Privacy Policy

GameRefinery Oy (”GameRefinery” or “We”) respects your privacy and is dedicated to protecting the privacy of those persons using (“User(s)” or “You”) GameRefinery Online Service and/or Reflection Service (“Service”). This Privacy Policy helps You understand what personally identifiable information and non-personal information We collect, and how We use it.

This Privacy Policy applies to Your use of the Service and You should read this document before using the Service. If You do not agree to the terms of this Privacy Policy, You may not use the Service.

Information related to use of cookies can be found in our Cookie Policy.

“Personal information” refers to information, which allows a User to be specifically identified as an individual person. We will also collect “non-personal information” meaning information that cannot be used to specifically identify anyone. Non-personal information may also result from removing the personally identifiable parts from personal information. We will collect and use both types of information and combinations of both types.

GameRefinery shall not be responsible for the actions of third parties (including people, companies or services), the content of third-party websites, the usage of the information provided by a User to such third parties, or any products or services they may offer.

Processing Personal Information

GameRefinery will only collect such personal information that is relevant for the purposes described in this Privacy Policy.

GameRefinery will process personal information for the purposes of creating Service accounts, using, maintaining, customizing and developing the Service, contacting Users, user verification, providing services, sending customer and marketing information to Users, enabling communication in the Service, conducting research, creating reports and allowing game developers to communicate with GameRefinery and to receive feedback on their games.

We will also use collected information to create a user profile link or combine it with other information we get from third parties, to help in providing the Services to You. Personal information will also be used to provide customer service and other services at your request, to send You information, including confirmations, invoices, technical notices, updates, security alerts, and support messages, as well as communicate with You about other products and services offered by GameRefinery.

GameRefinery commits to adhere to applicable laws and regulations pertaining to processing of personal information, as well as to process personal information in compliance with good processing practices. All personnel processing personal information are obliged to keep such information strictly confidential.

GameRefinery does not use automatic decision-making. However, we use profiling to provide you with individualized offers regarding the Service.

Legal basis for the processing

The legal basis for the processing of Your personal information is, where not stated otherwise or another legal basis is otherwise applicable, the performance of the contract for providing GameRefinery’s Service to You, as permitted by GDPR article 6(1)(b).

GameRefinery can also process Your personal information where we have a legitimate interest to do so, as permitted by GDPR article 6(1)(f), such as for marketing purposes.

Where the processing is such that Your consent is required by the applicable legislation, We will state so and obtain Your consent, and this will be the legal basis for the processing of Your personal information, as permitted by GDPR article 6(1)(a). However, You have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If such withdrawal means that We are no longer able to provide the Service to You, we may cease providing the Service.

In some cases, We may also have a legal obligation to collect personal information from You or may otherwise need the personal information to protect Your vital interests or those of another person.

Information We may Collect and Sources of Information

Depending on the part of Service You are using, We may collect several categories of information:

We will collect information that You give to us, for example when You sign up to use our Service. This information may include your name, e-mail address, company name and phone number. If You purchase a subscription to Service, our nominated third party payment processor may collect and process Your financial, credit card and related information.

If You use our Service, You may be asked to provide us with information about the account You use for development of your apps, for example your iTunes Connect or Google Play account, and any associated login or password details for access to your app platform account.

You may either send us or We may collect data from your app platform account when You link it to the Services for the purpose of analysis using our algorithmic statistic generation model (“User Input Data”). We use User Input Data to compile analytical information (whether in data, text, graphic or other form) which we create and give you access to via the Service based on algorithm-driven analysis of User Input Data and other data gathered from the online third-party data sources, including websites, the app platform account and various digital distribution, analytics, advertising and monetization platforms (“App Intelligence”).

If you do not provide GameRefinery the required information, this may mean that we are not able to provide the Service to you.

We may use technical means to collect information about You when You use our Service. This information can include Your Internet Protocol address, time of Your requests or actions in the Service, hardware identifiers, operating system and version, access times, browser type and language, location based on Internet Protocol (“IP”) address, media access control (“MAC”) address, international mobile equipment identity (“IMEI”) and Your device name.

From time to time, We may receive personal information about You from third party sources (including Facebook and LinkedIn), but only where We have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose Your personal information to us. We use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you and provide us with insight as to how we can improve site functionality.

Retention of Personal Data

GameRefinery retains the personal information collected pursuant to this Privacy Policy for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter, if the collected personal information is no longer needed for purposes specified in this Privacy Policy, GameRefinery will delete all aforementioned personal information in its possession within a reasonable timeframe or render it anonymous, meaning “non-personal data”. Further, GameRefinery will store the following categories of Your personal information for the retention periods outlined below:

CategoryRetention period
Information You give to usDuring Your subscription term in our Service
Technically gathered informationDuring Your subscription term in our Service

We will immediately cease collection of Your User Input Data if you delete Your account, but any of Your previously collected User Input Data that is already included in the pool of data used to compile our App Intelligence will not be automatically deleted (but those records will no longer be linked back to You). If you do not ask us to delete historic User Input Data, We will use that data to compile App Intelligence. Should You request deletion of all of the data relation to your app sales, please do contact us using the contact details provided below.

Recipients of Information

GameRefinery uses external service providers to provide technical solutions or services for processing stored information and for accessing the stored information by using a technical interface and will share Your personal information with such third-party service providers to the extent that it is reasonably necessary to perform, improve or maintain the Service. We use third party service providers, such as e-mail service providers, credit card processors, information analyzers and business intelligence providers. GameRefinery has the right to share personal information as necessary for the aforementioned service providers to provide their services to GameRefinery. List of the processors and other recipients can be provided upon request.

GameRefinery will not disclose your stored personal information to third parties for direct marketing, market research, polls or public registers without your consent. Personal information may be used for targeted in-service marketing and other similar purposes, and upon your consent, to email marketing by GameRefinery and selected third-parties. Your User Input Data (such as iTunes Sales Reports) informs our App Intelligence but remains private to You. We do not share Your User Input Data with other users of the Reflection Service. GameRefinery has the right to share non-personal information (such as anonymous User usage data, referring / exit pages and URLs, asset views, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality of the Service.

In exceptional circumstances personal information may be disclosed to third parties if required under any applicable law or regulation or order by competent authorities, or in order to enforce the Terms of Service and to investigate possible infringing use of the Service as well as to guarantee the safety of the Service.

GameRefinery has the right to share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business. Further, GameRefinery has the right to share aggregate or anonymous information with advertisers, publishers, business partners, and other third parties.

International Data Transfers

For some of our Services, Your personal information may be transferred to, and processed in, countries outside of the EEA. However, We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These measures include transferring your personal data to third parties who are located in a country which the European Commission has determined has data protection laws that are at least as protective as those in Europe, and transferring your personal data to third parties who have entered into standard contractual clauses with Us. For more information about these safeguards please contact us using the contact details provided below.

Protection of Information

The personal information will be maintained in external service providers’ servers with appropriate safeguards. The personal information is protected by appropriate industry standard, technical and organizational safety measures. Although We make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, We cannot guarantee the absolute security of that information during its transmission or its storage on our systems. GameRefinery will post a notice on the GameRefinery website or through the Service in case material security breach that endangers your privacy or personal information. GameRefinery may also temporarily shut down a service to protect personal information.

Rights of the Data Subjects and Contact Information

Right to access, correct and object

You may contact GameRefinery and We will inform what personal information We have collected and processed regarding You and the purposes such data are used for. You have the right to have corrected any incorrect, incomplete, outdated, or unnecessary personal information stored about You by contacting GameRefinery.

You may object to certain use of personal information when such processing is based on legitimate interest, including direct marketing or profiling. You may opt-out of receiving promotional emails by following the instructions in those emails. If You opt-out, We can still send you non-promotional customer information, such as emails about Your account, providing GameRefinery’s services and products or GameRefinery’s ongoing relationship with You.

Right to deletion and restriction of processing

You may also ask GameRefinery to delete Your personal information from our systems. We will comply with such request unless We have a legitimate ground to not delete the data. After the data has been deleted, We may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.

You may request GameRefinery to restrict processing of certain personal information. Your personal information will then only be stored and not processed otherwise, this may, however, lead to fewer possibilities to use the Service. If such restriction means that We are no longer able to provide the Service to You, GameRefinery shall be entitled to stop providing the Service.

Right to data portability

You have the right to receive personal information provided by You to GameRefinery in a structured, commonly used format. GameRefinery provides no guarantee that this information will be compatible, relevant or useful to any other service.

How to use the rights

These rights may be used by sending a letter or e-mail to GameRefinery on the addresses set out below, including the following information: user name used for login purposes (no password), name and phone number. We may request the provision of additional information necessary to confirm Your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.


In case You consider GameRefinery’s processing activities of personal information to be inconsistent with the applicable data protection laws, a complaint may be lodged with a supervisory authority for data protection.

Changes to the Privacy Policy

GameRefinery may change this Privacy Policy from time to time, and at GameRefinery‘s sole discretion. All changes hereto will be made available on this website, which is why GameRefinery encourages Users to frequently check this page for any changes to this Privacy Policy. Changes hereto will not prejudice Users’ rights without their consent.

Contact Information

The User may at any time contact GameRefinery at the address here below.

GameRefinery Oy

Business ID: 2669345-8
Address: Tammasaarenkatu 5, 00180 Helsinki, Finland

Last updated: March 17, 2020