The terms below apply to data processing of data subjects from EU and EEA.

Traxnet Oـ(hereinafter "Company") is committed to protecting your privacy. This Privacy Policy ("Policy") applies to those who visit the Websites and Application owned and operated by the Company, as well as Users of our Products and services offered by us (hereinafter collectively "Services") and their End Users. This Privacy Policy describes how the Company collects, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access and correction of your personal information.

If you have questions or complaints regarding our privacy policy or practices, please contact us with the contacts below.

Is the Company classified as a processor or a controller when processing data under the GDPR? Depending on the circumstances, we may be identified as a processor or controller. Information We May Collect or Receive Upon receiving consent from the user, we may collect data such as device type, country, device language, in-game behaviour and purchases, IP address, Apple’s Advertising Identifier (IDFA), and Google Play advertising ID. Collected data will be used to display advertisement of games and software which match your profile and history.

Why we collect?

To build applications and games, developers need to spend a significant amount of financial resources. For most of these developers, displaying advertisements is a major source of income. A company with its Services provides the necessary tools to earn money and continue supporting and building their products. By integrating our SDK into their games and application, developer show you customized advertisement based on your history, location, and other relevant data.

What we collect?

Device Information: including various unique identifiers, such as IDFA, Android Ad ID, IDFV, MAC address Location information: Our systems (like most used on the web) automatically collect an IP address when Users access the Service. IP addresses can be used to learn about the general location (e.g. city, state and country) of the User’s point of access to the web.

Unique device identifier generated from the device MAC/IMEI/MEID, which we alter to limit the ability to identify the relevant device in the future; An advertising ID, such as the Apple IDFA or the Android Ad ID; IP address; Device manufacturer and model; The operating system and version running on your system or device; Browser type; Language; The make of the CPU, and number of CPUs present; The graphics card information, such as type, vendor and driver name, version and graphics API; Amount of system and video RAM present; Current screen resolution; Operating system identifier (e.g., Mac, Windows, etc.); A checksum of all the data that gets sent to verify that it did transmit correctly; and App ID of the game installed. We may collect information, including the App List, to provide personalized ads. To learn more, see our Cookie Policy. Other information: We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

Use of collected data

Overview

We primarily use the information we collect to provide, administer, operate and improve our Services. We may use your information for the following purposes:

To create, administer and troubleshoot accounts, Services we provide; To provide technical support and respond to inquiries; To prevent fraud, enforce the relevant terms of service or licenses, and protect Users; To enable user-to-user communications; To link to or combine with other information we have gathered; To deliver and target advertising, including personalized ads; To inform Users of new products and services, including promotional offers; and To contact you with information that we believe will be of interest to you.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Comprehensive List

Below we list how we and our service providers use Personal Information for legitimate business purposes more comprehensively and inclusive of our legal basis for such collection and use as required by the laws of certain jurisdictions where we operate including:

Providing the functionality of the Services and fulfilling your requests. We use this information to manage our contractual relationship with you, or in some cases, based on your consent or our legitimate interest.

Aggregating and/or anonymizing Personal Information.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose. Accomplishing our business purposes.

For data analysis, for example, to improve the efficiency of our Services; For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements; For fraud and security monitoring purposes, for example, to detect and prevent cyber attacks or attempts to commit identity theft; For developing new products and services; For enhancing, improving, or modifying our current products and services and/or assisting our developers with this activity; For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users or our publisher’s and other advertising customer’s users; and For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users or assisting our developers with this activity within their business so we can focus our and their energies and resources on meeting our users’ interests; We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have your consent or legitimate interest.

We disclose Personal Information:

To our affiliates for the purposes described in this Privacy Policy. List of our affiliates include: Google Admob Facebook Audience Network UnityAds Chartboost

To our third-party service providers, to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services To third-party sponsors of sweepstakes, contests, and similar promotions.

By using the Services, you may elect to disclose Personal Information On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so: To comply with applicable law and regulations. This can include laws outside your country of residence. To cooperate with public and government authorities. To respond to a request or to provide information we believe is important These can include authorities outside your country of residence. To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide the information we believe is important. For other legal reasons. To enforce our terms and conditions or licenses; and To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors. Sharing information We may share information we collect with the following parties: Third-party service providers: We provide User information to other companies that perform Services on Our behalf. For example, we may employ service providers to process payments; host or store our data; deliver email messages or analyze data. Safety, security, and legal compliance: We may share your information: When we have a good faith belief that we are required to disclose the information in response to legal process (e.g., if we receive a court order, search warrant, subpoena, or similar legal process); To satisfy any applicable laws or regulations; If we believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; When we have a good faith belief that there is a meaningful risk that poses a threat to the safety of you, another person or the public generally; and In order to protect the rights or property of Company, including to enforce the terms and licenses that govern the use of the Services. Sale or merger: In the event that we explore or undergo a business transition, such as a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets, we may share or transfer all of your information, including personal information. We may utilize the data collected from applications to place personalized ads in apps and elsewhere. This usage will permit other parties, such as publishers and attribution companies, to learn about the devices that received, viewed or interacted with ads. With your consent: We may share your information for other purposes if (i) you direct us to do so or (ii) you consent to such sharing. De-identified and/or aggregated information: Some of the information we collect does not directly identify you or your device. We may modify other information that can identify you or your device to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information with any third party without restriction and use it for any purpose.

Minors

Children under 16 are prohibited from using our Services and we do not knowingly collect any personal information from children under the age of 16. You should not use the Services if you are below 16. We encourage parents and legal guardians to take appropriate measures to prevent children under fourteen years of age from looking at this Website without the appropriate permission. Accessing/Updating/Deleting Your Information You can access, update, remove your collected data by sending an email to "legal@traxnet.ee". We will make commercially reasonable efforts to address your requests within 72 hours.

Safeguard

We employ a variety of measures to safeguard the collection, transmission, and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information.

Changes

Amendments to this Policy will be posted to this page and will be effective after a period of 20 days from the date of posting. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Website prior to the change becoming effective and you will a reasonable period to stop using website, products or services offered by our Company before such changes apply to you.

Contact

You can contact us through: legal@traxnet.ee Villardi 32-14, 10122, Tallinn, Estonia