PRIVACY POLICY
Effective date: 11/8/2020
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.
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 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 18
("Children").
We do not knowingly collect personally
identifiable information from anyone under the age of 18. If you are a
parent or guardian and you are aware that your Child has provided us with
Personal Data, please contact us. If we become aware that we have
collected Personal Data from children without verification of parental
consent, we will take steps to remove that information from our
servers.
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, 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.