The provision of our applications (hereinafter "App"), whether via websites or through various app stores, is brought to you by Zotobi Management Limited. (the "Data Controller" of your personal data). Consequently, "We", "Us" and "Ours" refers to the Data Controller.
We are based outside the European Economic Area and have nominated the following representative to promptly respond to any requests by our customers and relevant authorities via post (or just email us):
Name: Mr. D. Jibilian
Address: 226A West Hendon Broadway, NW9 7ED
London, United Kingdom
You may email Us with regards to queries of any nature (in particular, to exercise Your Rights) at firstname.lastname@example.org
There are different types of information we obtain, whether directly from you or automatically via your device when you use the App. Essentially, we only obtain what is strictly necessary to provide you with our services, no more, no less.
Information, relating to you or your device, is either identified automatically by Our systems, provided to Us by the operating system of your device or is input by you manually when filling out certain fields, authorizing certain actions in the Apps.
|Information you provide Us with:||Legal basis for processing|
|1. Email address when you log in to use the App as a registered user.||
Performance of the contract with you.
Unless you sign up via other means (SNS, see below), We could not provide you with our services as a logged in user other than through some means of unique identification. You may still access Our App as a guest and link your account later.
We may contact you for marketing purposes of similar products and/or services. It will be in Our legitimate interests to do so, but you will always have a chance to opt out of such marketing communications prior to any such communication.
We will store just enough information to honour your opt-out preference in the future.
2. Social Network information via the "OAuth" method for secure login (read more about OAuth by following the link https://oauth.net/
Essentially, this is information from your public profile (with, for instance, Facebook) that you can control at any stage.
Performance of the contract with you.
Same as above, We could not otherwise provide you with our services as a registered user.
3. Your name and avatar (an image of your choice to be shown when playing the App)
Your consent at the time of provision of the same. You can always change or replace your name and avatar within the App settings.
4. Your date of birth when you provide it to our support team to get some freebies.
Your consent to receive freebies on that special day each year. We do not store the year of your birth, only the DD.MM. so to minimize the extent of personal data We hold about you.
5. Messages and communication with support
Performance of contract to respond to your queries and provide customer support. We do not use this information for anything else (for instance, we do not build your profile or target you based on your communication with us or with other users of the App).
Strange, but that is it. The rest is the technical stuff that must be processed in order to provide you with our services.
|Information collected automatically or assigned by Us to you||Legal basis for processing|
1. The server that hosts the App may record requests your device makes to the server, the details on device and browser you use, your IP address, date and time of access, city and country, operating system, browser type, mobile network information.
Performance of the contract.
The App would not operate otherwise, you need this to connect to the Internet.
This data is used only for technical purposes - that is, to ensure the proper functioning and security of the App and to investigate possible security incidents.
2. Advertising identifiers provided by the operating system of your handheld device (such as, for instance, IDFA, GAID)
Your consent to the provision of such identifiers given by default through the operating system of your device (Apple or Android, for instance). You are free to withdraw your consent by resetting those identifiers or opting out of interest based advertising.
This may be done via the settings of your handset and/or your browser. We respect those choices you make through the settings of your device.
3. Various device identifiers, provided by the operating system (device ID or a vendor ID, for instance) or allocated by Us (your in-App ID, for instance)
Our legitimate interests in fraud prevention and potential unauthorized access from multiple devices/locations, ensuring the technical availability and security of the App.
4. App version, OS version information, browser type, language used, make/model of your device
Performance of the contract.
We need to know this technical information so the App functions properly on your device.
5. All the events that naturally occur during your usage of the App (such as logs, events, hands played, purchase history, crashes of the App, system reports and so on). Statistical information with regards to App usage.
Partly, performance of the contract and partly our legitimate interests in fraud prevention and potential unauthorized access, ensuring the technical availability and security of the App.
Analysis of statistical information helps us to optimize the App in future updates, such usage does not affect your rights and freedoms and does not disclose any personal data of yourself or your contacts.
We protect your data and do not treat your personal data in any way that would surprise you (unless We told you about it and you made an informed decision to consent to such usage).
For instance, We encrypt the password created by you at the sign up stage and then store your personal data on secure servers that would prevent unauthorized access or destruction of your personal data.
We use the advertising identifiers in strict compliance with the requirements of the operating systems (for otherwise We would be in breach of their usage terms). Thus, We only use those advertising identifiers to meet our contractual obligations towards the parties that brought you to Us and vice versa (whether by you clicking on an advertising banner in our partners' apps, watching the ad or otherwise).
Unless you have asked us not to, We may rarely contact you by email about similar products and services to the App. Whenever We contact you, We would always give you the right to opt out prior to the first communication and at any time thereafter (see the section "Your Rights" below).
The purposes for processing the data provided by you include:
Providing you with Our services
Improving our services
Notifying you of any changes in our services
Depending on the type, your personal data is stored either until you delete the App or after six months of inactivity. Some data (such as IP addresses or blacklisted email addresses used for fraud) may be held for longer in our legitimate interests to protect our business from losses and also to respect your choice of opt-outs from marketing emails.
We are required by law to delete any information that is no longer necessary to provide Service to you. We assume that if you have not used our App for over six months ("Period of Inactivity"), you have left us indefinitely. We will delete any Personal Data that we have in our possession following the Period of Inactivity. But do not worry, you are always welcome to use our App again if you decide to come back.
Your data is stored on one of the secure servers that we rent and We use the recommended industry practices to keep your data secure. We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.
We currently use Hetzner and Amazon (the " Hosting providers") to store your personal data. Those Hosting providers are in possession of various international security certificates that ensure safety of your data with them. You can read more on the security measures of Hosting providers by following the links:
https://www.hetzner.com/assets/Uploads/downloads/FOX-Zertifikat-en.pdf ISO 27001 certificate valid until October 2019
https://d1.awsstatic.com/certifications/iso_27001_global_certification.pdf ISO 27001 certificate valid until November 2019
both links last accessed on May 21,2018
Thus, having the appropriate security with the Hosting providers when storing your data, We have to ensure that access to such data is provided on a need-to-know basis. Access to the Hosting providers is controlled via various technical and organizational measures that include:
Two-factor authentication to access the Hosting providers;
Following the principle of least privilege;
All servers and services are subject to continuous monitoring. This includes the logging of personal access in the user interface.
Each employee has access to the systems/services only via his/her own employee access. The access rights involved are limited to the responsibilities of the respective employee and/or team.
We do not share your personal data with any third parties, except where We have to comply with Our legal obligation. Some of the data of our users is aggregated for statistical purposes and processed in the legitimate interests as stated in section 2 above.
This does not mean that We blindly follow disclosure orders. We will check each request to ensure it satisfies the relevant safeguards, contains a court order or is issued under a legislative measure for the prevention, investigation, detection or prosecution of criminal offences.
As stated above, We share your advertising identifiers with third parties to meet our contractual obligations and pay their dues or protect ourselves against claims for payment.
While your data may be accessed from different parts of the world on our behalf, We do not actually transfer your personal data outside the EEA. To any extent that data is accessed from abroad, We follow set contractual safeguards and protections to ensure that your data is as safe abroad as it is within the EEA.
Where a third party accesses your data on our behalf or upon our instructions (be it inside or outside the EEA), We use the relevant legal basis to comply with the data protection legislation. In cases where there is no finding of an adequacy decision by the European Commission, we use model contracts to safeguard your rights and data.
When you log in to use any of Our Apps via an SNS (such as Facebook) you provide Us with certain information from you profile for that site. The information provided via SNS varies and depends on a particular SNS (for instance, Facebook provides information on your name, age range, picture, gender, friends list and email address). You can untick the boxes for information you prefer not to share with us during the sign up process.
You can find out more about these settings at the SNS where you play Our App (for instance, you can edit the privacy and settings of your apps with Facebook by following the link https://www.facebook.com/help/218345114850283?helpref=about_content - last accessed on 21 May 2018).
You are entitled to the full spectrum of the rights under the General Data Protection Regulation and We will go out of our way to accommodate any valid request. You can either exercise your rights by deleting certain features through your device or by emailing us at email@example.com to exercise all the other rights.
You have a wide array of rights that we respect. Among those the right to:
Require access to your personal data;
Require rectification of your personal data;
Require erasure of your personal data;
Withdraw consent to processing of your personal data, where applicable;
Lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been breached
You may be required to provide certain proof of identify so that We do not disclose personal data to those that are not entitled to it.
If your personal data is erased at your request or in accordance with our data retention policy, We only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.
Please note, all requests should be emailed to Us at firstname.lastname@example.org or sent to us by post. Due to the sheer volume of messages, in-App customer support messages cannot be regarded as an effective method of notice to Us.
There is no consensus on how mobile application companies should interpret the DNT signals. For the purposes of the OPPA, We do not currently respond to DNT signals whether that signal has been received on a computer or a mobile device.
We never knowingly collect or solicit any information from anyone of 13 years and younger. The App and its content are not directed at nor made look to appeal to such persons. Parents or guardians that believe that We hold information about their children aged 13 and under may contact Us at email@example.com
We will only collect and use your data where We have a legal basis to do so;
We will always be transparent and tell you about how we use your information;
When We collect your data for a particular purpose, We will not use it for anything else without your consent, unless other legal basis applies;
We will not ask for more data than needed for the purposes of providing our services;
We will adhere to the data retention policies and ensure that your information is securely disposed of at the end of such retention period;
We will observe and respect Your rights (in section 8 above) by ensuring that queries relating to privacy issues are dealt with promptly and transparently;
We will keep our staff trained in privacy and security obligations;
We will ensure to have appropriate technological and organizational measures in place to protect your data regardless of where it is held;
We will also ensure that all of our data processors have appropriate security measures in place with contractual provisions requiring them to comply with Our commitment;
We will obtain your consent and ensure that suitable safeguards are in place before personal data is transferred to other countries.
Zotobi Management Limited
Attention: Data Protection
Isle of Man, IM1 2PT
Support Team: firstname.lastname@example.org