Privacy Policy

Effective Date: December 21, 2023

Spectral Survivor is a game owned and developed by Fragment Digital. This Policy explains how Fragment Digital (referred to as “we” or “Fragment” in this Policy) collects, stores, uses, or otherwise processes the personal data of end users of our Services as defined below (referred to as “you” in this Policy), and what rights you have if we are processing your personal data.

In this Policy, “Services“ refers to our Games, Applications, Websites, and any related services or properties we control; “Games” refers to our games (such as those provided on mobile platforms, for example iOS and Android), applications, and other products; and “Websites” refers to websites and other online properties we control, including fragment.digital. The expression “your data” is used when referring to personal data that relates to you as an identified or identifiable individual.

It is important that you read this Policy before accessing or using the Services so that you are aware of how and why we may use data relating to you. In addition to this Policy, we encourage you to carefully review our Terms of Service, which govern your use of our Services.

While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 6 of this Policy.

We collect the following data:

  • Contact Information: Name, user name, gamertag, postal and email address, phone number, unique IDs, mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address
  • Characteristics: Age and gender
  • Commercial Information: Purchase and usage history and preferences, including gameplay information
  • Billing Information: credit or debit card information and shipping address
  • Electronic Activity: Web or app browsing and gameplay information related to the Services; information about your online interaction(s) with the Services or our advertising; and details about the games and platforms you use and other information related to installed applications
  • Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls)
  • Profile Inferences: Inferences made from your information and web activity to help create a personalized profile so we can identify goods and services that may be of interest
  • Audio and Visual Information: Account photos, images, and avatars, audio information via chat features and functionality, and gameplay recordings and video footage (such as when you participate in playtesting)
  • Sensitive Information: Precise location information (if you allow the Services to collect your location), account credentials (username and password), and contents of communications via chat features and functionality.

We process your personal data for the following purposes:

  • enable you to use our Services
  • create and maintain an account for you in our Services where applicable
  • provide the correct version of our Services to you (selecting an appropriate language)
  • enable you to communicate with other users in our Services (for example, by providing chat)
  • send you service-related communications
  • verify your purchases or other transactions in our Services
  • operate and maintain our Services
  • troubleshoot or debug any bugs or other issues in our Services,
  • measure and analyze the use of our Services or data we collect through our Services
  • conduct surveys or other research to learn more about our users
  • improve our current Services or develop new Services
  • personalize your gameplay experience in our Services based on your activity,
  • provide you with offers and rewards in our Services based on your activity,
  • handle support requests or otherwise manage our relationship with you
  • keep track of installations of our Games
  • measure, analyze, and improve the effectiveness of our advertising
  • send you communications about offers, rewards, events, or other news related to our Services
  • request our advertising partners to show or not show our ads to you based on your activity (including by limiting the number of times you see our ads)
  • request our advertising partners to advertise our Services to audiences who they believe have interests like yours
  • show ads to you in our Services, either from us or our advertising partners
  • keep track of your activity in our Services to learn about your interests and improve the advertising in our Services
  • personalize, or allow our advertising partners to personalize, the ads you see in our Services
  • detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior
  • establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations
  • to send you newsletters or other similar communications if you have subscribed to them
  • for other purposes explained to you when we ask for your consent (for example, using your IP address or GPS location to provide location-based experiences)

Where do we collect your data from?

  • directly from you when you submit it to us
  • directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services
  • if you interact with ads in our Games or our ads outside of our Services
  • if you choose to connect a third-party account
  • if you make purchases in our Services
  • with your consent, from other sources explained to you when asking for your consent

Providing data to us is not mandatory. However, we may be unable to provide the Services, or some parts or features of the Services, without processing your data.

Who do we share your data with?

  • persons or companies outside of the Fragment Digital that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services),
  • prospective or actual buyers (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring
  • competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation
  • any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests
  • with any other person or entity with your consent.

In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games.
In connection with the processing activities described in this Policy, your data may be transferred to and/or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, your Fragment ID, IP address or device ID, as collected via server log files, may be stored within Amazon Web Services in the USA. USA and other countries may have data protection laws that differ from the laws of your country. In these cases, we will provide appropriate safeguards to protect your personal data. These safeguards may include compliance with the European Commission’s standard contractual clauses for transfers of personal data or reliance on the appropriate legal framework.

Advertising

Advertising is one of the ways of funding our Services and enables us to make our Services available free of charge. In our Services, we show our own ads and also ads from third parties.

Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs (known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices) but also Internet Protocol (IP) addresses or other identifiers.

When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners. Our advertising partners may also collect information directly from our Services through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID).

In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services.

Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. It is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.

How long do we keep your data?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including providing you with the Services or complying with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. We may continue to use data that is not identifiable to you (for example, aggregate data).

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

If we are processing your data, you have the right to:

  • access, correct, or request the deletion of your data
  • request us to restrict our processing of your data
  • object to our processing of your data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
  • where technically feasible, request a copy of the personal data you have provided to us in machine-readable format.

Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.

To access your data in our Games or to request its deletion, please contact us at info@fragment.digital to unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.

Children’s privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Updates will be made available on this page. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.

Cookies

Like most websites today, our Websites may use cookies or similar technologies (for example, local shared objects or web beacons).

A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.

Using your browser or device settings, you can control the use of cookies, for example by disabling some or all cookies or configuring your browser or device to notify you when cookies are being set. However, please consider that disabling cookies may affect your ability to use the Services.

Contact Us

To exercise any of your rights, you may also contact us at info@fragment.digital, or by mail at Fragment Digital d.o.o., Miroslava Krleže 38, 48000 Koprivnica, Croatia. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you.