PRIVACY POLICY OF CUE BILLIARD CLUB
Effective date: 6/28/2023
Obumo
Games ("us", "we", or "our") is an app
development studio that creates applications, websites, and other digital
properties (collectively “Properties”).
This page informs you
of our policies regarding the collection, use and disclosure of personal
data when you use our Properties, and the choices you have associated with
that data.
We use your data to provide and improve our
Properties. By using these, you agree to the collection and use of
information in accordance with this policy.
Definitions
Personal Data
Personal Data means data about a living individual who can be
identified from those data (or from those and other information either in
our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the
use of our Properties or from our technical infrastructure (for example,
the duration of game session or delivery of an advertisement).
Cookies
Cookies are small files stored on your device (computer or mobile
device).
Data Controller
Data
Controller means the natural or legal person or entity who (either alone
or jointly or in common with other persons) determines the purposes for
which and the manner in which any personal information are, or are to be,
processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal
person or entity who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process
your data more effectively and to operate our Properties.
Data Subject (or User)
Data Subject is any living individual who is using our Properties
and is the subject of Personal Data.
Information Collection
and Use
We collect several different types of information for various
purposes to provide and improve our Properties.
Types of Data
Collected
Personal and Usage Data
While using our Properties, we may ask you to provide us with
certain personally identifiable information that can be used to contact or
identify you ("Personal Data"). Personally identifiable
information may include, but is not limited to:
Email address
First
name and last name
Phone number
Address, State, Province,
ZIP/Postal code, City
Cookies and Usage Data
IP Address
We
may collect information that your device or browser sends us whenever you
visit or access our Properties, or when you interact with a Property
("Usage Data").
This data may include, but is not
limited to, information such as your computer's Internet Protocol
address (e.g. IP address), operating system version, browser type, browser
version, the Property you interact with, the pages that you visit, the
time and date of your visit to those pages or Properties, the time spent
on those pages or Properties, unique device identifiers, and other
diagnostic data. This data may also be combined and linked with data from
other sources, devices, and Properties that you use.
Cookies and Similar Tracking Technology Data
We use cookies and similar tracking technologies, including
statistical or other identification methods, to track the activity and to
provide our Properties to you.
Cookies are files with a small
amount of data which may include an anonymous unique identifier. Cookies
are sent to your browser from a website and stored on your device. Other
tracking technologies are also used such as device identifiers, beacons,
tags and scripts to collect and track information and to improve, analyze,
and deliver our Properties.
You can instruct your browser to
refuse all cookies or to indicate when a cookie is being sent. However, if
you do not accept cookies, you may not be able to use some portions of our
Properties.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Properties.
Preference Cookies. We use Preference Cookies to remember your preferences and various
settings.
Security Cookies. We use
Security Cookies for security purposes.
Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may
be relevant to you and your interests. Opting out of interest-based
advertising or changing the privacy settings in your browser may reduce
the relevancy of the ads you see, but not the number or frequency of ads.
To learn more and to opt out of interest-based advertising, as delivered
by partners of ours who participate in the following organizations, please
follow the instructions at:
Digital Advertising Alliance - http://optout.aboutads.info/?c=2&lang=EN
Network Advertising Initiative - http://www.networkadvertising.org
European Interactive Digital Advertising Alliance - http://www.youronlinechoices.eu/
Use of Data
We use the collected data for various
purposes:
To provide and maintain our Properties.
To
provide advertising, including but not limited to interest-based,
contextual, and cross-device or application ad targeting.
To notify
you about changes to our Properties.
To allow you to participate in
interactive features of our Properties when you choose to do so.
To
provide customer support.
To gather analysis or valuable information
so that we can improve our Properties.
To monitor the usage of our
Properties.
To detect, prevent and address technical, security, or
fraud issues.
Legal Basis for Processing Personal Data under
the General Data Protection Regulation (GDPR)
If you are from the
European Economic Area (EEA) or the United Kingdom, our legal basis for
collecting and using the personal information described in this Privacy
Policy depends on the Personal Data we collect and the specific context in
which we collect it.
We or one of our Service Providers may
collect and/or process your Personal Data because:
We need to
perform a contract with you.
You have given us, as a Data Controller
or Data Processor, consent in compliance with applicable laws to do so.
The
processing is in our legitimate interest, except where such interest is
overridden by your data protection interests or fundamental rights or
freedoms.
To comply with the law.
IAB Europe Transparency
& Consent Framework
We participate in the IAB Europe Transparency
& Consent Framework and comply with its Specifications and Policies.
We use the Consent Management Platform provided by Consent Desk LLC.
Retention
of Data
We will retain your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will retain
and use your Personal Data to the extent necessary to comply with our
legal obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes and enforce our legal
agreements and policies.
We will also retain Usage Data for
internal analysis purposes. Usage Data is generally retained for a shorter
period of time, except when this data is used to strengthen the security
or to improve the functionality of our Properties, or we are legally
obligated to retain this data for longer periods.
Transfer of
Data
Your information, including Personal Data, may be transferred to
- and maintained on - computers located outside of your state, province,
country or other governmental jurisdiction where the data protection laws
may differ from those of your jurisdiction.
If you are located
outside United States and choose to provide information to us, please note
that we transfer the data, including Personal Data, to the United States
and process it there.
Your consent to this Privacy Policy
followed by your submission of such information represents your agreement
to that transfer.
We will take all the steps reasonably
necessary to ensure that your data is treated securely and in accordance
with this Privacy Policy and no transfer of your Personal Data will take
place to an organization or a country unless there are adequate controls
in place including the security of your data and other personal
information.
Disclosure of Data
Business
Transaction
If we are involved in a merger, acquisition or asset
sale, your Personal Data may be transferred. We will provide notice before
your Personal Data is transferred and becomes subject to a different
Privacy Policy.
Disclosure for Law Enforcement
Under
certain circumstances, we may be required to disclose your Personal Data
if required to do so by law or in response to valid requests by public
authorities (e.g. a court or a government agency).
Legal
Requirements
We may disclose your Personal Data in the good faith
belief that such action is necessary to:
To comply with a
legal obligation.
To protect and defend our rights or property.
To
prevent or investigate possible wrongdoing in connection with our
Properties.
To protect the personal safety of users of our Properties
or the public.
To protect against legal liability.
Security
of Data
The security of your data is important to us but remember
that no method of transmission over the Internet or method of electronic
storage is 100% secure. While we strive to use commercially acceptable
means to protect your Personal Data, we cannot guarantee its absolute
security.
Your Rights under the California Consumer Privacy
Act (CCPA) and California Privacy Rights Act (CPRA)
If you are a
resident of California, you have the following rights:
Right to Know
and Access Information: You have the right to request that we disclose
what personal information we collect, use, disclose, and sell. To make
such a request, please contact us.
Right to Delete: You have the
right to request the deletion of your personal information. To make such a
request, please contact us.
Right to Opt-Out of Sale of Personal
Information: If we sell personal information, you have the right to
opt-out. If we do not sell personal information, we will state this
clearly. If applicable, a link titled "Do Not Sell My Personal
Information" will be provided on our website.
Right to
Non-Discrimination: We will not discriminate against you for exercising
any of your CCPA or CPRA rights.
Minors Under 16 Years of Age: If we
have actual knowledge that we collect or maintain the personal information
of minors under 16 years of age, we will provide specific protections.
For
more information on how to exercise these rights, please contact us.
Our
Policy on "Do Not Track" Signals under the California Online
Protection Act (CalOPPA)
We do not support Do Not Track
("DNT"). Do Not Track is a preference you can set in your web
browser to inform websites that you do not want to be tracked.
You
can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.
Your Rights under the Colorado
Privacy Act (CPA)
If you are a resident of Colorado, you have the
following rights under the CPA:
Right to Access, Correct, or Delete:
You have the right to access your personal data, to request that we
correct inaccurate personal data, and to delete your personal data under
certain circumstances. To exercise these rights, please contact us.
Right
to Data Portability: You have the right to receive your personal data in a
portable and readily usable format.
Right to Opt-Out: You have the
right to opt-out of the processing of your personal data for targeted
advertising purposes, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects concerning you.
Right to Non-Discrimination: We will not
discriminate against you for exercising any of your CPA rights.
Your
Rights Under the Virginia Consumer Data Protection Act (VCDPA)
If you
are a resident of Virginia, you have the following rights:
The right
to access the personal data we have collected about you during the past 12
months, including the categories of personal data; the categories of
sources; the business or commercial purpose; the categories of third
parties with whom we share personal data, and specific pieces of personal
data we have collected about you.
The right to delete personal data
we have collected from you, subject to certain exceptions in the VCDPA.
The
right to opt out of our sale or sharing of your personal data.
The
right to not be discriminated against for exercising any of your rights
under the VCDPA.
To exercise any of these rights, please contact us
using the contact details provided in this policy. We may ask you to
verify your identity before responding to your requests.
Your
Rights Under the Connecticut Data Privacy Act (CTDPA)
If you are a
resident of Connecticut:
You have the right to request the specific
pieces of personal data we have collected about you in the past 12 months,
including the categories of personal data, the sources from which the
personal data was collected, the purposes for collecting or selling the
personal data, and the third parties with whom we share personal data.
You
have the right to request deletion of your personal data.
You have
the right to opt out of the sale or sharing of your personal data.
You
will not be discriminated against for exercising your privacy rights under
the CTDPA.
To exercise any of these rights, please contact us using
the contact details provided in this policy. We may ask you to verify your
identity before responding to your requests.
Your Rights Under
the Utah Consumer Privacy Act (UCPA)
If you are a resident of
Utah:
You have the right to request access to the personal data we
have collected about you in the past 12 months, including the categories
of personal data, the sources of personal data, the business or commercial
purposes for collecting the personal data, the categories of third parties
with whom we share personal data, and specific pieces of personal data we
have collected about you.
You have the right to request deletion of
your personal data.
You have the right to opt out of the sale or
sharing of your personal data.
You will not be discriminated against
for exercising your privacy rights under the UCPA.
To exercise any of
these rights, please contact us using the contact details provided in this
policy. We may ask you to verify your identity before responding to your
requests.
Your Data Protection Rights under the General Data
Protection Regulation (GDPR)
If you are a resident of the European
Economic Area (EEA) or the United Kingdom, you have certain data
protection rights. We aim to take reasonable steps to allow you to
correct, amend, delete or limit the use of your Personal Data.
If
you wish to be informed about what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.
In
certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on
you. Whenever made possible, you can access, update or request deletion of
your Personal Data directly within your account settings section. If you
are unable to perform these actions yourself, please contact us to assist
you.
The right of rectification. You have
the right to have your information rectified if that information is
inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your
personal information.
The right to data portability. You have the right to be provided with a copy of the information we have
on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we
relied on your consent to process your personal information.
Please
note that we may ask you to verify your identity before responding to such
requests.
You have the right to complain to a Data Protection
Authority about our collection and use of your Personal Data. For more
information, please contact your local data protection authority in the
European Economic Area (EEA) or the United Kingdom.
The
Company participates in the IAB Europe Transparency & Consent
Framework and complies with its Specifications and Policies. We use the
Consent Management Platform with the identification number 291.
Service
Providers
We may employ third party companies and individuals to
facilitate the delivery and operations of our Properties ("Service
Providers"), provide the Properties on our behalf, process Personal
Data, perform Property -related services or assist us in analyzing how our
Properties are used.
We may provide these third parties with
access to your Personal Data only to perform these tasks on our behalf as
a Data Processor and are obligated not to disclose or use it for any other
purpose.
These third parties may also collect data directly
from you for their own use and subject to their own privacy policies.
Other
Sites and Digital Properties
Our Properties may contain links to
other sites that are not operated by us. If you click a third-party link,
you will be directed to that third party's site. We strongly advise
you to review the Privacy Policy of every site you visit.
We
have no control over and assume no responsibility for the content, privacy
policies or practices of any third-party sites or services.
Children's
Privacy
Our Properties do not address anyone under the age of 13
("Children") without verifiable parental consent in compliance
with the Children’s Online Privacy Protection Act (COPPA), and we do not
process personal data of children under 16 without consent from the holder
of parental responsibility in compliance with the General Data Protection
Regulation (GDPR) or other applicable laws.
Changes to This
Privacy Policy
We may update our Privacy Policy from time to time. We
will notify you of any changes by posting the new Privacy Policy on this
page.
We will let you know via email and/or a notice on our
Properties, prior to the change becoming effective and update the
"effective date" at the top of this Privacy Policy.
You
are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
If you have any questions about this
Privacy Policy, or if you wish to exercise your rights under the CCPA,
CPRA, CPA, CTDPA, GDPR, UCPA, VCDPA, or other applicable data protection
laws, please contact us:
By email: [email protected]
By mail:
Obumo Games
Fő utca 1.
1011
Budapest
Hungary
To comply with our obligations under EU
data protection legislation, we have appointed a Data Protection Officer
(DPO) who is contactable using the details provided above.
To
comply with our obligations under the CPA, we have appointed a Colorado
Privacy Act Contact who is contactable using the details provided above.