General terms

As used in this Privacy Policy, "DataSmart", “we”, “us” or “our”, “ours” refers to SmartData Ltd, registered at Nalichnaya str. 22, St. Petersburg, Russia, with business address at Bolshoy pr. VO 80, St. Petersburg, Russia, and all of its subsidiaries. For general information please feel free to contact us via

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the “EULA”) governing the use of all "DataSmart" branded software applications (the “Application/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or , and any other websites and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”). This Privacy Policy covers how we collect, use, disclose, transfer and store information received about you and/or information received about your computing device through your use of the Applications or the Websites.

By agreeing to the EULA and/or using the Applications or the Websites, you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications or the Websites. As described in greater detail below, we may share this information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

In addition to the general content of this Privacy Policy which is applicable to all Applications, some of the Applications have special clauses that apply just to them, such as SOG.

Collection of device and technical information

We collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app, to personalize the content of the app, and to display contextual advertisements.

We automatically obtain certain information about your computing device, including:

  • IP address; Country code;
  • Language; Locale (specific location where a given language is spoken);
  • Time zone, session start/stop time;
  • Network status (WiFi, etc.), browser plug-in types and versions;
  • Applications installed;
  • Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
  • Push notifications token;
  • User identifier string.
  • Although some of this information may uniquely identify your device, this information does not identify you personally.

    Collection of classical personal information

    We may also collect personally identifiable information about you (such as your name and surname, email address), as well as non-personally identifiable information (such as specific age or age range and gender) that you provide us, by using our Applications, when you voluntarily register with SOG, request information using the Websites or contact us directly.

    We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.

    If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail to and your e-mail will be deleted from our database.

    Sharing of information upon your request

    We access your social network profile if you allow us to for the purposes of using in-game features.

    Some of the Applications use third parties’ services such as Google Play Services Sign-In, , Facebook, YouTube, Twitter or VK Log In. You may also share the content you created within the Application on Facebook or VK (“Third Party Social Network”). By logging in to the Application using Third Party Social Network or by using the Application to share content on such Third Party Social Network, you are authorizing us to collect, store, and use any and all information, in accordance with this Privacy Policy, that you agreed that such third parties could provide to us through the Application Programming Interfaces (“API”). Your agreement takes place when you “accept” or “allow” (or similar terms) one of our applications on such Third Party Social Networks. The information you allow us to access varies by Application, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at Facebook, and VK. These third party sites are governed by their own privacy policies and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions you can contact us at

    We may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your profile, such as your name, surname, email address, login ID, player identifier string; (ii) your photos and videos. The Application may further ask you to allow us to (i) post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates) and to (ii) manage your notifications (access your notifications and mark them as read). Please keep in mind that we will only do that if specifically directed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the Application on your device so that the Application will be able to communicate with Third Party Social Network directly; Voice recordings from Applications are also only being collected and stored within the Applications upon your request.

    Consent to public display of data upon your acceptance

    We may publicly display your data when you participate in game related activities for the purposes of user identification.

    If you use Third Party Social Networks to participate in game related activities, including but not limited to participation in leader boards, multi-player games or the downloading and uploading of content, DataSmart and its affiliates may also collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and achievements), or identify content that is created and shared by you with other players. Data that personally identifies you is collected, used, stored and transmitted in accordance with this Privacy Policy.

    Collection of data log files

    To make our apps appealing to users, we must collect data logs about the usage of the app by you. But don't worry, personal data is obfuscated/deleted within the app before we receive it and we tie the data to an ID that cannot be traced back to you.

    The Application might automatically send anonymized and obfuscated data log files to us that contain detailed information on your usage of the Application (e.g. data log files containing chat history, where (i) such history cannot be attributed to any individual person; and (ii) any personal details that you provide us voluntarily (e.g. personal names, addresses, numbers, places, etc.) are obfuscated/deleted within an app before they are sent to us). The data logs from you shall be assigned an ID that cannot be traced back to your device and your device identification shall be immediately deleted from our system. Such data log files are used solely for the purpose of analysis, development and improvement of individual functions within the Application with the aim of making the Application more appealing to users. The data logs will not be disclosed to third parties. Implied but informed consent shall be deemed given to us by downloading and using the Application.

    We will use such statistical data that may be connected with your device ID only for our internal purposes of developing, delivering, improving, personalizing and tailoring our products, services, content, and understanding and analyzing trends in connection with the usage of the Application, and administering the Application and customer communications.

    Our use of information

    We use the information we collect from you for delivering and promoting our services, internal analysis and research to improve the services and to display advertisements.

    You hereby allow DataSmart to collect, process and store the data as stated in this Privacy Policy.

    We use the information we collect about you/your computing device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

  • Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Applications and the Websites, administering the Applications and the Websites, and customer communications. For information that can be treated as personal information in some legislation, we use only device identifiers.
  • Analytics and research: Understanding and analyzing trends in connection with the usage of the Applications and the Website, auditing, learning about user behavior within the Applications and the Websites (how often you use the Application/Website, the events that occur within the Application/Website, aggregated usage, performance data etc.), gathering demographic information about our user base, data about where the Application was downloaded from. For information that can be treated as personal information in some legislation, we use only device identifiers. We use the data we receive from Third Party Social Network for internal analytics. For opting out from Firebase Analytics please visit Opt-Out Section of this Privacy Policy.
  • Push notifications

    We will only use push notifications to remind you about your activities within the Application. You will receive push notifications only if you are subscribed to push notifications in the Application. To unsubscribe, please use the instructions provided below:

    For Android: After an Application is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the Application and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the Application.

    Storing of information

    We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services.

    • For EU Countries

    • We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Location information is stored to the extent and for the duration necessary for the provision of a value-added service. Cookies, direct marketing and provision of value-added services information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy and the “Access to Personal Information” section herein. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

    • For US

    • We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

      Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.

    Deletion of information

    When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

    Disclosure to third parties

    We disclose the information to our advertising and analytics partners so that we can display advertisements and analyze the usage.

    We cannot provide all services necessary for the successful operation of the Applications or the Website by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking providers, third party advertising providers and other third party service providers that support the Applications and the Website (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our advertising campaign performance:

  • · Third party analytics providers: For some Applications we use third party analytics such as Flurry, BigQuery, Google Analytics (for Applications), Google Analytics (for Websites) and Firebase Analytics for the purposes of delivering our services, conducting analysis and research. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners' sites or apps” located at
  • We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications or the Website. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

    We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

    For any additional questions about third party information collection please refer to

    Third parties terms and conditions

    Please note that your access to and ability to use and interact with the Applications and the Websites may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers. You recognize and agree that DataSmart is not liable for any such third party terms and conditions and their use of your personal information.

    Protection of personal information

    We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

    Integrity of personal information

    We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.

    Access to personal information

    Access, correction or deletion requests regarding your personal information may be submitted to

    We make good faith efforts to provide you with access to the personal information you provide to us (information associated with your account). You can also request that we correct or delete information, provided that we are not required to retain such information by law or for legitimate business purposes.

    We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests can be made via .

    Information collection related to children

    We do not knowingly collect personal information from, children under 13. If we learn that we have collected personal information of a child under 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at

    The only personal information we collect from you for the purposes of offering our services are persistent identifiers (such as IP address). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to place contextual advertisement (including frequency capping), to authenticate users of or personalize the content on Applications, to maintain or analyze the functioning of the Applications, personalize the content of the Application (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the Application, to ensure legal or regulatory compliance.

    When using the persistent identifiers we will not contact you, display behavioral advertising to you, nor do any user tracking or profiling.

    We will send push notifications to users who allow us to do so in order to reengage them in terms of using the Application. You may unsubscribe at any time by following the instructions in section Push Notifications of this Privacy Policy. We strive to ensure that the content of the push notifications will always be family-friendly. Push notifications are local, contextual and sent in app only and not from a server or in conjunction with other user information.

    Third party sites

    Our Applications, Websites, products and services may contain links to third party websites, products, or services. For example, the Applications may feature offers from third party advertisers or the ability to engage in transactions with such entities. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.

    We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.


    You are always free to opt out from the future collection of your personal information by DataSmart in accordance with this Privacy Policy by uninstalling all the Applications from each of your computing devices and discontinuing use of the Websites.

    Changes to our privacy policy

    Please check regularly for changes to our Privacy Policy.

    We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at

    Should you request so by informing us on, we will send you all the updates of this privacy policy to your e-mail. We will also inform you about any material updates of our privacy policy with an in-app banner and a link.

    Any questions?

    Send us an e-mail to

    DataSmart Privacy Policy, v1.0, updated February 2017