Privacy Policy
Last Updated: [ Jul 22nd ] 2022
Thank you for
using our products and services! We respect your concerns about privacy and
appreciate your trust and confidence in us.
Here is a
summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to
help you navigate the Privacy Policy and it is not a substitute for reading
everything! You can use the hyperlinks below to jump directly to particular
sections.
What information do we need to provide the Services?
If you register
an account to use the Service then we will need
some information from you to set this up. If you choose, you can provide certain other information to personalise
the gaming experience and enable Service features, or participate in the Service. If you choose to participate in a survey
regarding the Service, we will redirect you to our affiliate platform to take
the survey and will receive your aggregated survey data from that affiliate
once you complete the survey. More Information.
How will we use your information?
We use your information to provide the many
functions and services that comprise the Service. We also use your information for account
verification, security purposes and to improve the Service. We do not share your information with any third
parties, except where we need to in order to provide the Service (e.g., use
local cloud providers; use our affiliates around the world to help us to
deliver the Service) or monitor the success of our marketing and
advertising programs, or we are instructed to by a court, authority or
compelled by law. More Information.
Who do we share your information
with?
We use some third parties to help us
deliver the best possible experience (e.g., cloud services to back up your data and SDKs). When we use a third party, we only do this to process or store your information
for the purposes described in this Privacy Policy. We also have
affiliates around the world who help us deliver the Service or conduct surveys
in relation to the Service, and we may be required by a court or legal
obligation to disclose certain information in some circumstances. More Information.
Where do we process your
information?
Our servers are located in the United States, Brazil,
Germany and Singapore. Your information can be accessed from outside of where
you live by our support, engineering and other teams around the world,
including Singapore. More Information.
How long do we keep hold of your
information?
We generally retain your information for the period
during which you maintain an account for the Service, after which time your data is deleted (as further described in this Privacy Policy),
unless otherwise required by applicable laws. More Information.
How can I exercise my rights over
my information?
Depending on
where you are, you may have certain rights with respect to your information,
such as rights of access, to receive a copy of your data, or to delete your
data or restrict or object to our processing of your data. More Information.
If you have any
questions about anything in this Privacy Policy, or want to exercise any rights
you may have, please contact us here.
How will we notify you of
changes?
Changes to this Privacy Policy will be posted here.
Please check this page frequently to see if there are any updates or changes to
this Privacy Policy. More Information.
Data
Controller: Proxima Beta Pte. Limited. Email: dpo_contrareturns@proximabeta.com
EU Representative: Proxima Beta Europe B.V. | Email: dpo_contrareturns@proximabeta.com
UK Representative: Image Frame Investment (UK) Limited | Email: dpo_contrareturns@proximabeta.com
Serbia
Representative: Karanovic & Partners o.a.d. Beograd. Email: local.representative@karanovicpartners.com
Turkey Data
Controller Representative:
Özdağıstanli Ekici Avukatlık Ortaklığı. Email: proximabeta@iptech-legal.com (Özdağıstanli
Ekici Avukatlık Ortaklığı is our data controller representative and its
authority is limited to the authorities stipulated under the Law on Protection
of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not
authorised for any other matters such as Service conduct, bans, investigations,
civil or criminal complaints.
Welcome to Contra Returns!
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with
Contra Returns (the “Service”), and
sets out your choices and rights in relation to that information. Please read
it carefully – it is important for you to understand how we collect and use
your information, and how you can control it.
If you do not agree to the processing
of your personal information in the way this Privacy Policy describes, please do not provide your information
when requested and stop using the Service. By using the Service you
are acknowledging our rules regarding your personal information as described in
this Privacy Policy.
The Service is operated by Proxima Beta Pte. Limited.
For the
purpose of data protection laws, the data controller of your
personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”). The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07
International Plaza, Singapore.
Our representative in the EU for the purpose of EU data protection laws is Proxima
Beta Europe B.V., which is a Dutch company within our corporate group. The
registered address of Proxima Beta Europe B.V. is Gustav Mahlerplein 2, 1082 MA,
Amsterdam. Our representative in the EU can be contacted at dpo_contrareturns@proximabeta.com.
Our data
protection officer can be contacted at dpo_contrareturns@proximabeta.com.
Our representatives for data protection purposes in
certain jurisdictions are as follows:
Jurisdiction |
Representative |
Address |
Contact details |
EU |
Proxima Beta Europe B.V. |
Gustav
Mahlerplein 2, 1082 MA, Amsterdam, the
Netherlands |
|
UK |
Image Frame Investment
(UK) Limited |
Suite 1, 3rd Floor 11 -
12 St. James's Square, London, United Kingdom, SW1Y 4LB |
|
Serbia |
Karanovic
& Partners o.a.d. Beograd |
Resavska
23, Belgrade, 11000, Serbia |
local.representative@karanovicpartners.com |
Turkey |
Özdağıstanli Ekici Avukatlık
Ortaklığı. |
Varyap Meridian Grand Tower
ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey |
Please reach out to us if you have
any questions or concerns regarding the processing of your personal
information: you can contact us anytime at dpo_contrareturns@proximabeta.com.
This section describes the different types of
personal information we collect from you and how we collect it. If you would like to know more about
specific types of data and how we use that data, please see the section
entitled “How we use
your personal information” below.
The
following is a high-level summary of the types of personal information we use:
1. Information you provide to us
(either directly or through a third party).
2. Information about you generated as part of the Service
We automatically collect certain data from you when
you use the Service, namely:
·
Device information: CPU specifications, memory specifications, memory data, program running
logs and crash information.
·
User ID and open ID in order to allow the survey to be completed within the Service.
·
Game data: open ID, gameplay
statistics (geographic ranking based on your selected country location and
information regarding your use of the Service, such as gameplay statistics
(e.g. level, heroes, scores, and date and time stamp of actions) and your
device’s hardware information, which consists of user region (country,
province, city, carrier id, region, IP address) and device information (application
version, application id, battery information, WiFi strength, available space,
network type, OS version, OS name, carrier, country code, device language,
device resolution, brand, manufacturer, device model, RAM, ROM and CPU
information, GPU information, Game Frame information, mobile signal strength,
network round trip time, network bytes received/sent, login/pay step event information,
XWID).
·
Your text and audio chat data
(online only) when you communicate
with other users in the Service (please note that this feature is subject to
availability in your jurisdiction and only to certain users).
·
Customer support information: your interactions with our help services and FAQ, as well as
information relating to your error reports.
Children must not use the Service for any purpose, except where their
parent or guardian has provided consent (to the extent this option is available
in your jurisdiction).
By children, we mean users under the age of 18 years old; or in the case
of a country where the minimum age for processing personal information differs,
such different age. For users located in certain countries we have listed the
relevant minimum age in the table below.
Country in which the user is located |
Minimum age of the user |
Algeria |
19 |
Argentina |
18 |
Australia |
18 |
Bangladesh
|
18 |
Brazil |
18 |
Colombia
|
18 |
Canada |
13 |
Egypt |
18 |
European
Economic Area/ Switzerland |
16 |
Kingdom
of Saudi Arabia |
18 |
Kuwait |
21 |
Mexico |
18 |
Morocco |
18 |
New
Zealand |
16 |
Qatar |
18 |
Russia |
14 |
South
Africa |
18 |
Tunisia |
18 |
Turkey |
18 |
United
Arab Emirates |
21 |
United
Kingdom |
13 |
United
States |
13 |
We do not knowingly collect personal information from children under
these ages for any purpose. If you believe that we have personal information of
a child under these ages without parental/guardian consent, or if you are the
parent or guardian of the user and wish to withdraw consent, please contact us
at dpo_contrareturns@proximabeta.com and we will delete
such information.
This section
provides more detail on the types of personal information we collect from you,
and why. For users who live in the EEA, Switzerland, UK, Brazil or
Turkey (each a “Relevant Jurisdiction”),
it also identifies the legal basis under which we process your data.
Personal Information |
Use |
Legal
Basis ( only relevant if you are located in a
Relevant Jurisdiction) |
Information you provide to
us (either directly or through a third party). |
||
Account registration
information: ·
Guest login: Open ID ·
Facebook account login: Facebook username, email address, user ID and IP address ·
Google Play account login: username, email address, user ID, nicknames, profile picture, user
token and open ID. ·
Apple account login: Apple nickname, Apple ID, profile picture, user token and open ID. |
We use this information to create your account for the Service in accordance
with your request. |
Necessary to perform our contract with you to provide the Service. |
Account verification
information: OpenID, amount charged and bill number in relation to
credit card account verification (if this is available in your jurisdiction). |
If you are a minor, we will process this
information to verify your account (credit card verification) during the
sign-up process and to obtain your parent’s or legal guardian’s consent to your use of the Service. |
It is in our legitimate interest to ensure you have obtained your
parent or legal guardian’s consent prior to using the Service if you are a
minor. |
Friend Information: ·
Creating custom account
friend lists: user ID, token and
username ·
Facebook friends list: your friend’s Facebook open ID, nickname and profile picture |
We use this information to enable you to connect and play with other
users, in accordance with your request. |
Necessary to perform our contract with you to provide the Service. |
Survey information: age, gender, email, address, geographic (country) location, game
information (game habits and preferences, e.g. recently played games, game
duration and favourite game categories and experience, social media
preference, language preference) and any other content you choose to provide
as part of the survey response. |
We use this information to better understand our users and to improve
the Service. |
We collect this information with your consent. |
Information generated as
part of the Service |
||
Payment information: ·
Identity information: open ID, role ID, country ·
Device information: screen resolution, client exports IP, CPU model, Android ID, remaining
memory, remaining external SD card space, screen orientation, device model ·
Other information: country currency, SDK version, application version, IP address, network
Type, buried data reporting, network monitoring data |
We use this information
to facilitate your in-app purchases made via the Google Play Store or Apple
App Store. |
Necessary to perform our
contract with you to provide the Service. |
Crash information: device information (device
name, device model, phone memory, CPU usage rate, CPU model, device system
version, device brand, device manufacturer, ROM, RAM, device language, CPU
architecture, whether root, remaining external SD card space, remaining
memory, whether it is running in the simulator, running process information, APN,
system time, battery status) and other technical information (process name, network
type, application version, application package name, SDK version, SDK
information / user information / application information, buried data
reporting) and XWID, IDFV(iOS). |
We use this information
to locate and resolve crash issues. |
It is in our legitimate
interests to use this information to ensure the security and integrity of the Service. |
Advertising Information (collected via and shared with Appsflyer, a
third party SDK): ·
Technical information: technical information related to your mobile device or computer,
such as browser type, device type and model, CPU, system language, memory, OS
version, Wi-Fi status, time stamp and zone, device motion parameters and
carrier. ·
Technical identifiers: various unique identifiers that generally identify your computer,
device, browser or application, for example, IP address (which may also
provide general location information), user agent, Android ID, Google
advertising ID, IDFA, your user ID issued by us and other similar unique
identifiers. ·
Engagement information: your interactions with our advertisement campaigns, such as: your clicks
on our ads, ad impressions viewed, audiences or segments to which an ad
campaign is attributed, the type of ads and Service from which such ads were
displayed, the webpages that you visit from our Service, the URL from the
referring app, downloads and installations of the Service and other
interactions, events and actions we measure and analyse within the Service
(e.g. add to cart, in-app purchases made, clicks, engagement time etc.). |
We use this information
to monitor the success of our marketing campaigns and to monitor marketing
conversion rates. |
It is in our legitimate
interests to use this information to monitor your use of the Service and
views, clicks and engagement with the advertisements displayed in the Service. |
Device information: CPU specifications,
memory specifications, memory data, program running logs and crash
information. |
We use this information
for security purposes and to provide the Service. |
It is in our legitimate
interest to ensure the security and integrity of our Service. |
User ID and Open ID |
We use this information
to allow you to complete the survey (if you wish to participate) in-app. |
We collect this
information with your consent. |
Game data:
|
We use this information
to: ·
to improve the Service and its functionality; ·
maintain a record of log-in and actions of your account; ·
for security and verification purposes; ·
for general/overall game analytics (not confined to error-fixing or
debugging); and ·
to provide you with feedback and information about your gameplay and
progress. |
Open ID, gameplay
statistics and device’s hardware information (excluding XWID): Necessary to
perform our contract with you to provide the Service. XWID: It is in our
legitimate interests to conduct app analytics and to ensure the smooth operation
of the Service. |
Text and audio chat data (online only)*: Free text chat (users can communicate using their own, custom
messages) and audio chat (users can communicate using their microphone, if
they wish). These are only stored
locally on your device, and are not processed by our servers. *Subject to this
feature’s availability in your jurisdiction and to certain users. |
We facilitate the posting
of your text chat communications with
other users and to facilitate your audio communications with other users. |
Necessary to perform our
contract with you to provide the Service. |
XWID: Your XWID, which is
generated by us. |
We us this information to
perform general/overall game analytics (not confined to error fixing or
debugging), and to enable you to use the Service as a guest user. |
It is in our legitimate
interest to conduct app analytics and to enable you to use the Service as a
guest if you wish to. |
|
We use this information
to improve the Service. |
It is in our legitimate
interest to improve the quality of the customer service and FAQs provided via
the Service. |
Security related information: the list of hack or cheating software on your device, in-game screen
information, device operation system settings, device information including
mobile phone brand, model, CPU structure, CPU model, kernel version,
resolution, application package of hack software; and available memory,
information about your internet connection including WiFi name of the WiFi
access point (if applicable) and a list of installed APK and running apps. |
We use this information for
anti-cheating purposes, including to detect and observe cheating behaviours
and monitor the presence and operation of suspected cheating activity and domain
name hijacking. |
It is in our legitimate
interest to ensure the security of our Service and to maintain a fair gaming
environment. |
Notification Information:
|
We use this information
to send you in-game notifications and to send you email notifications. |
Necessary to perform our
contract with you to provide the Service. |
Compliance Information: open ID, token, IP
address, username and email address. |
We use this information |
It is in our legitimate
interest to ensure you are delivered the appropriate version of the Service
and for your data to be stored into the relevant country server. |
Analytics and profiling data (collected via and shared with Firebase,
a third party SDK): number of users and
sessions, session duration, operating systems, device model, geography, first
launches, app opens, app updates, in-app purchases and Google advertising ID
and IDFA (we do not store Google advertising ID or IDFA on our servers). |
We use this information
to monitor the success of our marketing campaigns and to monitor marketing
conversion rates. |
It is in our legitimate
interest to use this information to monitor your use of the Service and
views, clicks and engagement with the advertisements displayed in the Service. |
Statistical Reporting information: data reporting information based on your use of the Service (event_name,
stage_number, stage_name, stage_status, stage_error_code, extra_json,
stage_time) |
We use this information
to perform data analytics and to report on key statistics from your logins.
This allows to understand the success rate of the Service. |
It is in our legitimate
interest to use this information to monitor your use of the Service and
conduct app analytics in order to improve the Service. |
SDK information: errorcode
, error message, sdk name , sdk version, request url , response body, seq_id,
stage, log information |
We use this information
to perform data analytics to understand the performance and operation of our
SDKs within the Service. |
It is in our legitimate
interest to use this information to monitor your use of the Service and
conduct app analytics in order to improve the Service. |
Account
Deletion information (H5): email address, region, open ID, user token |
We use
this information to allow you to delete your account upon your request. |
Necessary
to perform our contract with you to delete your account upon your request. |
Our corporate group operates around
the world. Pursuant to our contract
with you to provide you with the Service, your personal information will be
processed on our servers that may not be located where you live. No matter
where our servers are located, we take appropriate measures to safeguard your
rights in accordance with this Privacy Policy. Our servers for the Service are located in:
In addition, your information can
be accessed from outside of where you live by our support, engineering and
other teams around the world, including Singapore.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
We are committed to maintaining the
privacy and integrity of your personal information no matter where it is
stored. We have information security and access policies that limit access to
our systems and technology, and we protect data through the use of
technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not
completely secure. Although we will implement and maintain reasonable measures
to protect your personal information, we cannot guarantee the security of the
information transmitted through the Service or otherwise via the Internet; any
transmission is at your own risk.
Where we use service providers who might have access
to your personal information, we require them to have privacy and security
standards that are comparable to ours. We use contracts and other measures with
our service providers to maintain the confidentiality and security of your
personal information and to prevent it from being used for any purpose other
than as provided in this Privacy Policy.
We do not keep your data for longer than is necessary unless we are
required to do so under law. For further details on how long we keep your data,
please refer to the time periods set out below.
Personal Information |
Retention Policy |
Account registration
information Friend information Payment information Crash information Advertising information Device information Game data Customer support
information (FAQ information) Security related
information Notification information Compliance information Analytics and profiling
data (Firebase) (except Google advertising ID and IDFA) User ID and Open ID |
Stored for the lifetime
of your use of the Service. Data will be deleted manually upon your request
within 30 days from receipt of the request, unless you are located in Brazil,
in which case your data will be deleted manually within 15 days
from receipt of the request. |
Account verification
information XWID Customer support
information (error reporting information) Statistical Reporting
information SDK information |
Stored for the lifetime
of your use of the Service unless you request to delete your Service account
or such data, in which case, the data will be deleted within 30 days upon
your request (unless you are located in Brazil, in which case your data will
be deleted manually within 15 days from receipt of the request). Where you do not request for account deletion, your data will be
retained for 1 year after the Service is shut down, before it is deleted. |
Text and Audio Chat data
(online only) |
Stored locally on your
device. This is not stored on our servers. |
Survey Information |
Stored
for a year from collection, after which it will be deleted. |
Account deletion information (H5) |
Stored
for a cool-down period of 30 days, after which it will be deleted
immediately. |
If we are required to retain your information beyond
the retention periods set out above, for example to comply with applicable
laws, we will store it separately from other types of personal information.
Some jurisdictions’ laws grant specific rights to
users of the Service, which are set out in this section.
This section entitled “Your Rights”
applies to users that are located in a Relevant Jurisdiction. If you are
located in a territory outside a Relevant Jurisdiction, please refer to the
Supplemental Jurisdiction-Specific Terms for an overview of your rights and how
these can be exercised.
The sub-sections entitled “Access”, “Correction”, and
“Erasure” also apply to users that are located in Canada, Argentina and Russia.
You have certain rights in
relation to the personal information we hold about you, depending on where you
are located. Some of these only apply in certain circumstances (as set out in
more detail below). We must respond to a request by you to exercise those
rights without undue delay and at least within one month (though this may be
extended by a further two months in certain circumstances). To exercise any of
your rights, please contact us at dpo_contrareturns@proximabeta.com.
Access
You have the right to access
personal information we hold about you, how we use it, and who we share it
with. You can access the personal information you have made available as part
of your account by logging into your account. If you believe we hold any other
personal information about you, please contact us at dpo_contrareturns@proximabeta.com.
Portability
You have the
right to receive a copy of certain personal information we process about you.
This comprises any personal information we process on the basis of your consent
(e.g., survey information) or pursuant to our contract with you (e.g., account
name), as described above in the section “How We Use Your Personal Information”. You have
the right to receive this information in a structured, commonly used and
machine-readable format. You also have the right to request that we transfer
that personal information to another party, with certain exceptions. We will provide further information to
you about this if you make such a request.
If you wish for us to transfer such personal information to a third party,
please ensure you detail that party in your request. Note that we can only do
so where it is technically feasible. Please note that we may not be able to
provide you with personal information if providing it would interfere with
another’s rights (for example, where providing the personal information we hold
about you would reveal information about another person or our trade secrets or
intellectual property).
Correction
You have the right to correct any of your personal
information we hold that is inaccurate. You can access the personal information
we hold about you by logging into your Service account. If you believe we hold
any other personal information about you and that information is inaccurate,
please contact us at dpo_contrareturns@proximabeta.com.
Erasure
You
can delete your account, or remove certain personal information, by logging
into your Service account. If there is any
other personal information you believe we process that you would like us to
erase, please contact us at dpo_contrareturns@proximabeta.com.
We may need to retain personal
information if there are valid grounds under data protection laws for us to do
so (for example, for the defence of legal claims or freedom of expression) but
we will let you know if that is the case. Where you have requested that we
erase personal information that has been made available publicly on the Service
and there are grounds for erasure, we will use reasonable steps to try to tell
others that are displaying the personal information or providing links to the
personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us
to stop processing the personal information we hold about you other than for
storage purposes in certain circumstances. Please note, however, that if we stop
processing the personal information, we may use it again if there are valid
grounds under data protection laws for us to do so (for example, for the
defence of legal claims or for another’s protection). As above, where we agree
to stop processing the personal information, we will try to tell any third
party to whom we have disclosed the relevant personal information so that they
can stop processing it too.
Objection
You have the right to object to our processing of your
personal information. We will consider your request in other circumstances as
detailed below by contacting us at dpo_contrareturns@proximabeta.com.
To the extent
provided by applicable laws and regulations, you may withdraw any consent you
previously provided to us for certain processing activities by contacting us at
dpo_contrareturns@proximabeta.com. Where consent is required to
process your personal information, if you do not consent to the processing or
if you withdraw your consent we may not be able to deliver the expected service.
Announcements
We may from time to time
send you announcements when we consider it necessary to do so (for example,
when we temporarily suspend access to the Service for maintenance, or security,
privacy or administrative-related communications). You may not opt-out of these
service-related announcements, which are not promotional in nature.
Questions, comments and requests regarding this Privacy Policy are
welcomed and should be addressed to dpo_contrareturns@proximabeta.com.
In the event that you wish to make a complaint
about how we process your personal information, please contact us in the first
instance at dpo_contrareturns@proximabeta.com and we will endeavour to deal with your request as soon as possible.
This is without prejudice to your right to launch a claim with the data
protection authority in the country in which you live or work where you think
we have infringed data protection laws.
If we make any changes to this Privacy Policy we will post the updated
Privacy Policy here. Please check this page frequently to see if there are any
updates or changes to this Privacy Policy.
Except as otherwise prescribed by law, in the event of any discrepancy
or inconsistency between the English version and local language version of this
privacy policy, the English version shall prevail.
Some jurisdictions’ laws contain additional terms for users of the
Service, which are set out in this section.
If you are a user located in one of the jurisdictions below, the
terms set out below under the name of your jurisdiction apply to you in
addition to the terms set out in our Privacy Policy above.
Algeria
By using this Service, you give us your
consent for the collection, storage, treatment and use of your personal
information, and transfer of your personal information to a third party (local
cloud providers to back up your data or our affiliates around the world to help
us deliver the Service) located in Brazil, Germany, Singapore and the United
States (as described in the Privacy Policy)
where it is manually and electronically treated.
Argentina
Your rights
If you are dissatisfied with our response to your request for access to,
correction, or erasure of your personal information or your privacy complaint
in respect of your personal information, you may contact the Agency for Access
to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de
Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar).
Data transfers
While we take reasonable
steps to ensure that third party recipients of your personal information comply
with privacy laws that are similar to those of your jurisdiction, by providing us your personal information
and by using the Service, you consent to the transfer of your personal
information to a jurisdiction where privacy laws may not offer the same level
of protection as the laws that may apply in Argentina.
Australia
Overseas
Recipients
We take reasonable steps to
ensure that third party recipients of your personal information located outside
Australia handle your personal information in a manner that is consistent with
Australian privacy laws. However, you acknowledge that we do not control, or
accept liability for, the acts and omissions of these third party recipients.
Access
You have the right to access
personal information we hold about you, how we use it, and who we share it
with. You can access the personal information you have made available as part
of your account by logging into your account. If you believe we hold any other
personal information about you, please contact us at dpo_contrareturns@proximabeta.commailto:dpo@thenextstudio.net.
Correction
You have the
right to correct any of your personal information we hold that is inaccurate.
You can access the personal information we hold about you by logging into your
Service account. If you believe we hold any other personal information about
you and that information is inaccurate, please contact us at dpo_contrareturns@proximabeta.com.
Children
If you are under the age of
18, you undertake that you have the consent of your parent or legal guardian to
register an account on and use the Service.
Transacting
Anonymously
Where practicable, we will
give you the option of not identifying yourself or using a pseudonym when
registering an account on or using the Service. You acknowledge that if you do
not provide us with your personal information, we may be unable to provide you
with access to certain features or sections of the Service, including social
media integration and In-Service purchases.
Your Rights
If you are dissatisfied with
our response to your request for access to, or correction of, your personal
information or your privacy complaint in respect of your personal information,
you may contact the Office of the Australian Information Commissioner (Telephone:
+61 1300 363 992 or email: enquiries@oaic.gov.au).
Data Transfers
While we take reasonable
steps to ensure that third party recipients of your personal information comply
with privacy laws that are similar to those of your jurisdiction, you
acknowledge and agree that we cannot control the actions of third party recipients
and so cannot guarantee that they will comply with those privacy laws.
Brazil
This section applies to users located in Brazil:
Language
This
Privacy Policy is provided in Portuguese for users located in Brazil. In case
of dispute, the Portuguese version of this Privacy Policy shall prevail.
Consent
Revocation
Whenever
we use your personal information based on your consent, you may revoke the
consent that you have previously given for the collection, use and disclosure
of your personal information, subject to contractual or legal limitations. To
revoke such consent, you may terminate your account or you can contact dpo_contrareturns@proximabeta.com. This may affect our provision of the Service to you.
Parental and Guardian Consent
If
you are under the age of 18, you should not use the Service for any purpose
without first obtaining parental/guardian agreement to this Privacy Policy
(both for themselves and on your behalf). We do not knowingly collect personal
information from any children under the age of 18 without such consent. Please
contact our Data Protection Officer if you believe we have any personal
information from any children under the age of 18 without such
parental/guardian consent – we will promptly investigate (and remove) such
personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU
AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION,
INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY
POLICY.
California
This section applies to California residents covered by the California
Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal Information
Over the past 12 months, we have
collected and disclosed the following categories of personal information from
or about you or your device:
We collect
your personal information for the following purposes:
For additional information
about what each type of personal information is used for, see this chart in the main
portion of the Privacy
Policy.
We disclose
personal information to the following types of entities:
In the past 12 months, we have not sold
Personal Information of California residents within the meaning of “sold” in
the CCPA.
Rights under the CCPA:
If you are a California resident, you have the right to:
We aim to fulfil all verified requests within 45
days pursuant to the CCPA. If necessary, extensions for an additional 45 days
will be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log
into your account and manage your data from there. If you are a California
resident to whom the CCPA applies, you may also exercise your rights, if any,
regarding other data by contacting us at dpo_contrareturns@proximabeta.com.
Canada
If you are located in Canada and wish to obtain written
information about our policies and practices with respect to our service
providers located outside Canada, you may contact us at dpo_contrareturns@proximabeta.com. Our privacy experts who monitor this email address are
also able to answer any questions users may have about the collection, use,
disclosure or storage of personal information by our service providers.
Where
we use service providers who might have access to your personal information, we
require them to have privacy and security standards that are comparable to
ours. We use contracts and other measures with our service providers to
maintain the confidentiality and security of your personal information and to
prevent it from being used for any purpose other than as provided in this Privacy
Policy.
Colombia
Language
This
Privacy Policy is provided in Spanish for users located in Colombia. In case of
dispute, the Spanish version of this Privacy Policy shall prevail.
How We Use Your Personal Information
From the entry
into force of this Privacy Policy, at the time of the collection of your
personal data, we will request your prior authorization, by informing you about
the specific purposes of the processing of your personal data for which such
consent is obtained under the Privacy Policy.
Your authorization
may be expressed (i) by writing, (ii) orally or (iii) through unequivocal
conducts that allow us to reasonably conclude that your authorization was
granted, such as the act of accepting the Privacy Policy. We may keep evidence
of said authorizations, while respecting the principles of confidentiality and
privacy of information.
Your Rights
As a data
subject you have certain rights, including (i) to access, update and rectify
your personal data; (ii) to request a copy of the consent you have given us;
(iii) to be informed about how we have processed your personal data; (iv) to
file claims before your country’s data protection authority; (v) to revoke the
consent you have given us to process your personal data, unless the processing
is based on compelling legitimate grounds or is needed for legal reasons; (vi)
to ask for the suppression of your personal data (right to erasure); and (vii)
to freely access your information.
You can
contact us if you want to exercise any of these rights through our contact
information in the section ‘Contact & Complaints’ of this Privacy Policy.
Proceedings For The Exercise Of Your Rights
Queries
(rights to access): You can file queries regarding the processing of your
personal data by us. Queries will be attended to within a maximum term of ten
(10) business days from the date of receipt. When it is not possible to attend
the query within the said term, you will be informed of the reasons for the delay
and we will indicate the date on which the consultation will be attended to,
which may, in no case, exceed five (5) business days following the expiration
of the first term.
Claims
(right to correction and erasure): You have the right to file claims in relation
to the processing of your personal data by clearly describing the facts that
give rise to your claim. The term to attend to the claim will be fifteen (15)
business days from the date of receipt. When it is not possible to attend to
the claim within the said term, you will be informed of the reasons for the
delay and the date on which the claim will be handled, which may, in no case,
exceed eight (8) business days following the expiration of the first term.
Egypt
This Privacy
Policy is provided in Arabic for users located in Egypt. In case of dispute,
the Arabic version of this Privacy Policy shall prevail.
By clicking
“accept” or by proceeding with the sign up process, you acknowledge that you
have read, understood, and consented to this Privacy Policy. If you do not
consent to this Privacy Policy, you must not use the Service.
You are
acknowledging your consent to the processing, storage, and cross-border
transfer of your personal data. The cross border transfer may be to any country
in which we have databases or affiliates, in particular United States, Brazil, Germany
and Singapore.
If you are a
new user, you have seven days to inform us of any objection you may have to
this Privacy Policy.
As an Egyptian data subject, you have certain
rights under the Egyptian Personal Data Protection Law.
France
Your Rights
Instructions
for the processing of your personal data after your death
You have the right to provide us with general or specific instructions for the retention,
deletion, and communication of your personal data after your death.
The specific instructions are only valid for the processing activities
mentioned therein and the processing of these instructions is subject to your
specific consent.
You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your
instructions. This person will be informed of your instructions in the event of
your death, and be entitled to request their implementation from us. In the
absence of designation or, unless otherwise provided for, in the event of the
death of the designated person, their heirs will have the right to be informed
of your instructions and to request their implementation from us.
When you
wish to make such instructions, please contact us at dpo_contrareturns@proximabeta.com.
Kingdom of Saudi Arabia
You consent to
the collection, use, disclosure, export and storage of your personal
information as described in this Privacy Policy.
Kuwait
You represent that you are at least 21 years old, or
18 years old and have obtained parental/guardian consent and, therefore,
legally capable of contracting under the applicable laws and regulations in
Kuwait.
By accepting this Privacy Policy, you
expressly state that you authorise us to collect, use, store, and process your
personal data and to disclose this data to third parties whether inside or
outside of Kuwait, in line with the provisions of this Privacy Policy.
Mexico
Language
This Privacy Policy is
provided in Spanish for users located in Mexico. In case of dispute, the
Spanish version of this Privacy Policy shall prevail.
Age Restrictions
You won’t be able to use
the Service unless you are 18 years old or you have obtained parental/guardian
agreement to this Privacy Policy (both for themselves and on your behalf).
Types of Personal Information We Use
For clarification purposes,
in section 1 "The types of personal information we use” and section 2 “How
we use your personal information” you can find full details about the personal
data we use. Therefore, we are providing you with complete information about
the personal data we use, in terms of the Federal Law on Protection of Personal
Data held by Private Parties and other applicable regulations.
Purposes of Processing
Some of the purposes of
processing stated above are for voluntary purposes, including to show you
personalised recommendations and advertising. You may object the processing of
your personal data for voluntary purposes as stated in the section “Your
Rights” below.
Please, be informed that we
may also use your personal data to comply with legal obligations or requests
from competent authorities, assert or defend our rights before the competent
authorities / courts, respond to requests you send us in relation to your
personal data and to carry out the transfer of personal data detailed in
section 3 “How we store and share your personal information”.
Data Transfer Consent
In general, we do not
require your consent to carry out the transfers detailed in section 3 “How we
store and share your personal information”. However, we require your consent to
transfer your personal data to a third party that acquires all or substantially
all of us or our business.
By using the Service and
providing us with your personal data, you agree to the data transfers detailed
above that require your consent. You may exercise your rights in connection
with your personal data as stated in the section “Your Rights” below.
Your Rights
The sub-sections entitled
“Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to
Storage Only “, which includes the limitation to the use and disclosure of your
personal data included in Section “Your Rights” above also apply to users that
are located in Mexico.
You also have the right to
revoke the consent that you have provided us to process your personal data.
To exercise any of your
rights, contact our Data Protection Officer at dpo_contrareturns@proximabeta.com.
To know more about your
rights, as well as the applicable means, procedures and requirements to
exercise any of your rights, please contact our Data Protection Officer at dpo_contrareturns@proximabeta.com.
Morocco
The protection of your privacy is an important principle for us. We
collect information for purposes strictly necessary for the proper use of the Service.
By accepting these conditions of use, you explicitly accept that your
personal data may be subject to processing by the Service.
Kindly note:
New
Zealand
This section applies to users located in New Zealand:
Overseas Recipients
We take reasonable steps to ensure that third party
recipients of your personal information located outside New Zealand handle your
personal information in a manner that is consistent with New Zealand privacy
laws. However, you acknowledge that we do not control, or accept liability for,
the acts and omissions of these third party recipients.
Access
You have the right to access personal information we
hold about you, how we use it, and who we share it with. You can access the
personal information you have made available as part of your account by logging
into your account. If you believe we hold any other personal information about
you, please contact us at dpo_contrareturns@proximabeta.com.
Correction
You have the right to request the correction of any of
your personal information we hold that is inaccurate. You can access the
personal information we hold about you by logging into your account. If you
believe we hold any other personal information about you and that information
is inaccurate, please contact us at dpo_contrareturns@proximabeta.com.
Children
If you are under the age of 16, you undertake that you
have the consent of your parent or legal guardian to register an account on and
use the Service.
Your Rights
If you are dissatisfied with our response to your
request for access to, or correction of, your personal information or your
privacy complaint in respect of your personal information, you may contact the
Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).
Data Transfers
While we take reasonable steps to ensure that third
party recipients of your personal information comply with privacy laws that are
similar to those of your jurisdiction, you acknowledge and agree that we cannot
control the actions of third party recipients and so cannot guarantee that they
will comply with those privacy laws.
Peru
You may exercise rights related to the protection of
personal information by requesting access to your personal information or the
correction, deletion or suspension of processing of your personal information,
etc. pursuant to applicable laws such as the Personal Data Protection Law (the
“Law”).
You may also exercise these rights through your legal
guardian or someone who has been authorised by you to exercise the right.
However, in this case, you must submit a power of attorney to us in accordance
with the Law.
Upon your request, we will take necessary measures
without delay in accordance with applicable laws such as the Law.
You can also withdraw your consent or demand a
suspension of the personal information processing at any time.
If you consider that your request has not been met you
may file a claim with the Peruvian National Authority of Personal Data
Protection.
Contact
To protect your personal information and handle
complaints relating to your personal information, we have appointed the
following department responsible for managing and protecting your personal
information.
Qatar
If you
are using the Service in Qatar, you consent (for the purposes of Law No. 13 of
2016 on the Protection of Personal Data, as may amended from time to time) to
the processing of your information in accordance with this Privacy
Policy.
Russia
The Service is not directed at Russian users or
Russian market and, in particular, is not available in the Russian language. However,
if you happen to be using the Service in Russia, by using the Service you
consent to:
The sub-sections “Access”, “Correction”, “Erasure”,
“Restriction of Processing to Storage Only”, “Objection” of the section “Your
Rights” above apply to users in the Russian Federation.
We will notify you of any material changes and may
request you to acknowledge such changes. Unless we require your acknowledgment,
you shall be deemed to have agreed to the changes if you continue using the
Service after the notification.
As regards the representative for Russia, you can
contact us at dpo_contrareturns@proximabeta.com. Please include the word “Russia” in the subject line of
your email.
Separate
consent for using certain data
By using the Service you also consent to the sharing
of your personal information with certain third parties for the purposes set
out under section 3 “How
We Store and Share Your Personal Information”.
You determine, in your discretion, the terms of disclosure
to the general public of your personal data by choosing to use certain features
of the Service and by choosing the appropriate privacy settings in respect of your
personal information in the Service.
We process your personal information subject to the
terms of this Privacy Policy and your chosen features and settings.
This consent is granted for as long as you use the
Services. The consent may be withdrawn by you (and you may set any restrictions
on processing of your relevant personal information) at any time by contacting
us (dpo_contrareturns@proximabeta.com): please include the word “Russia” in the subject line of
your email.
Serbia
Our designated local representative in Serbia is
Karanovic & Partners for the purposes of compliance with the Law on
Personal Data Protection, and can be contacted at
local.representative@karanovicpartners.com. Please include the word “Serbia” in
the subject line of your email.
South Africa
You have the
right to lodge a complaint with the Information Regulator (South Africa) by
emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical
address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein,
Johannesburg, South Africa.
Turkey
Our Data Controller Representative in Turkey for the
purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık
Ortaklığı, can be
contacted at proximabeta@iptech-legal.com. Please include the word “Turkey” in
the subject line of your email.
You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information
data we hold about you. As a Turkish data subject, you may have the right to
apply to the data controller and (to the extent permitted under applicable laws
and regulations):
In accordance with Article 9 of the DPL, your
personal data may be transferred abroad as follows:
Identity of
the overseas recipient |
Location of
the recipient (or as otherwise stated in the recipient’s privacy policy) |
Purposes of
use of Personal Information by the recipient |
Items of
Personal Information to be provided |
Microsoft
Azure |
Germany,
United States |
Storage of
personal information |
All personal
information specified in the section “Data Retention” |
Appsflyer |
Belgium,
Ireland |
Conduct
analytics and monitor the success of our advertising campaigns |
Advertising
information |
Firebase |
United States |
Conduct
analytics and monitor the success of our advertising campaigns |
Analytics and
profiling data |
Ukraine
By accepting this Privacy Policy, you expressly
authorize us to collect, use, store, and process your personal data, including
disclosing to third parties and transferring to countries other than Ukraine,
to the extent and for the purpose provided by this Privacy Policy.
United Arab Emirates
You consent to the collection, use, disclosure,
transfer, export (to the extent permitted by applicable laws) and storage of
your personal information, as described in the Privacy Policy.
We may voluntarily report a cyber-security incident
where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law).
The incident can be reported to the relevant authorities for the purpose of
investigations. Please note that voluntary reporting of a cyber-security
incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness
organisation that provides a process for logging incidents and advising on
known cyber security threats in the UAE.