Privacy Policy

City IT Services LLC ('we', 'Company', 'us') owns and operates the Services. We are committed to full transparency regarding our privacy practices.

The Services consist of the website (Rocket Wings.net) and all related pages ('Website'), as well as our mobile applications published on Google Play and/or the App Store ('Apps'), including 'Rocket Wings'. Collectively, these are referred to as the 'Services'.

This Privacy Policy explains how your personal data may be collected, used, and protected. We have aimed to write it in clear, straightforward language to help you understand the legal aspects. Our goal is to assure you that your personal data is safe with us.

The Privacy Policy covers:

• which personal data we process;
• why we process it;
• your rights regarding your data;
• whether we share data with third parties;
• how we protect your personal data;
• and other important details about data processing.

This Privacy Policy forms an integral part of our Terms. Please read both carefully.

If you have any questions about this Privacy Policy, how we handle your personal data, or wish to exercise your rights, please contact us at: gorileung260408@outlook.com

1. What is Personal Data?

Personal data means any information relating to an identified or identifiable natural person. This can include your name, email address, location data, or technical identifiers such as MAC address, IMEI, UDID, IDFA, IP address (static or dynamic), browser type, and operating system.

For California residents, personal data also includes information that identifies, relates to, or could reasonably be linked (directly or indirectly) with a particular consumer or household.

'Processing' means any operation performed on personal data, such as collection, recording, organization, storage, adaptation, use, disclosure, or erasure.

For California residents, 'Sell', 'selling', 'sale', or 'sold' means transferring personal data to another business or third party for monetary or other valuable consideration.

Sensitive personal data includes information about racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data (for identification), health data, sexual orientation, or criminal records. For Indian residents, sensitive data also includes passwords and financial information (e.g., bank or card details).

We do not intentionally collect or process sensitive personal data.

Other terms used here have the same meaning as in our Terms or the GDPR (Regulation (EU) 2016/679). The Company is the data controller for personal data collected via the Services.

2. What Data Do We Collect?

We collect different categories of data depending on how you use our Services. We do not knowingly collect sensitive information.

a. Website

1) Requests and communications
When you contact us via the email address provided on the Website, we collect the information you voluntarily provide (e.g., name, surname, email address). Please avoid sharing excessive or third-party personal data.

2) Newsletter subscriptions
If you subscribe to our newsletter, we collect your email address and username. You can unsubscribe at any time using the link in every email.

3) Automated collection (cookies and similar technologies)
Cookies are small text files stored on your device. They help us improve your experience and ensure the Services function properly. With your consent, we may also use cookies for analytics and personalized advertising. See our Cookies Policy for more details.

b. The 'Rocket Wings' App

1) Account data
You do not need to create an account to use the App. You will be assigned a guest account without providing any personal data. You may choose to sign in using Google Play Games, Gamekit, Google, Apple, or Facebook. If you do so, you give us permission to access your first name, last name, and email address from that third-party account. This information is optional – you can continue using the App as a guest without it.

2) Requests and communications
When you contact us through the App, we collect the data you provide (e.g., name, surname, email address). Please do not include unnecessary or third-party personal data.

3) Newsletter subscriptions
Same as described for the Website – we collect your email and username, and you can unsubscribe at any time.

4) Automated collection
We automatically collect certain technical information, including IP address, unique device identifiers, operating system, and browser type. This helps us improve the App's functionality and your user experience.

5) Financial information
We do not collect your payment credentials (bank details, card numbers, etc.). Payments are processed by third-party providers with appropriate security measures. We only receive transaction IDs and receipts to confirm that a transaction relates to you.

3. Legal Basis and Purposes of Processing

a. Legal Basis

• Performance of a contract: We process most data (e.g., account data where registration is required, request-related data) to fulfill our obligations under the Terms.
• Your consent: For Apps that do not require an account, we process account data based on your consent when you authorize a third-party login. Newsletter subscriptions and non-essential automated collection also rely on your consent.
• Legitimate interests: We may send you marketing emails about similar products or services based on our legitimate interest in business development. We also rely on legitimate interest to store your data temporarily after you delete the App to avoid data loss. You can always unsubscribe.
• Legal obligation: We may ask for your date of birth to verify you are not underage, as required by law.

b. Purposes of Processing

We process your personal data to provide and improve the Services. Specific purposes include:

• Account data (where required): to create and maintain your account, identify you, enable use of the Services, communicate with you, and send newsletters.
• Account data (guest users): to sync game progress across devices and prevent loss of in-game data.
• Request-related data: to respond to your inquiries and ensure satisfaction.
• Newsletter data: to inform you about updates, innovations, and improvements.
• Automatically collected data: as described in our Cookies Policy.

We may also process data to comply with legal obligations, protect vital interests, perform public interest tasks, or pursue legitimate interests (e.g., fraud prevention, legal protection). If we change the purpose, we will notify you and, where required, obtain fresh consent.

We do not sell your data or make automated decisions with legal or significant effects.

4. How Long Do We Keep Your Data?

a. Retention Periods

• Account data: Until your account is inactive for more than 2 years.
• Newsletter data: Until you unsubscribe.
• Request-related data: During our communication plus 6 months afterward.
• Automatically collected data: As specified in our Cookies Policy.

b. Backups

We create regular backups to restore the Services in case of failure. Backups may contain your personal data and are deleted within 3 days. They are used only for restoration purposes based on our legitimate interest.

c. Statistical Processing

We may retain anonymized data longer for statistical purposes (e.g., to assess business performance or improve Services). Once anonymized, data is no longer subject to data protection laws.

5. Sharing Data with Third Parties

We do not sell your personal data. However, to provide and maintain the Services, we may share data with our employees and independent contractors, under strict confidentiality and data processing agreements. All third parties provide at least the same level of protection as described in this Privacy Policy.

6. Your Data Protection Rights

To exercise any of the following rights, email us at gorileung260408@outlook.com. We may verify your identity before responding. We will reply within one month.

You have the right to:

1. Know the sources, location, purpose, and controller of your personal data.
2. Receive information about third parties with whom your data is shared.
3. Obtain a portable copy of your data (where processing is automated and based on consent or contract).
4. Access your data and receive confirmation of whether it is being processed.
5. Object to processing – if we cannot demonstrate a compelling legitimate basis, we will stop.
6. Request correction or deletion of inaccurate or unlawfully processed data.
7. Protect your data from unlawful processing, loss, or destruction.
8. Lodge a complaint with a supervisory authority or court.
9. Place restrictions on processing while giving consent.
10. Withdraw consent at any time (without affecting previous lawful processing).
11. Know about automated decision-making and request human review (currently not used by us).

Additional rights for California residents (CCPA)

12. Request disclosure of categories of personal data collected, sold, shared, or disclosed for business purposes, and the categories of third parties involved.
13. Opt out of any future 'sale' of your personal data. You may also opt out of personalized advertising by contacting us.
14. Non-discrimination for exercising your rights – we will not deny services, charge different prices, or provide a lower quality of service.

7. Age Restrictions

You may only consent to data processing if you meet the minimum age in your jurisdiction:

• EU member countries: 13–16 years (depending on the country)
• USA: 13 years
• Australia: 15 years
• India or Philippines: 18 years
• Other countries: the age of full legal capacity

Our Services are not directed at children below these ages. If we discover that we have collected personal data from such a child, we will delete it immediately. Parents or guardians may contact us to report such cases.

8. Where Is Your Data Stored?

We do not physically store most personal data. Data is hosted in databases and file repositories provided by Amazon Web Services EMEA SARL in Frankfurt, Germany. Backups are also stored in Frankfurt.

9. Security Measures

We implement appropriate security measures, including:

• Confidentiality: All personnel and contractors sign confidentiality agreements. Access is logged.
• Isolation: Zero‑privilege default; access is granted on a need‑to‑have basis.
• Authentication: Password hashing and two‑factor authentication.
• Monitoring: Security reports and activity logs; internal and external performance monitoring.
• Internal policies: Employees and contractors follow a security policy covering organizational, physical, and technical safeguards.

No method of transmission over the Internet is 100% secure. In the event of a data breach that poses a high risk to your rights, we will notify you and the relevant authorities without undue delay. If you are a Philippine resident, you are indemnified for damages caused by inaccurate or unauthorized use of your data.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If changes materially affect your rights, we will notify you by email or via a prominent notice in the App when you first use it after the update. The 'Last modified' date will be updated at the top of this page.

11. Contact Information