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Contra Returns

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.

How to get in touch with us

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.

Contact 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

dpo_contrareturns@proximabeta.com

UK

Image Frame Investment (UK) Limited

Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB

dpo_contrareturns@proximabeta.com

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

proximabeta@iptech-legal.com

 

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.

1.     The Types of Personal Information We Use

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

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.

2.     How We Use Your Personal 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:

  • Open ID
  • Gameplay statistics: geographic ranking based on country selection and game play statistics, e.g. level, heroes, scores and date and time stamps of actions
  • Device’s hardware information: 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

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.

Customer support information:

  • FAQ information: number of home page visit page views and unique visitors, number of search page views and unique visitors, number of search into AI and search into FAQ, number of FAQ page views and unique visitors, number of interactions with FAQ, number of FAQ likes, number of FAQ stepping, number of click times into the customer service home page and the number of human sessions and bot sessions; and
  • error reporting information: error name, event name, sign, h5_sign, language type, token, authorization request IDs, FAQ_ID, Common information for data reporting

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:

  • In-app notification: open ID, device language, device version, brand, app version, screen size, network type, ROM, RAM and CPU name
  • Email notification: email address

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.

 

3.     How We Store and Share Your Personal Information

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:

4.     The Security of Your Personal Information

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.

 

5.     Data Retention  

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.

6.     Your Rights

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.

7.     Contact & Complaints

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.

8.     Changes

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.

9.     Language

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.


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

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 3How 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.