Privacy Policy of Online Games Operated by Sharkrise s.r.o.
(hereinafter referred to as the “Privacy Policy”)
This Privacy Policy outlines the rights and obligations of Sharkrise s.r.o. (hereinafter referred to as the “Operator”), as well as the rights of Users, in relation to the processing of personal data within all online games operated by the Operator (hereinafter referred to as the “Game” or “Games”).
The Operator processes personal data in accordance with:
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Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), and
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Act No. 18/2018 Coll. of the Slovak Republic on the Protection of Personal Data (hereinafter referred to as the “Data Protection Act”).
The Games may be provided through the Operator’s own websites or third-party platforms, including but not limited to iOS (App Store), Android (Google Play), Facebook, or Amazon (hereinafter referred to as the “Platforms”).
Operator:
Name: Sharkrise s.r.o.
Registered Seat: Ulica Michala Bučiča 7477/5, 841 07 Bratislava, Slovak Republic
Company Registration No.: 56989555
Commercial Register: District Court Bratislava III, Section: Sro, File No.: 188376/B
E-mail: dev@sharkrise.com
Article I – Preamble
Personal data processed in connection with the Games are handled in good faith and exclusively in accordance with applicable laws and international treaties binding upon the Slovak Republic, in particular:
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Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), and
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Act No. 18/2018 Coll. on the Protection of Personal Data (Slovakia).
The Operator takes great care to prevent any violation of the fundamental rights and freedoms of natural persons, especially their right to human dignity, privacy, and protection from unlawful interference.
All personal data are processed transparently, lawfully, and only for clearly defined purposes related to the operation of the Games.
Article II – Definitions
Address – a set of data identifying a person’s residence (street name, number, town, postal code, district, country).
Affected Person / User – a natural person above the age of 16 who uses or registers for the Game and whose personal data are processed by the Operator.
Authorized Person – any natural person who, based on authorization or job duty, processes personal data under the Operator’s instructions in accordance with the Data Protection Act.
Blocking of Personal Data – a temporary or permanent restriction of processing, during which personal data may only be processed to fulfill obligations under the Data Protection Act.
Consent of the Affected Person – any freely given, specific, informed, and unambiguous expression of will by which the User agrees to the processing of their personal data.
Cross-border Transfer – any transfer of personal data to or from the territory of the Slovak Republic.
Deletion of Personal Data – erasure or physical destruction of data in a manner that makes them unrecoverable.
Disclosure of Personal Data – making personal data accessible to third parties for the purpose of operating the Game or fulfilling contractual or legal obligations.
Game – any digital interactive product operated by Sharkrise s.r.o. for entertainment or educational purposes, communicating with the User through 2D or 3D graphics and sound.
Identification Code of the User – a platform-specific identifier (e.g. Device ID, Advertising ID, IDFA, Android ID, Google Advertiser ID, Steam ID).
Information System – any structured set of personal data processed automatically or non-automatically for a specific purpose.
Marketing to the User – personalized or contextual promotion of the Operator’s products and services within the Game.
Office – the Office for Personal Data Protection of the Slovak Republic, which supervises compliance with data-protection legislation.
Operator – Sharkrise s.r.o., Ulica Michala Bučiča 7477/5, 841 07 Bratislava, Slovak Republic, Company Registration No.: 56989555.
Personal Data – any information relating to an identified or identifiable natural person. Within this Policy, personal data are divided into:
a) Essential Personal Data – data required for participation in the Game, without which access is not technically possible;
b) Additional Personal Data – data processed only on the basis of the User’s consent;
c) Data processed on the basis of legitimate interest – data processed for operational, analytical, or security purposes of the Operator.
Processing of Personal Data – any operation performed on personal data, such as collection, storage, modification, use, transmission, or deletion.
Product Marketing – promotion of the Operator’s products on external websites to raise awareness and attract new Users.
Publishing of Personal Data – public disclosure through online platforms or media.
Purpose of Processing – a clearly defined and lawful reason for processing personal data.
Service Provider (Processor) – a third party processing personal data on behalf of the Operator under a written agreement compliant with § 8 of the Data Protection Act and Art. 28 GDPR.
Third Party – any person other than the User, Operator, Service Provider, or Authorized Person.
Article III – Data Subject (User)
The User is any natural person over 16 years of age whose personal data are processed by the Operator in connection with the Game.
By agreeing to this Privacy Policy, the User declares that they:
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are at least 16 years old and thus may give consent without parental approval;
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have read and understood the Terms of Service (ToS) and this Privacy Policy;
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voluntarily provide Essential Personal Data necessary to join and use the Game.
User Rights
The User has the right to:
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obtain information on the scope and purpose of data processing,
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access their personal data,
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request rectification, restriction, or erasure of personal data,
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object to processing or to data transfer.
- withdraw Consent of the Affected Person at any time
- file a complaint at the appropriate Office, if the Operator rejects the User’s request to exercise his/her rights.
Requests may be sent to dev@sharkrise.com. Each request must include user identification (submitted from the email address registered to the user). For faster processing, we recommend including the game and server in your request.
Article IV – Third Parties and Service Providers
The Operator cooperates only with trusted third-party service providers that process personal data on behalf of Sharkrise s.r.o. under a written agreement compliant with Article 28 of the GDPR and §8 of the Slovak Data Protection Act.
Personal data are disclosed to such third parties only to the extent necessary for the performance of their contractual obligations and always in accordance with applicable data protection laws.
If the Operator discovers that incorrect, outdated, or unlawfully processed personal data have been disclosed to a third party, the Operator will notify that third party without undue delay and instruct it to take corrective actions (such as blocking, correcting, updating, or deleting the affected data).
This notification may be omitted only if it is objectively impossible or would require disproportionate effort. Upon request from the Office for Personal Data Protection, the Operator must demonstrate the reason for such omission.
1. Categories of Third Parties
The Operator may share or store Users’ personal data with the following categories of third parties:
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Hosting and data storage providers – for operating the Games and maintaining servers.
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Analytics and performance tools – TO BE ADDED LATER.
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Advertising and marketing partners – TO BE ADDED LATER.
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Customer support providers – TO BE ADDED LATER.
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Legal and accounting advisors – TO BE ADDED LATER.
2. Example Service Providers
The Operator may currently use or in the future cooperate with the following service providers (or their equivalents):
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Websupport, s.r.o. – hosting services (Slovak Republic)
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MongoDB, Inc. – TO BE ADDED LATER
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Google LLC – TO BE ADDED LATER
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Meta Platforms Ireland Ltd. – TO BE ADDED LATER
A full and up-to-date list of service providers is available upon written request to: dev@sharkrise.com
Article V – Personal data categories, purpose and retention period
The Operator processes personal data of the User which were disclosed by the User for the purposes of his/her serious intention of joining the Game. The User acknowledges the fact that without the disclosure of these Essential Personal Data it is not technically possible to join the Game and for this purpose the User disclosed to the Operator the following personal data directly or indirectly:
email address, username or display name, Game Account ID, platform identifier (e.g. IDFA/GAID/Steam ID), IP address, country of the User, login timestamps.
The User may give the Operator consent to process the following Additional Personal Data in the corresponding window directly within the Game. The User may withdraw this consent at any time. (These Additional Personal Data are processed by the Operator only after the consent is given by the User):
avatar or profile photo (if uploaded voluntarily), e-mail address for marketing communication or information purposes, approximate location (country or region) for localized offers or advertisements, advertising identifier (e.g. IDFA/GAID) for personalized ads, push notification token (if enabled), in-game survey or feedback responses (if applicable), other optional profile data explicitly provided by the User.
The Operator is processing Data processed on the basis of legitimate interest for operational, analytical, or security purposes. This enables the Operator to ensure smooth operation of the Game and to optimize and develop the Game for the benefit of the Users. The Operator processes the following personal data within the scope of this legitimate interest:
IP address, country of the User, device and technical information (device model, operating system, app version, language settings), telemetry and gameplay data (e.g. feature usage, session length), crash and error logs, platform identifier (e.g. IDFA/GAID) used for analytical or anti-fraud purposes.
Data Retention
Essential Personal Data:
The Operator will retain Essential Personal Data for as long as there is a valid contract between the User and the Operator. After the contract ends, the Operator will delete the data within 60 days.
Additional Personal Data (processed on the basis of consent):
The Operator will retain Additional Personal Data until the user withdraws consent. After consent is withdrawn, the Operator will delete the data within 60 days.
Data processed on the basis of legitimate interest:
The Operator will retain such data for as long as the legitimate interest exists. Once the legitimate interest no longer applies, the Operator will delete the data within 60 days.
Data required by applicable law:
The Operator will retain any Personal Data that must be kept to comply with applicable legal obligations for the period required by law. Regarding article 58 of directive 2006/112/EC on common system of value added tax and article 24f of the Council implementing regulation (EU) No 1042/2013, the Operator will store relevant Personal Data for a period necessary to fulfill its obligations (maximum of 10 years).
Article VI – Safety and Security
The Operator shall ensure the security of personal data processing by implementing appropriate technical, organizational, and personnel measures to protect data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
All persons who process personal data on behalf of the Operator are duly authorized and bound by confidentiality obligations.
These measures are regularly updated to reflect technological developments and the level of risk associated with processing.
Article VII – Cookies Policy
The Operator may use cookies or similar technologies to ensure proper operation of the Game and its website, to remember User preferences, and to analyze technical performance.
TO BE ADDED LATER: Detailed information about cookie categories (e.g., analytics, advertising, preferences) and cookie consent management tools once the official website and tracking features are launched.
Users may disable cookies in their browser settings at any time. However, doing so may limit certain Game or website features.
Article VIII – Deletion of Personal Data
The Operator deletes personal data within 60 days of receiving a valid deletion request or after the User’s account is deleted, unless legal obligations require longer storage.
Users may request the deletion of their data via email at dev@sharkrise.com
