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Main | Privacy Policy |
Privacy Policy Information you provide when using our applications: Directly from you and/or your device by automatic means. The Company collects Personal Data directly from you and/or your device (such as your phone or computer) by automatic means when you use our Services or interact with our ads outside of our Services on third-party websites or applications, including through cookies or similar technologies or software development kits (SDKs) For more information regarding the Company’s use of cookies, please view our Cookie information. We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others. 3. How do we use your Personal Data? We use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customize our Services to you, these include the following processing activities: To perform our contract with you in respect of our Services. Based on your given consent through when using our services Based on our legitimate interest to make our Services the best they can be and provide you with the best possible user experience in our Services Based on our legitimate interest to make our servicesmore intuitive and evaluateuser behaviours andpreferences. Based on our legitimate interest to facilitateperformance marketing. Based on our legitimate interest to safeguard our operations. Based on our legitimate interest to establish, exercise and defend legal claims. In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above. 4. Who we share your information with. Your Personal Data will (for the purposes described in this Privacy Policy) be transferred or disclosed to third parties, for the processing of that Personal Data on our behalf, such as to: 5. Appropriate Safeguards to countries outside the EU/EEA-area In connection with the processing activities described in this Privacy Policy, we share information outside of the European Union (“EU”) and the European Economic Area(“EEA”). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies or the service providers we use to provide the Services may be located outside of the EU and the EEA or if you connect from a location outside the EEA. Where the Company transfers Personal Data outside the EU/EEA, The Company will ensure that Standard Contractual Clauses have been entered into between the transferring entity and the receiving external party. Alternatively, other safeguards will be put in place prior to such transfers. Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means. You are under Data Privacy Laws upon request entitled receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outsidethe EU/EEA. You can do so by reaching out to our Data Processing Officer diac@bigzur.com. 6. How long do we keep hold of your information? We will retain your information only for as long as is necessary for the purposes set out in thisPrivacy Policy. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you; (ii) as required by legal obligations to which the Company is subject (such as tax and accounting obligations); and (iii) as advisable in light ofour legal position (such as applicable statutes of limitations). For more specific information about data retention terms, please contact our Data Processing Officer diac@bigzur.com and we will provide the specific data retention terms for your jurisdiction. 7. Security We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorised or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorised access. 8. Your rights Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services,we will collect data relating to you for some or all the purposes described in this Privacy Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Services, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings. In relation to our processing of your Personal Data you have, under certain circumstances, the right to exercise the following rights: Access You may request confirmation whether or not Personal Data is processed and, if that is the case, access to your Personal Data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal Data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise. Object to certain processing You may object to the processing of your Personal Data on the basis of a legitimate interest, on grounds relating to your particular situation and to the processing for direct marketing purposes. To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message. Rectification You have at any time the right to have inaccurate Personal Data rectified, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Data completed. Erasure You may have your Personal Data erased under certain circumstances such as when your Personal Data is no longer needed for the purposes for which it was collected. Restriction of processing You may ask us to restrict the processing of your Personal Data to only comprise storage of your Personal Data under certain circumstances, such as when the processing is unlawful, but you do not wish your Personal Data erased. Withdrawal of consent You have the right to at any time withdraw your consent to processing of Personal Data to the extent the processing is based on your consent. This does not affect the lawfulness of processing based on consent before its withdrawal. Data Portability You may ask to receive a machine-readable copy of Personal Data processed and ask for the information to be transferred to another Controller (where possible). This only refers to such Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you and only to the extent the Personal Data has been provided to the Company by you (data portability). Complaints to the supervisory authority You have the right to lodge complaints pertaining to the processing of your Personal Data to the relevant data protection supervisory authority. How to adjust your preferences To access your data in our Services or to request its deletion, please use the automatic tools provided in our Services. These tools are specific to each of our Services. You willfind them in the game settings under “Settings” or a similarly named option. On the same page, you can also opt out of our personalized offers, where applicable. If you opt out of interest-based advertising, you will still be able to play our games and you may still see advertising in our games. You can also choose to prevent your device's ad identifier by changing the settings of your device. We ask you to primarily use these tools to submit requests, because that helps us validate, process, and fulfil your request more quickly and reliably. If you have any questions about this Privacy Policy or our data collection practices, please contact us at the address or email set out under section 1 of this Privacy Policy and specify your country of residence and the nature of your question. 9. Note for California residents If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018 (“CCPA”), you are entitled to receive specific information on how we process your data. You also have specific rights to your data, including the right to opt out of the sale of your personal information. To review this specific information and familiarise yourself with your rights under the CCPA, please review our Supplemental Privacy Notice for California Residents. 10. Privacy Policy Addendum - Asia This section applies to residents connecting from or for the services offered in South Korea and Japan. Consent to the collection, use and transfer of personal information By using our services, you consent to the collection, transfer and use of your personal information as outlined in this Privacy Policy. This includes consenting to the transfer of your personal information to other parties (including overseas transfers) as outlined above insections 4, 11 and 12 of this Policy. You may withdraw your consent at any time. Withdrawing your consent may impact your ability to use our Services, as the use of your personal information is necessary for the functioning of the Services. Retention and methods of destruction of personal information When personal information becomes unnecessary, the retention period has expired or the purpose of processing has been achieved, we take appropriate measures to render the personal information unreadable and/or unidentifiable. This may include permanent deletion of your personal information that we have collected. Please see section 6 of this Privacy Policy formore information about retention periods. If we must keep your personal information in order to comply with relevant laws or regulations, your information will be stored separately and only used for such compliance purposes. We remove and destroy personal information in accordance with applicable law and only for the duration of the relevant retention period (as set out in this Privacy Policy). Personal information stored in electronic form is destroyed and/or anonymized so that it cannot be reasonably reproduced and physical records are destroyed by actions such as shredding or incineration. 11. Changes to the terms of this Privacy Policy We may update this Privacy Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here and last date of update is available at the top of this page. We will also inform you of any changes by other means that are appropriate to the significance of the changes. 12. Data controllers Company name: Apple Inc. Purpose: Sign-in for Crossplay, Purchases, Game Center Achievements Company name: Google LLC Purpose: Advertisements, Sign-in for Crossplay, Purchases, Game Center Achievements, Advertisements 13. Data processors Company name: IronSource Ltd Purpose: Advertisements Company name: Unity Software Inc. Purpose: Advertisements, Marketing Company name: AppsFlyer Inc. Purpose: Analytics |