Last updated: January, 2023
BAVOVNAGAMES LTD, having its registered address at A.G. Leventis, 5, THE LEVENTIS GALLERY TOWER, 13th floor, Flat/office 1301, 1097, Nicosia, Cyprus, with company registration number ΗΕ 440968 (hereinafter referred to as “Company”, “we”, “us” or “our“) has developed this Privacy Policy (hereinafter referred to as “Privacy” or “Privacy Policy”) to let you know how we collect and use the personal data you provide to us while visiting this website (hereinafter referred to as the “Website“) and using our games, applications and other services (hereinafter referred to as “Services“). By visiting our Website and/or using our Services, you (hereinafter referred to as “you”, “your”, and “User”) accept the practices described in this Privacy Policy.
“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data.
Please read this Privacy Policy carefully before accessing or using our Website and/or Services. When you visit or use our Website and/or Services, you expressly consent to the collection, use, storage, processing, and disclosure of your information, including Personal Data, as described in this Privacy Policy. If you do not agree to this Privacy Policy and/or any other rules posted on the Website, then you may not access the Website and/or use our Services.
INFORMATION WE COLLECT
We may collect and store the following information when you use our Website and/or Services:
1) Information you provide to us: your name, email address, phone number, gender, age, address, birth date, billing and credit card information (if you engage with a paid Service), other information you share with the Services;
2) Information about how you use the Services and our Website:
– the pages you view;
– how you browse the Website and/or our Services etc.;
3) Information automatically collected:
– your IP address, browser type, Internet service provider, and platform type;
– date and time stamp;
– the website from which you came and the website to which you are going when you leave our Website;
– identification numbers associated with your device, device type, model and manufacturer, mobile device operating system brand and model, mobile carrier, phone number, email address, and other apps that you have downloaded);
– Mobile Advertising ID;
4) Cookies and similar technologies;
5) Your communications with us and other users;
6) Information about your location through GPS, Wi-Fi, or other methods;
7) Information that third-party organizations may provide to us, such as contact details, demographic information, credit reference or fraud prevention information.
PURPOSES AND LEGAL BASIS OF PROCESSING YOUR PERSONAL DATA
We may use your Personal Data for the next purposes:
- to comply with applicable laws and regulations;
- to provide you with the Website and/or Services that you ask us for;
- to comply with our obligations arising from any contracts entered into between you and us, or between you and our affiliates or service providers;
- to detect, prevent and address technical issues;
- to provide you with information about other products and services we offer;
- to notify you about changes to our Services;
- for quality assurance, and to record details about the Services you order from us;
- to serve advertising tailored to your preference and interests;
- to improve our Services and Website;
- to perform analytics and understand how users interact with our Services and/or Website in order to continuously improve them either directly or through third-party partners.
Legal basis for processing your Personal Data:
- the processing is necessary for the performance of a contract;
- the processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data;
- you have given us consent to process your Personal Data for specified purposes, such as to provide our Services and other items requested by you;
- the processing is necessary for compliance with a legal obligation.
THIRD PARTIES TO WHOM WE MAY TRANSFER COLLECTED PERSONAL DATA OR WHO MAY PROCESS THIS PERSONAL DATA
We may share collected Personal Data with:
- Our employees, contractors, affiliates, distributors, providers and suppliers who provide certain services to us or on our behalf, such as payment services, operating and supporting the Services, analyzing data, or performing marketing or consulting services, etc.;
- Our parent company, subsidiaries and corporate affiliates, joint venturers, or other companies under common control with us;
- Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. Our payment providers may be changed from time to time so you have to monitor such changes on your payment page. Pay attention, that for the distribution of our Services, we use such third-party providers as App Store and Google Play (as specified below) which may use their own payment providers. In case of processing your payment information by the payment provider, you should be governed by the privacy policy and the cookie policy of such payment provider.
- App Store (developed by Apple Inc.) – an app marketplace that helps us to distribute our games and apps. Privacy Policy of App Store: https://www.apple.com/legal/privacy/data/en/app-store/;
- Google Play (developed by Google LLC) – a digital distribution service that helps us to distribute our games and apps. Privacy Policy of Google: https://policies.google.com/privacy;
- Anti-fraud and credit check providers to keep us and you secure. You acknowledge that our anti-fraud and credit check providers may be changed from time to time;
- Providers that help us make the Website and/or Services available and functional (such as hosting services);
- Wix provided by Wix.com, Inc. This platform helps us to create new functions for our Website and develop them and our Services. Privacy Policy of Wix: https://www.wix.com/about/privacy;
- Providers that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information);
- Providers that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, event planning, marketing or operational services to us or our User;
- Providers that help us to show you relevant ads such as Applovin (privacy policy: https://www.applovin.com/privacy/), ironSource (privacy policy: https://www.is.com/privacy-policy/),
Unity Ads (privacy policy: https://unity.com/legal/privacy-policy), Facebook (privacy policy: https://www.facebook.com/privacy/policy/?entry_point=facebook_page_footer), Mintegral (privacy policy: https://www.mintegral.com/en/privacy), etc.; - Google Analytics provided by Google LLC. This tool uses collected information for the purpose of evaluating your use of the Website and compiling reports on your activity for us and third parties, who help operate and provide services related to the Website. Privacy Policy of Google: https://policies.google.com/privacy;
- Game Analytics provided by GameAnalytics Ltd. This tool that collects, visualize, and analyzes the data for making better games (Services). Privacy Policy of Game Analytics: https://gameanalytics.com/privacy/;
- Amplitude provided by Amplitude, Inc. This platform makes analytics for optimizing our Services for better engagement with the User. Privacy Policy of Amplitude: https://www.amplitude.com/privacy;
- Government authorities or third parties if it is required to do so by law, or in response to a court order.
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties.
RIGHTS OF THE USER
Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations and may differ in different regions.
If you are a resident of the European Economic Area (EEA) you have the next rights concerning your Personal Data which are specified in General Data Protection Regulation:
- the right to withdraw a previously given consent for Personal Data processing;
- the right to ask for the deletion of Personal Data;
- the right to obtain from the Company restriction of Personal Data processing;
- the right to receive Personal Data in a structured, commonly used, and machine-readable format and transmit it to another controller (the right for data portability);
- the right to obtain from the Company without undue delay the rectification of inaccurate Personal Data;
- the right to ask the Company for information about what Personal Data is being processed and the rationale for such processing;
- the right to get access to Personal Data that is being processed;
- the right to object to the processing of Personal Data;
- the right to object to a decision based on automated processing;
- the right to submit a complaint with a supervisory authority.
If you are a resident of California you have the next rights concerning your Personal Data which are specified in California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA) and Children’s Online Privacy Protection Act (COPPA):
- the right to knowthe categories of:
- collected Personal Data by the Company;
- sources of Personal Data;
- Personal Data that the Company has disclosed to third parties for a business purpose;
- sold Personal Data by the Company;
- third parties to whom Personal Data was sold;
- recipients to whom Personal Data was disclosed;
- the right to knowthe business or commercial purposes of Personal Data collection or selling;
- the right to know the specific pieces of collected Personal Data;
- the right to request deletion of collected Personal Data, subject to certain exceptions;
- the right to opt-out of Personal Data salesto third parties;
- the right to receive a notice of any actual or potential privacy breach with respect to your Personal Data;
- the right to be free of discrimination for exercising the aforementioned rights.
POLICY CONCERNING AGE
If you are a resident of the European Economic Area (EEA) please pay attention that we do not knowingly collect the Personal Data of children without verification of parental or official guardian consent where we are required to do so. Pay attention that in countries of the European Economic Area, the age before which it is necessary to obtain parental or official guardian consent for the collection of Personal Data is different, but cannot be lower than 13 years old.
If you are a resident of California, please pay attention that we do not knowingly collect Personal Data from anyone under the age of 13 without verification of parental or official guardian consent. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental or official guardian consent, we will take steps to remove that information from our servers.
THIRD-PARTY LINKS
Our Website may contain links to other websites that are operated by third parties and are not controlled by, or affiliated to, or associated with us, unless expressly specified otherwise by us. Therefore, the Company is not responsible for any privacy practices or policies of such third parties, nor do we control or guarantee the accuracy, integrity, or quality of the information, data, text, or other materials available on such websites. Please, review carefully the third-party’s policies and practices and make sure you understand them before you use such websites.
PERSONAL DATA SECURITY
The Company takes reasonable technical and organizational measures to safeguard personal data against unauthorized access, alteration, disclosure or destruction of your Personal Data, username, password, transaction information and data stored on our Website and/or Services. Unfortunately, no data transmission, software, or storage system can be guaranteed to be 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur.
If you have reason to believe that your Personal Data may no longer be secure and/or there is a Personal data breach, please notify us immediately.
PERSONAL DATA RETENTION
We will retain your Personal Data while we are using it, as described in our Privacy Policy. We may continue to retain your Personal Data after we have ceased such uses for certain legitimate business purposes. We may also continue to retain your Personal Data to meet our legal requirements or to defend or exercise our legal rights. Therefore, the length of time for which we will retain your Personal Data will depend on the purposes for which we need to retain it. After we no longer need to retain your Personal Data, it will be deleted or securely destroyed.
TRANSFER OF PERSONAL DATA
The collected Personal Data may be transferred to and maintained on computers located outside of your country, state, province, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Pay attention, that your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to such transfer of Personal Data.
Our Company will take all steps reasonably necessary to ensure that:
– your Personal Data is handled securely and in accordance with this Policy;
– your Personal Data is not transferred to an organization or country unless appropriate data security control is in place.
If the country to which the Company transfers Personal Data does not belong to the European Union and does not ensure adequate levels of protection, such transfer will be performed only after the Company and said subjects will conclude specific agreements, containing safeguard clauses and/or appropriate safeguards for the protection of your Personal Data will be carried.
GOVERNING LAW
This Privacy Policy is governed by the laws of the Republic of Cyprus, without respect to its conflict of laws principles. The User and the Company agree to submit to the non-exclusive jurisdiction of the courts of the Republic of Cyprus, to settle any dispute or claim that arises out of or in connection with this Privacy Policy and/or any other rules posted on our Website.
The User and the Company hereto will use their reasonable best efforts to resolve any dispute hereunder through good faith negotiations.
MODIFICATIONS
The Company reserves the right to change or modify this Privacy Policy at any time without prior notice to you. Please review our Privacy Policy before you provide any Personal Data periodically on an ongoing basis.
When we make changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy on our Website. Your continued use of our Website and/or Services after any changes or revisions to this Privacy Policy become effective will constitute a binding acceptance by you of this Privacy Policy or any subsequent modifications.
HOW TO CONTACT US?
If you have any questions about this Privacy Policy or would like to exercise any of your rights, please email us at support@bavovnagames.com.