Privacy Policy

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications)

Last updated on September 30th, 2020

1. General provisions.

1.1. Elyland Investment Company Limited (hereafter referred to as «We» or «Company») takes all the necessary measures to process fairly and to protect the personal data of players of the game «» (hereafter referred to as «Game»).

1.2. This policy (hereafter referred to as «Policy» or «Privacy Policy») as well as the End User License Agreement (EULA) and all its addenda, regulate issues related to the collection, storage and processing of personal and other data of the players participating in the Game, which the Company collects as a result of You using the Game. To ensure transparency and security, Our Privacy Policy as set forth below will inform You about the nature, scope, and purpose of the personal data processed by Us. This Privacy Policy also explains how personal information (personal identifiable information, personal data) is collected, used and disclosed by Us while using the Game, or any related services made available through the Game, or when You otherwise interact with Us.

1.3. We reserve the right to update this Privacy Policy at any time without prior notice. We will process data in accordance to the Privacy Policy that you have consented to at the time of your consent. Upon a change in Policy, we will alert you with a conspicuous in-Game banner notice; your continued use of the Game and/or its services will constitute Your consent to the updated Policy. Use the “Last Updated” date in this Policy to determine when it was last changed.

1.4. Please note that We may combine the information We collect from You independently with the data that You provide Us with.

1.5. Capitalized terms that are used in this document signify the same concepts as those in the EULA.

2. Information on the person (controller) who controls the processing of players’ personal and other data in the Game:

Elyland Investment Company Limited, HE 266867, address: 7 Florinis, Greg Tower, 2nd floor, 1065, Nicosia, Cyprus. You can contact Us via

3. What do we mean under personal identifiable information or personal data?

3.1. Personal data or personal identifiable information means any information relating to an identified or identifiable natural person. The definition of personal data now encompasses not only natural person’s explicit identifiers like name or address, but also any online identifiers (for example, IP address, Your device ID etc.) together with other personal data. We would like to clarify if We collect the IP addresses of User but does not link the IP address to any particular consumer or household, and could not reasonably link the IP address with a particular consumer or household, then the IP address would not be “personal information.”

4. Categories of information We collect.

4.1. We collect, process, or use the following categories of personal and other data:

Payment information: Payments that You may make for the purpose of purchasing Additional Services or objects in the Game, will be processed by the payment processor according to its confidentiality and security policy. However, Our payment services provider disclose to Us some categories of users data related to their payments, in particular first and last four numbers of Your bank card, type of card (Visa/Master card, debit/credit), name of bank - card issuer and location of bank (country), cardholder name, expiration date of Your card, sum of the transaction, number of Your account or electronic wallet, etc.\

Stored Credential. Respectively, for US Stored Credential is Payment information mentioned above which is received from our payment services provider and is stored by US.

4.2. When You make a payment for Additional Services in Our Game, You will be redirected to the web pages of the respective payment systems depending on the payment method chosen, and will have to personally provide all of the data required by such payment systems for the purpose of processing the payment. When using a debit or credit card to purchase Additional Services, You will be required to enter the following data: PAN, cardholder name, service code, expiration date of Your card on the website of the payment system. When purchasing Additional Services via electronic payment systems, You will be required to provide the number of Your account or electronic wallet.

5. Children’s data

5.1. We understand that Our Game can be used by children. Generally speaking, most of our Services are not intended for children under the age of 13 (or minors aged from 13 to 17 years located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.

Though our Services do not target Children as the primary audience, we may collect age information before allowing /not allowing a user to proceed for certain Services. For users who identify themselves as Children, We obtain legally valid parental consent.

If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.

6. When do We collect information?

6.1. We collect information from You when You register in the Game, log into the Game, play, surf the Website of the Game, subscribe to a newsletter, fill out a form or enter information on the Website of the Game, contact Us, respond to a survey or marketing communication, or use certain other Game features.

6.2. We may receive information about You from third parties, for example, if You decide to log into the Game using any of Your accounts on other platforms. We may combine such information received from third parties with the data that You provided Yourself or that has been collected automatically. All kinds of information will be processed according to this Policy.

6.3. If You do not ask Us to delete certain data beforehand, We will store it for the period indicated by law, or necessary for the realization of the purposes for which We have collected it. In any case We may retain your personal information so long as Your in-Game account is active.

7. Purposes for processing information according to this Privacy Policy.

7.1. We collect and process your personal data in order to:

7.2. Beyond these purposes, we process your data only if you have granted express consent for its stated purposes (for example, market to you specifically, such as through email remarketing and web retargeting).

8. What is the legal basis for processing your personal information?

8.1. We are committed to protecting Your privacy and handling Your data in an open and transparent manner and as such We process Your personal data for one or more of the following reasons:

9. Transfer of information to third parties.

9.1. We do not sell or rent Your personal information to third parties. We do not transfer Your personal data to third parties, with the exception of cases as specified in the Privacy Policy.

9.2. We may use third party companies and individuals for the purpose of developing and supporting the Game, providing access to the Game on Our behalf and services in it (e.g., without restriction, hosting and operating the Game, database management, web analytics pertaining to the processing of payments, detecting fraudulent activities, and improving the Game, or helping Us in analyzing the practices of Your usage of the Game). Such third parties may have access to Your personal data within the context of performing such work on Our behalf. These processors may be located outside the European Union. Please note that the Company grants access to any information under the condition that the third party ensures the safety of the information to which it may have access according to the data protection laws and the GDPR.

9.3. In particular, We work with (or may work with in the future) network advertisers, advertising agencies, providers of analytics services and other providers, which provide Us with information regarding the traffic on the Website, including the pages visited and actions taken by a player; support Our advertisements on other websites, mobile applications and other places on the internet; provide Us with information on the usage of the Game and the effectiveness of Our advertisements. Our service providers may collect certain information about Your visits and actions in the Game, as well as other websites or services. They may also install and gain access to their own tracking technologies on Your technical device (including cookies and web beacons) and may use this information to show You targeted advertisements, provided You give Your consent to these activities.

9.4. We may also share Your personal information with other entities of our corporate group. Such disclosure is regulated by our internal corporate privacy policies.

9.5. It must be noted that we may disclose information about You for any of the reasons set out hereinabove, or if We are legally required to do so, or if We are authorized under our contractual and statutory obligations, or if you have given Your consent to do so. All data processors appointed by us to process customer data on our behalf are bound by contract to comply with the GDPR provisions.

9.6. Under the circumstances referred to above, recipients of personal data may be, for example: supervisory and other regulatory and public authorities; external consultants, financial and business advisors; auditors and accountants; marketing operators; card payment processing companies; file storage companies, archiving and/or records management companies, cloud storage companies; companies who assist us with the effective provision of our services to you by offering technological expertise, solutions and support; website and advertising agencies.

9.7. Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

We may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the rights, property, or personal safety of Our Company, its customers or any third party.

10. Email communications

If you have given Us Your email for purposes of communication or promotion, we will Use Your data to contact You or send promotional emails relating to Your interests. You may revoke Your consent to being contacted by email for promotional purposes any time, by clicking on an unsubscribe link or replying directly stating Your wish to unsubscribe.

Further, with Your consent, We may make use of email tracking technology to obtain data on if You open an email or if you click on links in an email. This data will be used only in automated ways to help improve future marketing messaging and/or to prioritize follow ups based on perceived communications relevance. Without Your consent, We will not make use of personal data unique to You, such as your IP address, Your device and browser information, or the time and number of times You open an email or click on a link.

11. Cross-border data transmission.

Your personal data may be stored on servers that are located beyond the borders of Your country of origin or residence. We take all technical and organizational measures to ensure the security and safety of any of Your personal data that may be stored and processed outside of Your local jurisdiction. Personal data of the EU residents is kept within EU territory.

12. Changing or deleting Personal data or other information on a player, and refusal to provide such data.

12.1. If You wish to find out what information about You is being stored, You may do so by sending Us a request at this email: You can also send Us a request to delete or change Your personal data. Please note that in the case of deletion of data, some or all of the Game’s functions may become unavailable to You.

12.2. At Your request, We will delete Your personal data and will make a commercially reasonable effort to delete any other information related to You. However, certain data will be stored on Our servers even after the deletion of Your personal data. For example, some personally-non-identifiable information related to You may be stored in Our archives for the purposes of administration. Besides, the requirement of information deletion is conditioned by the need of complying of legal obligations and resolving possible disputes. You should also understand that it is not always technically possible to completely remove certain information from Our databases.

12.3. Additionally, We will not delete any information that You Yourself have posted publicly in the relevant sections of the Game. Please note that neither You nor the Company can delete all copies of any information that has been previously transmitted to other persons in the Game.

13. How do We protect Your information?

13.1. Our servers and other devices as well as software used in the Game are scanned on a regular basis for security holes and known vulnerabilities in order to make Your user experience as safe as possible.

13.2. We use regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We provide training to Our employees and subcontractors on data protection best practices and require them to enter into a confidentiality agreement. In addition, all personal information You supply is encrypted via Secure Socket Layer (SSL) technology.

13.3. We implement a variety of security measures when a player interact with the Game, places an order enters, submits, or accesses their information to maintain the safety of Your personal information. However, while We use all reasonable efforts to protect Your personal information, We cannot guarantee the absolute security of Your data submitted through Our Game.

14. Do We use “cookies”?

14.1. A cookie is a small text file that a website stores on your computer or mobile device (any of them hereafter referred to as – device) when You visit the Game. First party cookies are cookies set by the website of Game. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies. Persistent cookies are cookies saved on Your device and that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.

14.2. How do We use cookies?

We use “first-party cookies”. These are cookies set and controlled by Us, not by any external organisation. However, in Game you will have to accept cookies from external organisations.

The 3 types of first-party cookie we use are to:

Visitor preferences

These are set by Us and only We can read them. They remember:

Operational cookies

There are some cookies that We have to include in order for certain web pages to function. For this reason, they do not require your consent. In particular:

Authentication cookies

These are stored when You log in to Game. This allows Us to analyze Your Game usage and your selections (e.g. your login name, language, or region).

Analytics cookies

We use these purely for internal research on how We can improve the services in our Game. The cookies simply assess how you interact with our website – as an anonymous user (the data gathered does not identify you personally).

Also, this data is not shared with any third parties or used for any other purpose. The anonymised statistics could be shared with contractors working on communication projects under contractual agreement with the Company.

Third-party cookies

Our Game displays content from external providers.

To view this third-party content, you first have to accept their specific terms and conditions. This includes their cookie policies, which we have no control over.

But if you do not view this content, no third-party cookies are installed on your device. Third-party providers (third-party partners) in Game are:

These third-party services are outside of the control of the Company. Providers may, at any time, change their terms of service, purpose and use of cookies, etc.

14.3. How can You manage cookies?

You can manage/delete cookies as you wish - for details, see

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.

Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

See below for descriptions about the cookies used on Our site and how You can opt out from them.

Required Cookies

Our Game stores various cookies that are required for the navigation and usage of it.

Opt-out: You can configure your browser to disable these Required Cookies. This may reduce the game functionality.

Google Analytics (Functional Cookies)

Our Game use Google Analytics, a web analysis service of Google, Inc. (“Google”). Learn more from their Terms of Service and Privacy Policy.

Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.

You can manage your preferences concerning cookies - Advertising Cookies. These cookies are provided by Our third-party partners to analyze and track site visit and sign ups stemming from advertising.

Google AdWords (Advertising Cookies)

Our Game uses Google AdWords Conversion Tracking cookie to measure and optimize the performance and user experience related to Our ads in Google Search or selected Google Display Network sites. Learn more about Google’s privacy policy here.

Opt-out: Visiting Google’s Ads Settings.

15. Ads

15.1.Ads for browser version of Game:

The Company works with publishers and advertising networks (“Advertising Partners”) to deliver interest-based ads to users that have played Game. This practice is often referred to as “online behavioral advertising” or “targeted advertising.” Our Advertising Partners use software that recognizes pixels and cookies (identifiers) that are placed on the browsers of Company Users. When the ad software recognizes these identifiers, they deliver ads for Companies’s products and services to Company Users who are also on other websites.

To learn more about how behavioral advertising works and your ability to opt out, visit the Google’s Ads Settings

15.2. Ads Served in Mobile Apps:

When you play mobile Game, we or our Advertising Partners may use one or more of several different identifiers for your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to you in Game. This means that your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads you see; (b) track the source of installs related to ads seen in other apps; and (c) identify your interests and behavior and target advertising to you based on those interests and behavior.

If you do not want to receive interest-based in-application advertisements on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with controls regarding the collection and use of cross-app data for behavioral advertising.

15.3. All of the opt-out tools described in this subsection are provided by third parties, not by the Company. We do not control or operate these tools or the choices that advertisers and others provide through these tools. Please note that you may still receive third-party advertisements during access to Game after using these opt-out tools, but the advertising you see may be less relevant to your interests.

16. How long We keep Your Information:

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

17. Contact details

If You have any questions concerning the procedures We use to process Your information, or information related to You in the Game, kindly submit them at the following email: or via the contact form on the Game’s Website.