PRIVACY POLICY
Last Updated: April 14, 2023
This Privacy Policy describes the collection and processing of information about you that can directly or indirectly identify you (the “Personal Data”) carried out by the mobile applications (the “App”) provided by Gora Games ME FZ LLC (“we”, “us”, “our”).
Contact details of data controller:
Name: Smertrios Limited
Address: 42A Grigori Afxentiou Street, Egkomi 2407, Nicosia, Cyprus
E-mail: support@goragaming.com.
Please read this Privacy Policy carefully as it contains important information about the following:
· How do we collect your Personal Data?
· How do we process your Personal Data?
· When can we share your Personal Data?
· How long do we retain your Personal Data?
· Do we use automated decision-making or refer to the automated profiling?
· What rights do you have?
We may update this Privacy Policy from time-to-time to keep it in conformity with the relevant legislation, including the Regulation of the European Parliament and of the Council (EU) 2016/679 (the “GDPR”) and California Consumer Privacy Act 2018 (the “CCPA”). We will keep you informed about the changes to our Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your Personal Data, we will request your consent or your renewed consent (in case it was obtained previously).
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect Personal Data if you provide it to us or automatically by electronic means.
HOW DO WE PROCESS YOUR PERSONAL DATA?
We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing.
Categories of Personal Data that we process are specified below:
Purpose of the processing
Personal Data
Legal basis for the processing
to register your account in the App
· E-mail;
· general location data (determined by the built-in tool in the App);
· phone number;
· country, state, street, house, apartment, index (the “Address data”)
Terms and Conditions
* Without providing this data you will not be able to use some of the App’s features
to fill out an account in the App
· nickname;
· name, surname
Terms and Conditions
* Without providing this data you will not be able to use some of the App’s features
to ensure proper use of the App, including the ability to monitor and troubleshoot technical issued
· technical data such as IP address, device ID, general location data, device model, date and time of access (the “Technical Data”);
· usage experience, i.e. information about your use of the App (the “User Data”);
· account ID
Terms and Conditions
* Without providing this data you will not be able to use the App
to communicate with you (including technical support)
· E-mail; or
· phone number; or
· any other information that you have made public in the messengers or social networks you used to contact us at the time of contacting us (name, photo, etc.);
· account ID;
· information that you provide us when you contact us
Our legitimate interest in receiving communication from you and reacting to it and your interest in getting our response
to manage and optimize users’ experience by improving our knowledge of our users
· Technical Data;
· User Data;
· Google Advertising ID; or
· Apple ID for Advertisers
Our legitimate interest in evaluating and creating statistics on the use of the App and your interest in the App updates which will be tailored to your needs
to provide you with advertising, including that is relevant to your interests
· Technical Data;
· User Data;
· E-mail;
· phone number
Our legitimate interest based on the balance of interests while you have absolute right to object to direct marketing
WHEN CAN WE SHARE YOUR PERSONAL DATA?
We can share your Personal Data with third parties only in the cases listed below.
When we are required by law: We may disclose your Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies), in connection with any legal proceedings or prospective legal proceedings and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
With our partners who help us support the App:
We may have partners that help us to make the App better, including analytics, advertising and payment services which may process your Personal Data for purposes specified in section “HOW DO WE PROCESS YOUR PERSONAL DATA?” above respectively.
A list of third-party services used by App is below.
Payment services. We may provide paid features in our App. In that case, we may use third-party services for payment processing, as follows:
· Apple in-app purchase. Apple in-app purchase is world-class commerce and payment system provided by Apple, Inc. Address: One Apple Park Way, Cupertino, CA 95014, United States. Privacy Enquiries, Privacy Policy of Apple, Inc.
· Google in-app purchase. Google in-app purchase is payment system provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Google, Inc.
· Xsolla. Xsolla is payment system provided by Xsolla (USA), Inc. Address: 15260 Ventura Blvd., Suite 2230, Sherman Oaks, CA 91403 USA. Privacy Policy of Xsolla, Inc.
We do not process your payment data; such data is processed by the relevant payment provider.
Analytics services. We may use third-party service providers to monitor and analyze the use of our App, as follows:
· Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Google Inc.
· Google Firebase. Google Firebase is a mobile and web app development platform that offers several integrated features such as a mobile app server, analytics tools, app promotion and monetization tools provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Firebase.
· Google BigQuery. BigQuery is a cloud-based big data analytics web service for processing very large read-only data sets provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Google Cloud Privacy Notice.
· Amplitude. Amplitude is a service for analyzing user behavior on the web and mobile applications provided by Amplitude, Inc. Address: to the attention of Privacy, 631 Howard Street, Floor 5, San Francisco, CA 94105, USA. privacy@amplitude.com or ccpa@amplitude.com, Privacy Policy of Amplitude, Inc.
· Tableau. Tableau is a visual analytics platform transforming the way we use data to solve problems provided by Tableau Software, LLC. Adress: NorthEdge 1621 N 34th St. Seattle, WA 98103. privacy@salesforce.com or datasubjectrequest@salesforce.com, Privacy Policy of Tableau Software, LLC.
· Mixpanel. Mixpanel is a tool that allows us to analyze how users interact with your Internet-connected product provided by Mixpanel, Inc. Adress: One Front Street, 1 Front St #28th, San Francisco. compliance@mixpanel.com, Privacy Policy of Mixpanel, Inc.
· AppsFlyer. AppsFlyer is a mobile marketing analytics and attribution platform provided by AppsFlyer. Address: to the attention of Legal Team/Data Protection Officer, 14 Maskit St., Herzliya, Israel, 4673314. privacy@appsflyer.com, Privacy Policy of AppsFlyer.
Ads systems. We may use third-party service providers advertising purposes respectively, as follows:
· Facebook Ads. Facebook Ads Manager is a Facebook tool that allows to create and manage ads provided by Meta Platforms, Inc. Address: 1601 Willow Road, Menlo Park, CA 94025, USA. Privacy Policy of Meta.
· Google Ads. Google Ads is a contextual advertising service from Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Google, Inc.
· AppLovin. AppLovin is a technology platform enables developers to market, monetize, analyze, and publish their apps provided by AppLovin Corporation. Address: to the attention of Data Protection Officer, AppLovin Corporation, 1100 Page Mill Road, Palo Alto, CA 94304. dataprotection@applovin.com, Privacy Policy of AppLovin Corporation.
· Unity Ads. Unity Ads is the ad monetization solution for mobile games from Unity Technologies. Adress: San Francisco, 30 3rd Street, United States. DPO@unity3d.com, Privacy Policy of Unity Technologies.
· TIK TOK Ads. TIK TOK Ads is an advertising service. Transfer to the USA, the Russian Federation, the UAE, Indonesia, India based on the Jurisdiction Specific Terms and Controller to Controller Data Terms, Request privacy information.
Other partners. We also have partners to help us maintain the App:
· Zendesk, Inc. Zendesk, Inc. provides us a cloud-based helpdesk platform that supports us covering our App service or technical support of the App. Adress: 1019 Market Street, San Francisco, CA 94103, USA. euprivacy@zendesk.com, Privacy Policy of Zendesk, Inc.
· Digital Ocean, Inc. DigitalOcean, Inc. is a cloud hosting provider that offers cloud computing services and infrastructure as a service. Adress: 101 Avenue of the Americas (Grand St.) New York, NY 10013. United States. privacy@digitalocean.com, Privacy Policy of DigitalOcean, Inc.
PLEASE NOTE THAT SOME OF THESE COMPANIES MAY BE LOCATED OUTSIDE THE EU (INTERNATIONAL DATA TRANSFERS) INCLUDING IN THE COUNTRIES WHICH DO NOT ENSURE AN ADEQUATE LEVEL OF PROTECTION OF YOUR PERSONAL DATA. Where this is the case, we meet the strict conditions of Personal Data transfers from the member states of European Union to other countries by using the Standard Contractual Clauses (SCC) adopted by the European Commission to ensure that Personal Data are properly protected or relying on other derogations compliant with GDPR.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain your Personal Data for no longer than it is necessary to fulfill the purposes specified in the section “How do we process your Personal Data”. Except for any legal obligation that sets a longer data retention period, at the end of these periods, the Personal Data processed will be deleted or anonymized.
DO WE USE AUTOMATED DECISION-MAKING OR REFER TO THE AUTOMATED PROFILING?
We neither use automated decision-making nor refer to the automated profiling.
WHAT RIGHTS DO YOU HAVE?
Rights of EU residents:
(1) The right of access to your Personal Data meaning that you can receive a copy of the Personal Data that we hold about you, as well as other supplementary information.
(2) The right to rectification of your Personal Data which is incomplete or inaccurate.
(3) The right to erasure of your Personal Data meaning that you can ask us to delete or remove your Personal Data in certain circumstances. Note, that we can retain your Personal Data as necessary to comply with our legal obligations or resolve disputes. If we have no grounds to continue processing your Personal Data, we will delete or remove it and notify you about such deletion or removal.
(4) The right to restrict processing of your Personal Data if (a) the accuracy of the Personal Data is contested by you, (b) the processing is unlawful and you oppose the erasure of the Personal Data, (c) we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, and (d) you have objected to processing pending the verification whether the legitimate grounds override this.
(5) The right to data portability. The right to portability of your Personal Data, which applies only to information we have processed based on your consent or Terms and Conditions.
(6) The right to object to the processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to the processing on this ground. We will no longer process the Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
(7) Right to withdraw consent at any time where we are relying on the consent to process your Personal Data. If we have no other grounds for processing your Personal Data, after you send us a request to withdraw consent, we will stop processing your Personal Data that we were processing under your consent.
We will address your request as early as possible and no longer that within 1 month. Please note that this period may be extended by 2 further months where necessary, taking into account the complexity and number of the requests. In this case, we will inform you of the extension within 1 month of receipt of your request and will explain you the reasons for the delay.
Rights of California residents:
(1) The right to opt out. Under the CCPA each California resident can request business stops selling Personal Data to third parties.
Do we actually “sell” Personal Data? We do not, and will not, provide your Personal Data in direct exchange for money. Therefore, in the literal sense, we do not sell your Personal Data.
(2) Other rights. You also have a right to be informed about what categories of Personal Data we are collecting: you can request us to disclose what Personal Data we have collected in the past 12 months and right to get a free copy of your Personal Data disclosed in a readily usable and readable format. You can also request us to delete the Personal Data we have collected in the past 12 months. We will not discriminate against you for exercising any of your rights granted under CCPA.
Mandatory Verification: As required by CCPA we will need to verify your identity before processing your request. In order to verify your identity, you will be asked to log in to your account or (if you do not have an account) we will try to match the information you provided with the information we handle about you. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you have requested us to delete your Personal Data.
As required by CCPA we endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by e-mail.
How to exercise any of your rights? You may exercise your rights by sending a relevant request to the e-mail indicated in the contact details.
If you have any comments about how we process your Personal Data, please let us know and we will consider your claim. If you are not satisfied with our response to the complaint, you have the right to file a complaint with the competent authority.