they have not allowed you to provide us with their data. In such a case, we will immediately delete this data and stop the processing. You are solely responsible for all activities that you perform on our Website with the third parties' data without their consent.
- Data related to your requests
When you send any request or message to the Company via the Games, we collect and process the data you voluntarily provide to us (your name, surname, email address, etc.), as well as your ID in the Game, where applicable. You can also specify other personal data in the request. We ask you not to provide us with the excessive personal data, including the personal data of any third parties or sensitive data.
- Data collected in relation with our anti-fraud practices
During your usage of the Services we may automatically collect information on your suspicious behaviour that may be aimed at violating the Terms. The collection is not permanent, since it starts only after the system encounters with your particular activity set as trigger for launching the collection. After that the collected data will be manually processed by our personnel to detect whether it is a real attempt to breach the Terms.
- Automated collection (cookies and similar technologies)
Automated data collection helps us to automatically receive the information from your device and send the information back to improve your interaction with the Services and ensure its effective functioning. The personal data collected through the automated collection could include: IP address and unique device identifiers, device attributes like operating system and browser type.
Please refer to our Cookies Policy to find more details.
Also, we automatically collect data about your in-game activity, such as the duration of session, its frequency etc., which helps us to improve the quality of our Services.
- Financial information
Please pay attention that we do not collect your payment credentials (bank credentials, cards numbers and dates of issuance etc.). Such information may be collected exclusively by third-party payment providers with the respective licenses and security measures with regard to your payment credentials, as it is prescribed in our Terms. We receive from the third-party providers only Transaction ID and Recipes with the information on conducted transaction, data and time, and services bought, just to make sure that the transaction relates to you.
3. Lawful Basis and Purposes of Processing Your Data?
a. Lawful basis
Performance of the contract. Our Services include using of the Website and the Games, their maintenance, as well as the user support and information services. We collect and process most of the personal data described in the Section above to fulfil our contractual obligations under our Terms, that is for the performance of the contract. Namely, the performance of the contract is the lawful basis for the processing of the account data and data related to your requests.
Your consent. Data collected through the automatic collection is collected on the basis of your consent, unless it is strictly necessary for the mere functioning of the Services.
Legitimate interest.
- We process third party’s data based on our legitimate interest to allow you to add that third-party to your friends list and to provide such third party with access to the Game.
- Data collected in relation with our anti-fraud practices is processed based on our legitimate interest. The legitimate interest in this case consists in preventing violation of the Terms and causing damages to the Company.
- We also collect and process your account data to send you our newsletters on the basis of our legitimate interest. In such case the legitimate interest shall be our business development through sending marketing and promotional emails to keep you informed of all changes, innovations, and improvements we make within the Services.
Such information would be only about similar products or services, and on the emails you provided in the context of the sale of our Services. In addition, the legitimate interest is the legal basis for the processing when we store your personal data after your deletion of the Services. In such case the legitimate interest consists in avoiding risks of the loss of the data within our systems.
You can always choose to stop receiving our emails. If you want to cease this type of communication, simply use the “Unsubscribe” button which is present in each of our emails.
- We collect and process financial information to provide you with the paid Services, be able to prove the actuality of the transactions in case of dispute emergence. That constitutes our legitimate interest.
Legal obligation. We retain the financial information to be able to comply with our legal obligations as to the taxpaying and reporting, as well as complying with any other legal obligations prescribed by law.
b. Purposes of processing
We collect and process the personal data described in the section above in order to provide you with all the necessary services within our Services.
In particular, we collect and process different types of data for the following purposes:
- account data:
- in order to create and technically maintain your account, identify the user and verify the identity of your person, give you the opportunity to use the Services, communicate with you at your request, and other communication;
- to give you the ability to synchronize your in-game achievements among different devices of yours, to preserve you from losing the in-game process in case of deletion of the Game;
- third-party data – to allow you to add that third-party to your friends list and to provide such third party with access to the Games; if such person creates the User Account, further provided personal data would be processed on the terms provided in this Privacy Policy;
- data related to your requests – to communicate with you at your request, to provide a comprehensive answer to your inquiries, and to make sure that you are satisfied with our Services;
- data collected in relation with our anti-fraud practices – to prevent violations of the Terms and causing damages to the Company;
- data collected through the automated collection – as indicated in our Cookies Policy;
- financial data – in order to provide you with the paid Services, be able to prove the actuality of the transactions in case of dispute emergence and demonstrate the incomes to the tax authorities.
Additionally, we may process your data:
- for the compliance with our legal obligations;
- to protect your vital interests or vital interests of another natural person;
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
- for the purposes of the legitimate interests pursued by us or by a third party (e.g. to prevent or investigate possible wrongdoing in connection with the Services or to protect ourselves, our subcontractors, partners and affiliates against legal liability).
If we decide to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal data within the newly set purposes. Where applicable, you will have to provide your consent for the amended purposes (unless additional purpose of processing is compatible with those listed above).
Please note that we do not sell your data or make any decision based solely on automated processing that may produce legal effects or similar significant effects.
4. How long do we store your data?
a. Retention period
Generally, we will not store any data you provide for longer than the specific Services require. To be more precise, we store your data for such periods of time:
- your account data – as long as you keep your account active, but at any case not more than 2 years after any of your activity in the account stops;
- data connected to your requests – for as long as you remain an active user of our services. The data will remain accessible in our backend for one year to ensure continued support and reference. Once the issue is resolved and archived, it remains retrievable in the backend for any follow-up or related purposes. If your account becomes inactive or a contract associated with the request is voided, all data related to that account will be deleted from our systems within 90 days.
- data collected in relation with our anti-fraud practices – during the collection of the data and six months thereafter to be able to explain to you the reason of account restrictions set by us;
In certain cases, this data may be securely stored by a third-party service provider for a period of no more than five years to comply with legal or operational requirements related to fraud prevention and investigation.
- data collected through the automated collection – as indicated in our Cookies Policy.
- financial data – until you request to delete the financial data, but not more than 2 years after the transaction occurs.
b. Other processing
Please note that sometimes we may process your data for the period longer than indicated in this section. Such processing could be carried by us only for statistical purposes as it is provided for in Article 5 of the GDPR and subject to the appropriate safeguards in accordance with applicable data protection laws.
Statistical purposes mean any collection and processing of personal data necessary for statistical surveys or to produce statistical results. The statistical purpose implies that such statistical results do not include personal data, but only aggregate data. The statistical results may further be used for various purposes, for example, to assess our business development, understand the market demands and improve our Services.
In most cases, we will anonymize your data before starting processing it for the statistical purposes. As a result, such data will be no longer considered personal and its use will be not governed by data protection laws.
5. Granting Access to Third Parties
We do not sell your personal data to third parties. However, to provide qualitative services, support various functions of our Services and ensure their operation, we may hire people, work with service providers, partner companies, and organizations. For these reasons, some of your personal data may be transferred to these persons.
In all cases, we comply with the requirements of data protection legislation and make every effort to ensure that data processing is secure at all stages. Our subcontractors and any other third parties will provide the same or equal protection of user data as stated in this Privacy Policy.
To achieve the purposes of data processing, we may provide your data to the following persons:
a. Our employees and independent contractors
We may pass on your data to our employees or verified independent contractors (including private entrepreneurs). We always enter into non-disclosure and confidentiality agreements with those employees and independent contractors who have access to your data to ensure their data protection. In case of the independent contractors who are private entrepreneurs, we also sign the data processing agreements with them, where applicable.
b. Third-party services providers
The Company engages a number of trusted third-party service providers in order to support different features of our Services and ensure its overall functioning. We also use third-party services to organize our work in the most efficient way and provide our clients with the best customer service.
Therefore, we may grant the following third-party service providers (and their subcontractors) with a limited access to your personal data:
- Google Analytics (the USA) is well-known online business analytics service that helps us to understand how our users interact with our Website. Google LLC is certified under the Swiss-U.S. Privacy Shield frameworks. As a big transnational corporation, Google engages sub-contractors to carry out its obligations under contracts with customers. The list of Google’s sub-contractors engaged in the provision of Google Ads services (including Google Analytics, Google Tag Manager and Google Optimize) is provided for https://privacy.google.com/businesses/subprocessors/here.
- Meta (California, the USA) is an American company offering online social networking services. We use Meta in respect of Facebook Software Development Kit (Facebook SDK). It allows us to easily integrate our Games with Facebook, promoting it there on the targeted audience. The Privacy Policy is available https://opensource.fb.com/legal/privacy/here.
- Facebook Insights is an analytics dashboard where you can track user behaviour and post performance on your Facebook business page. In addition to providing key metrics like page views and post reach for paid and organic posts, the platform also recommends competitor pages to watch and track.
- Facebook Pixel is a piece of code that you put on your website that allows you to measure the effectiveness of your advertising by understanding the actions people take on your website.
- Amazon RDS (Seattle, the USA) is a distributed relational database service by Amazon Web Services (AWS). It is a web service running "in the cloud" designed to simplify the setup, operation, and scaling of a relational database for use in applications. The Privacy Policy is available https://aws.amazon.com/privacy/here.
- Xsolla (Xsolla, Inc. USA) is a platform which organizes and automates the complex payments processes for gaming businesses. See their privacy practices https://xsolla.com/privacypolicyhere.
- Dev 2 Dev (Dev 2 Dev Portal LLC, Delaware, the USA) is a provider of IT consulting services and in particular, it advices with information security. See their privacy practices https://www.dev2dev.com/docs/privacy-policyhere.
- SFBX (France) is a consent management platform that enables to optimize consent rate and ensure a personalized user experience. See their privacy practices https://sfbx.io/en/politique-de-confidentialite/here.
- All or partial advertising on this Website or App is managed by Playwire LLC and Google AdSense. If Playwire publisher advertising services are used, Playwire LLC may collect and use certain aggregated and anonymized data for advertising purposes. On specific domains, Playwire also provides the Consent Management Platform (CMP) to communicate your privacy choices to Google services (via Google Consent Mode). To learn more about the types of data collected, how data is used and your choices as a user, please visit https://www.playwire.com/privacy-policyprivacy policy.
Most of the services listed above are designed for analytics and marketing purposes. To find out what particular data are sent to the third-parties in this aspect, please visit our Cookies Policy.
If you are interested in more details about how these third-party services process personal data, please refer to their privacy policies available on their websites. However, we want to reassure you that due to their residency of headquarters or affiliates companies they all are subject to the best worldwide standards of data protection. We care about your data security and choose only reliable partners.
As regards the engagement of the above-mentioned service providers, we take all necessary steps to ensure compliance with the applicable data protection laws such as the GDPR. In particular, we make sure that your personal data is being protected and used only within the purposes specified in this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors and partners, as well as taking technical measures to ensure the information is protected when stored, used and while being processed and transferred.
Since some of your data may be transferred to third parties outside of the EEA, we could also transfer such data on the basis of the standard contractual clauses signed with the respective third parties, if the country of transfer (like Ukraine or the USA) is not subject to the adequacy decisions of the European Commission. You may request the copy of such instruments via contact details provided in Section 11.
We may also disclose your personal data to ensure compliance with the law. In other words, we may disclose information necessary for an investigation or trial at the official request of public authorities. If we are forced to disclose your information, we will notify you immediately and provide a copy of the request unless prohibited by law.
6. Your Data Processing Rights
To exercise your rights listed below, you can send a request to the Company to play@quartsoft.com.. In order to properly protect your data, the Company may take additional measures to identify you when processing your request. We will provide you with a response to your request no later than 1 month from the date of its receipt, except as provided by law.
Thereby, you have the right to:
- Know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the owner or controller of personal data.
The Company respects the rights of personal data subjects and provides all necessary information in an accessible and understandable format. The Privacy Policy was created to ensure this right.
- Receive information on the conditions for granting access to personal data, in particular information on third parties to whom your personal data is transferred.
- Obtain a copy of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance where the processing is carried out by automated means.
Under the GDPR, you may exercise this right in terms of your personal data that is processed on the basis of consent or the performance of the contract, if the data is collected directly from you and not created by the Company.
- Access to your personal data and the right to receive an answer as to whether your personal data is processed, as well as to receive the content of such personal data.
You can at any time receive confirmation from us whether we are processing your personal data and receive a full copy of this data. In this case, you have the right to receive your personal data in a structured, commonly used and machine-readable format, as well as the right to transfer this data to another owner (controller) at its discretion.
- Submit a reasoned request to us objecting to the processing of your personal data.
If the review of such a request reveals that the Company cannot demonstrate a valid legal basis for the processing of data that overrides your interests, rights, and freedoms, we will stop processing it and inform you about it.
If the request is not satisfied, we will provide you with a reasoned response to the refusal.
- Make a reasoned request to change or destroy their personal data if such data are processed illegally or are inaccurate, as well as in other cases provided by law.
In particular, in the event of any inaccuracies in the data processed by the Company, the person whose personal data are processed has the right to contact us with a request to make appropriate changes to their personal data. You may also request that your data be destroyed if you believe that the Company no longer needs it for the purposes for which it was collected.
- Protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision, or untimely provision, as well as to protect against the provision of information that is inaccurate or discredits the honor, dignity, and business reputation.
- Complain about the processing of your personal data to the supervisory authorities or to the court and apply legal remedies in case of violation of the legislation on personal data protection.
- Make reservations about the restriction of the right to process your personal data while giving the consent.
You have the right to request that the Company restrict the processing of your data in specific situations as permitted by law. For example, this may apply when you contest the accuracy of the data, and the Company is verifying its accuracy, or when you require the data to establish, exercise, or defend legal claims, even if the Company no longer needs the data for its original purpose.
- Withdraw consent to the processing of personal data.
You can withdraw your consent to the processing of your personal data at any time in case of the legal basis for the processing was the consent. In this case, we must stop processing, i.e., destroy or delete your personal data and notify you on the results.
There may be exceptions to this right. For example, if the law requires the Company to retain this data, or when it is necessary for protection in litigation, or when the Company has other grounds for processing, etc.
- Know the mechanism of automatic processing of personal data and the right to protection against an automated decision that has legal consequences for you.
This provision is intended to protect the data subject from decisions made by the algorithm without human involvement or control. For example, if a computer program decides on the basis of certain collected information who needs help and who does not. To protect you against such a decision, if we implement one, we will explain the subject of the rules and logic of decision-making by the algorithm, as well as the ability to require a review of the decision by a person.
However, as of now, the use of the Services does not provide any solely automated solutions that would have legal consequences for you.
The rights that are provided to California residents under CCPA
- Rights to transfer of your personal data
If we share your personal data, or disclose it for a business purpose, we will notify you of that in an appropriate way. In such case you have the right to request us to disclose the following information:
You have the right to receive explicit notice and to be provided with an opportunity to exercise the right to opt-out, if a third party decides to further share your personal data.
We will also notify you in case we decide to “sell” some of your personal data within the meaning of the CCPA. If we do so, you shall have the right, at any time, to direct us not to “sell” your personal data. This right may be referred to as the right to opt-out.
- Right to opt-out
You can choose to opt-out of having your personal data “sold” or been used by third-parties and businesses.
By informing us via email, you can restrict third-party providers to use your personal data. Third-party providers will only show you non-personalized ads. Non-personalized ads are based on contextual information, such as the content of our Services.
- The categories of personal data that we collected about you.
- The categories of personal data that we sold or shared about you and the categories of third parties to whom the personal data was sold or shared, by category or categories of personal data for each category of third parties to whom the personal data was sold or shared.
- The categories of personal data we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- Rights as to non-discrimination
We shall not discriminate against you because you exercised any of the consumer’s rights under this Privacy Policy, including, but not limited to, by:
- Denying the Services to you.
- Charging different prices or rates for the Services, including through the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of the Services to you.
- Suggesting that you will receive a different price or rate for the Services or a different level or quality of goods or services.
7. Your age
The privacy of children is one of our concerns. Here at our Websites and the Games we can provide services to consumers of all ages.
You can solely give your consent to data collection and processing if you are at least at the age of:
- from 13 to 16 years – if your place of residence is one of the countries-members of the EU. The exact number depends on the particular country;
- 13 years – if your place of residence is the USA;
- the relevant age in your country, if it is not listed above.
Our Services do not address anyone under the age indicated above. We do not knowingly collect personally identifiable information from children under the age indicated above. In the case we discover that such a child has provided us with personal data, we immediately delete it from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us so that we are able to take necessary actions.
8. Personal Data Location
The Company does not physically store most of the personal data. All other data are stored in databases and file repositories hosted by Amazon RDS. Databases are continuously backed up to enable restoring to any point in time within a retention period.
9. Security of Personal Data
We take appropriate security measures to protect your personal data from accidental loss or destruction, from unlawful processing or access to it.
Confidentiality. All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties. Also any access by authorized personnel is logged.
We use verified contractors that might have access to the data as specified in this Privacy Policy and with whom relevant data processing agreements are concluded. Moreover, we guide and train our personnel to process your data securely.
Isolation. The Company uses its own system for managing internal accounts and access to data. Access to personal data is restricted to individually authorized personnel. Authorized personnel are granted a minimum access on a need-to-have basis.
Protection from unauthorized access. With regard to protection from unauthorized access to personal data, we have implemented passwords hashing and multi-factor authentication.
Encryption. The Company encrypt stored user data and data provided by external platforms. The Company requires to encrypt all network connections and prohibit unencrypted data transmission.
Securing credentials and access tokens. Firewall is installed on all servers, which prohibits access from all computers on the network except the corporate network. Tracking Data Transfer is ensured through a comprehensive solution based on the analysis of the system server logs and their current state.
Logging. To register and track all access to data and requests for receiving or changing data, a system for collecting and monitoring all system logs at different levels of the application is used.
Monitoring and system updates. The Company implements a system which allows to regularly update system code and environments. The Company uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made. System performance and availability is monitored by both internal and external monitoring services.
Internal Policies and Procedures. All the employees and the contractors are obliged to obey the internal security policy with respect to the processing of personal data. Such policy provides for organization, physical, and technical security measures, and, for such purpose, takes into account the nature, scope, context and purposes of the processing, as well as the risks posed to the rights and freedoms of data subjects.
Disclaimer. While taking necessary steps to secure your data, we have no choice but to admit that no method of transmission over the Internet or method of electronic storage is 100% secure. If it happens that any of your personal data is under the breach and if there is a high risk of violation of your rights as a data subject, we would inform you and the respective data protection authorities as to the accidents without undue delay. We will also do our best to minimize any such risks.
10. Changes to this Privacy Policy
We may amend or update this Privacy Policy from time to time. If we decide to do so, and the amendments will substantially affect your rights and legitimate interests, we will notify you of any changes via email and/or a prominent notice within the Games when you use the Games for the first time after the amendments. We will also indicate the "Last modified" date at the top of this Privacy Policy.
11. Contact Information
If you have any questions about the Privacy Policy or your data being processed by us, you are welcome to contact us: