Data Protection & Privacy Policy

True Pilots is a Cyprus company registered at 27 Evagorou Avenue, IRINI Building, Office 44, Trypiotis 1066, Nicosia, Cyprus.

If you have questions specifically about data privacy, you can contact us using info@truepilots.com.

This privacy policy applies to you if you are a visitor of our websites or play our games if they are embedded on a third party website/storefront, regardless on which platform you’re using our services (mobile, desktop).

We collect personal data from you when you register an account with us (i.e. in our games). The following categories of data are processed by us:

The way we process these data, why and on what legal basis we do this are explained below.

Sensitive data in the GDPR are the so-called "special categories of personal data", e.g. on your racial or ethnic origin, your health, or your political opinions.

We do not collect any sensitive data from you.

That said, we cannot control what content you put into messages you write through our games or websites (e.g. to other users, or when you create a support ticket). While we strive to protect any privacy implied by such a transfer, we cannot differentiate a particularly sensitive message from any other kind of message you may choose to write. Please be aware that such messages are not given any additional protection.

If you are younger than 16, you need to obtain a clear consent of your parent or guardian if you are willing to use our websites or games. A parent or a guardian can at any time exercise all the applicable rights available by law and those listed in this Data Policy on your behalf.

We only process a user’s personal data in compliance with the relevant and pertinent data protection regulations. This means that a user’s data shall only be processed if the user has given his or her legal permission for us to do so. This is the case especially then when data processing is required in order for us to be able to provide our contractual and online services, or when required by law, we are in possession of the consent of the user, and when it is collected for the sake of our legally legitimate interests (i.e. interest in the analysis, optimization, and economic operation and safety of our online product as per Article 6 (1) (f) of the GDPR, in particular with regard to range measurement, the creation of profiles for advertising and marketing purposes, as well as the collection of access data and the use of the services of third-party providers).

We feel obligated to point out that Art. 6 (1) (a) and Art. 7 of the GDPR serve as the legal basis for consent, Art. 6 (1) (b) of the GDPR serves as the legal basis for processing for the performance of services and the performance of contractual measures, Art. 6 (1) (c) of the GDPR serves as the legal basis for processing in order to fulfill our legal obligations, and Art. 6 (1) (f) of the GDPR serves as the legal basis for processing in order to safeguard legitimate interests.

Our games cannot function without certain data. In order for you to have any meaningful progress in your gameplay, we need to be able to reliably differentiate you from other users of our games, which is why we ask you to register an account. When you log in, we compare your login credentials against those we have on file, and maintain your customisation data and game progress.

Your display name, avatar, and certain elements of your progress are made public within our game platform (e.g. for in-game leaderboards, or in the in-game contest). You can change your display name and avatar at any time.

The recommendation and reward feature shows the friends you have invited to the game and the friends that have been invited by friends as well as the time these players have been using the service for the last time.

Additionally, your country and language is used to provide you with a localisation of our games - we will try to serve you content in your language and our in-game shop in your local currency.

If you want to buy in-game currency in our in-game shop, your interaction will usually be with third-party payment processors. In either case, if a payment was successful, we get this information as a digital invoice, which we store to fulfil legal requirements (Article 6.1.c GDPR), to retain them in the case of legal dispute (legitimate interest; Article 6.1.f GDPR), and to optimise our web presence for you (legitimate interest; Article 6.1.f GDPR).

These invoices contain data on what item you purchased, how much you paid for the item and what method you used to pay us with. We do not store information that could be used to make a payment on your behalf.

To help secure our games and to prevent fraud, we store data such as your IP address and certain device information when you access our games and interact with those.

Your device data and IP address information is stored and logged to allow fraud and data security forensic investigation. Your IP address information is also processed automatically by our network devices - this infrastructure is needed to serve our website, but also to deny access to IP addresses known to be in use by malicious actors.

Due to the nature of this interest, we cannot offer you a means to opt-out of this processing, as this would undermine its purpose (and in some cases, an opt-out is technically impossible - e.g. we cannot exempt your IP address from processing by our network devices).

If you object to this processing, we ask that you please do not use our games.

To optimise our marketing campaigns and our games, we track information about your behaviour and preferences. These data are pseudonymised and stored separately from your account data. While they are stored on an individual basis, these data are only available to the employees that must work with these data, and they are reported on only in aggregate.

Over the course of campaign optimisation, we share some of these data with third-party trackers (listed below).

There are some data we require from you:

Without these personal data we cannot provide our services to you.

We do not use your personal data for any automated individual decision-making that would have legal or otherwise similarly significant effects on you.

Any effects of automated decisions based on your personal data are confined to our game platform. For example, we may use your purchase information (frequency and amount) to give you automated, customised discounts in-game.

For data that we store for legal reasons, we retain the data as long as legally required of us (up to ten years).

For data that we store in consideration of legal disputes, we retain the data as long as legally permissible. This may be up to 30 years.

For logs storing network data, we delete the data in regular intervals - the exact time varies based on configuration rules (which may prune the logs based on size rather than a fixed time), on whether the data was part of a snapshot that landed in a backup, and on whether the logs are part of a set of logs that are routinely forwarded to a central log repository, but will not exceed 2 years.

The providers we use are contractually bound to treat your data with the utmost care. Whenever the process allows, we anonymise or pseudonymise your data.

Under no circumstances do we sell your data to third parties.

We are committed to complying to the General Data Protection Regulation (GDPR) - one of the strictest Data Privacy regulation in the world. This affords you several inherent rights to your personal data.

You have the right to…​

You can easily ask us to delete your data (which is only possible with the full deletion of your game account): please contact us either through the support widget on our website, or by contacting us via email (info@truepilots.com). If you contact us, please understand that we may need to ask you to prove your identity - after all, you wouldn’t want a random stranger to get access to your data/delete your profile, and neither do we.

Note that it may take up to a month for us to process a request of yours. Should there be any delay, we will of course let you know.

You can find additional legal information in the Articles 7.3, 15 – 21 and 77 of the GDPR.

To improve our games, to correct errors, to optimise the site and our campaigns used to promote it, we store pseudonymised data about our players' behaviour on our website and in games and use several tracking services to assist us (on basis of Article 6.1.f GDPR).

These services either use cookies (desktop) or device IDs (mobile) to allow them to correlate the behavioural data they collect (for example to tell us how long the average user spent on our site, or how great a percentage of users that visited our site registered an account with us).

Data exchanged may be information on when you registered an account with us, from where you came (which banner you clicked or which game site you play our games on), your device parameters (e.g. operating system, brand), your user ID in our games, page impressions (time and page identifier) or payments you make.

The trackers use these data either to craft approximate behavioural profiles of you (enabling them to supply better marketing targeting to the users of their service), or to permit us to pay our campaigns by registration events or paying users rather than impressions ("performance marketing").

We make use of the widespread SSL (Secure Socket Layer) encryption method to deliver our site securely when you visit it, in conjunction with the highest level of encryption supported by your browser.

You can tell when any single page at our website is transmitted in encrypted form by the closed presentation of the lock (or key) symbol in your browser’s status bar.

We also take appropriate technical and organizational security measures to protect your data against destruction, accidental or intentional manipulation, partial or total loss, or against the unauthorized access by third parties. Our security measures are continuously improved upon in accordance with technological developments.