Arena of Valor

Privacy Policy

Last Updated: 2022-4-26

Thankyou 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 Service?

If you register an account to use the Service then we will need some information from you to set this up. If you choose to register an account using a social media account (e.g. Google, Facebook, Apple), we will need information from that social media account to set this up. If you choose, you can provide certain other information to personalise the gaming experience and enable game features, or participate in the Service. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.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. If you choose to use the eSports Website, we will need your Game log-in credentials (via your social media account) and other information, such as your email address, prize distribution information, and information to enable you to create, register for and participate in eSport competitions for the Game. 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 support and 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 or to back up your data; using our affiliates around the world to help us to deliver the Service), provide and enhance your experience on the Service and certain Service-related products, or monitor the success of our marketing and advertising programs, orwe 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 support services). 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 Service-related products, 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 Brazil, Germany,Singapore, the United States, and Russia (for Russian users). Your information can be accessed from outside of where you live by our support, engineering and other teams are located in our offices around the world, including Singapore, Brazil, Germany, the United States and Russia. Certain personal information processed for marketing purposes may also be stored and processed by our third party SDK Appsflyer’s servers in the United States, Belgium and Ireland, or Adjust SDK’s servers in Frankfurt, Amsterdam and the United States. 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_aov@proximabeta.com

EU Representative: Proxima Beta Europe B.V. | Email: dpo_aov@proximabeta.com

UK Representative:Image Frame Investment (UK) Limited | Email: dpo_aov@proximabeta.com

Serbia Representative: Karanovic& Partners o.a.d. Beograd. Email: local.representative@karanovicpartners.com

Turkey Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: turkeydatarep_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 in-Service conduct, bans, investigations, civil or criminal complaints.

Welcome to Arena of Valor!

This Privacy Policy explains the when, howand whywhen it comes to processing of your personal information in connection with the Arena of Valor platform, consisting of the Arena of Valor mobile game (“Game”) and its website, and the Arena of Valor eSports Website (“eSports Website”) (collectively or individually, as applicable, 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 accepting our rules regarding your personal information as described in this Privacy Policy.

 

This Service is operated by Proxima Beta Pte. Limited(“we”, “us”, “our”).

For the purpose of data protection laws,the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

The registered address of Proxima Beta Pte. Limitedis 10 Anson Road, #21-07 International Plaza, Singapore (079903).

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, the Netherlandsand can be contacted at dpo_aov@proximabeta.com. Our data protection officer can be contacted at dpo_aov@proximabeta.com.

Our data protection officer can be contacted at dpo_aov@proximabeta.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

 

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime atdpo_aov@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:

Game

1. Information you provide to us (either directly or through a third party). 

 

• Account registration information:You give us your nickname when you log-in as a ‘guest’ in order to use the Service. If you login via your Google Play account, you give us your Google ID and Google display name. If you login via your Apple (iOS game centre) account, you give us your Apple ID, Apple display name and profile picture. If you login via your Facebook account, you give us your Facebook username and ID and you may choose to give us your email address and friends list as well. You may also choose to provide your gender during account registration.
• Validation data: When you register for an account for the Service we will process certain information to validate your eligibility for the Service.
• Survey information (aggregated data): If you choose to participate in a survey about the Service, you may be asked to provide certain personal information, e.g. your age, gender, email, address, phone number geographic (country) location, game information (game habits and preferences) and any other content you choose to provide as part of the survey response. We will use your survey response the purpose of improving the Service. In such case, your personal data will be processed in accordance with iMUR’s privacy policy. We will only process your aggregated information which we receive from the iMUR platform once you complete the survey and for the purpose of improving the Service.
• Marketing information: Advertising information about you that we collect directly from you and from third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer), such as your IP address, IDFA, Android advertising ID (AAID), which users click/viewour campaign and creative materials, e.g. photos and videos that are advertised on the ad partner’s platform, your advertising ID and other user engagement data (purchase behaviour and in-app behaviour) (collectively, “advertising identifiers”), Facebook campaign ID, user search terms and Google Adwords campaign information and identifiers. We also collect certain advertising information about you which we share with third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer and Adjust) to monitor the success of our advertising campaigns, such as your advertising identifiers, user in-game activities (including login, purchase activities, friends invited and user retention) and other tracking information (mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website / app).
• Forum (website only) information: If you choose to use and post on a forum, your username, password, email address and the content of your forum posts and messages.

2. Information about yougenerated as part of the Service

 

We automatically collect certain data from you when you use the Service, namely:

 

·      IP address and open ID to facilitate account registration;

 

·      game data and log information: open ID, IP address, device model, geographic ranking based on your selected country location and information regarding your use of the Service, such as gameplay statistics (e.g. level, heroes and scores);

 

·      GPS information to enable you to find users near you;

 

·      game analytics information: your user region and device information to enable us to perform overall game analytics, including error fixing, troubleshooting and debugging;

·      transaction records: when you make purchases within the Service, your Open ID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to your player ID;

• your text and audio chat datawhen you communicate with other users in the Service (including if you use text-translation services or voice-to-chat functions when you communicate with other users in the Service);
• gameplay videoif you choose to download or share your gameplay;
• for the purposes of providing customer support (in-app or via email): name, open ID, device ID, application version, battery level, WiFi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate your problem;
• for the purposes of sending you push notificationswhile using the Service: your device model, device name, device manufacturer, running process information, SDK version, application package name, application version, operator name and network type;
• security information: your device (iOS or Android)’s technical device information, for the purposes of detecting and preventing cheating and any domain name hijacking on the Service;
• anti-cheating security information: your game speed, whether in-game tools are functioning within the normal parameter, account, access time, for the purpose of detecting and preventing cheating on the Service; and
• In-game forum information: Your user ID, nickname, profile picture, comments left by you on the forum, in order to facilitate the posting of your comments on the forum.

eSports Website

• account login information: In order to access the eSports Website, you must login via your Apple, Facebook or Google account used to register for the Game. If you login via your Google Play account, Apple (iOS game centre) account or VK account, you give us your user ID, nickname, profile picture, user token and Open ID. If you login via your Facebook account, you give us your Facebook UID, name, profile picture, user token and Open ID;
• competition information: Your Open ID, nickname, profile picture;
• game data and log information: as above in the “Game” section, which is also processed to provide you with feedback and information about your gameplay and progress during our eSport competitions;
• your text chat datawhen you communicate with your team mates;
• data reporting information: your user ID, client type, nation, battle ID, match ID, area ID, target user ID, channel ID and push ID;
• your Game ID and email address; and
• prize distribution information:Consignee name, phone number, address and bank card details (for monetary prizes).

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here.

Children

Our Service is not intended for children, unless their parent or legal guardian has provided consent (if this is available in your jurisdiction). Except with such consent, children must not use the Service for any purpose. If you are a parent of a child who has signed up with your consent and you would like to understand more about the Service or how you can revoke your consent, please refer to the section “Information for Parents” below.

By children, we mean users under the age of 13 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.

Except as lawfully permitted, 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 atdpo_aov@proximabeta.comand 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 European Economic Area, United Kingdom, Switzerland, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

 

We may collect other personal information from you from time to time for specific reasons. For example, when you participate in a promotion, lucky draw or sweepstake event in your country, or if you win a prize when participating in such activities, pursuant to the contract for the activity you may provide us with information (such as your name, player ID, game data, competition submission, email address, phone number, postal address, or payment details). When this happens, we may provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, the information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights. We generally retain such information for the duration of the relevant activity and thereafter in accordance with legal obligations.

 

In certain circumstances, if you bind, link and/or sync your account for the Service with another app, website or service related to the Service (for example, Arena Buddy), we may also share certain personal information with such services for the purpose of providing and enhancing your experience using the Service and Service-related products. Please refer to the privacy policy of the relevant product for details on how your data is processed.

 

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 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:

·      Brazil

·      Germany

·      Singapore

·      United States

·      Russia (for Russian users)

Marketing data about you that is collected or shared with third party ad partners (e.g. Facebook and Google) may also be stored and processed on our third party SDK’s (Appsflyer) servers in the United States, Belgium and Ireland, and AdjustSDK’sservers in Frankfurt, Amsterdam and the United States. Customer support information may also be stored in our third party partner (AIHelp)’s servers in the United States.

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, Brazil, Germany, the United States and Russia.

Only where necessarywill we share your personal information with third parties. Situations where this occur are:

·      Third partiesthat provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, to allow you to login through an existing social network account (e.g. Google Play), and for the purpose of providing marketing and advertisements on ad partners’ platforms ( Facebook, Google, Apple, Twitter, Snapchat and Appsflyer) and monitor the success of our marketing and advertising programs on such platforms. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

·      Companies within our corporate groupwho process your personal information in order to operate the Service and interoperable functions and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required todisclose information about you to authorities such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

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 of your information which you do 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.                                  

 

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_aov@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_aov@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., game play statistics), 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 account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_aov@proximabeta.com. 

Erasure

You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at dpo_aov@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_aov@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_aov@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 the Service’s access 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_aov@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_aov@proximabeta.comand 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 region 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 policy here and notify our userswithin the Service. 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.

 

INFORMATION FOR PARENTS

Before your child can use Arena of Valor, you will need to provide your consent to approve your child’s account set-up and the processing of their personal information.

 

What personal information does Arena of Valor process?

 

Arena of Valor is a platform that consists of services including a mobile game and eSports website.

 

If your child successfully signs up to Arena of Valor, this will result in the collection and sharing of certain personal information:

 

• a nickname (for the account);
• device information (including IP address and device identifiers) which is used to register each account, maintain the game environment, ensure optimal performance and security, and troubleshoot bugs;
• Identifier for Vendors (IDFV)/Identifier for Advertisers (IDFA), which is used solely to manage our promotion campaigns (there is no advertising within Arena of Valor);
• game and log data (to save game progress);
• GPS location sufficient to allow users to play with other players nearest their region, reducing latency (but please note that geolocation is not sufficient to identify street name and/or name of city or town);
• gender (if they choose to add this to their profile);
• survey responses (if they choose to participate in game feedback surveys from time to time);
• customer support information (if they contact customer support);
• In-game forum information (including comments they post on the forum, if they choose to do so);
• email address;
• prize distribution information (if they participate in our eSports competitions and win any prizes).

 

You can review our Privacy Policy for more details on what personal information we collect and how we use and process the information.

 

 

Does Arena of Valor process personal information differently for children?

 

Yes. In some jurisdictions children will not be able to access certain features – such as in-game voice chat.

 

 

Why is my consent required?

 

Certain jurisdictions require or recommend the consent of a parent or legal guardian before their child can sign up to a game such as Arena of Valor, where personal information will be processed. If you do not consent, or withdraw your consent, we will immediately delete any personal information collected up to that point.

 

 

What method(s) can I use to verify my child’s account?

 

In some jurisdictions, including the United States, we ask for date of birth at registration. We will not allow a child to sign-up without first obtaining verifiable consent from that child’s parent or legal guardian. As part of this, we need to verify that you are an adult capable of providing such consent. To do this, we charge or authorize a small amount to a credit card. This process is handled by Skyblue Enjoy Investment Pte. Ltd. We do not process your credit card information – only the third party payment processor collects credit card information. The credit card information is not retained for any reason, including future purchases or connected to in-app payment functions (if any) in the game.

 

 

What if I do not consent?

 

If you do not consent (including by providing your credit card details for verification) then your contact information will be deleted.

 

 

How do I withdraw my consent or delete my child’s account?

You can withdraw your consent or delete your child’s account by emailing us at dpo_aov@proximabeta.com. You can also request a copy of your child’s personal information at any time.

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, the user gives his/her consent for the collection, the storage, the treatment, the use, the transfer of your personal information to a third party (local cloud providers or to back up your data or our affiliates around the world to help us to deliver the Service) located in Germany, the United States, Brazil, Singapore, Belgium, Frankfurt, Amsterdam, and Ireland(as detailed 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 providingus 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.

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.

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_aov@proximabeta.com.

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 account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_aov@proximabeta.com.

 

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-game 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.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorize us to collect, use, store, and process your personal data, including, disclosing to third parties, to the extent provided by this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, toGermany, the United States, Brazil, Singapore, Belgium, Frankfurt, Amsterdam,and Ireland.

Age Restriction

In order to use the Service, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

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_aov@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 AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, 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:

• Identifiers, such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
• Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and other device information as described in the main policy. This information is collected directly from you and your device.
• Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
• Geolocation data such as your GPS information if you use location based services. This information is collected directly from you.
• Audio and visual information such as your social media profile picture, audio messages and gameplay video. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account, or if you choose to share your gameplay.
• Other information described in subdivision (e) of Section 1798.80, including information about your gender. This information is collected directly from you in the context of being our consumer.

 

We collect your personal information for the following purposes:

• To provide you the Service, including offering the Service, maintaining your account, processing payments, and delivering audio and text messages;
• To process surveys;
• To improve our services, including the functionality of the Service;
• For security and verification purposes, including to prevent and detect fraudulent activity;
• To address and remediate technical issues and bugs.

 

For additional information about what each type of personal information is used for, see this chartin the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

• Other companies within our corporate group who process your personal information in order to operate the Service
• Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us
• Regulators and judicial authorities and law enforcement agencies
• Entities that acquire all or substantially all of our business

 

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:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
• the categories of personal information about you that we collected;
• the categories of sources from which the personal information was collected;
• the purpose for collecting personal information about you;
• the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
• the specific pieces of personal information we collected about you;
• Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
• Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.  

 

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 exercise your rights, if any, regarding other data by contacting us at dpo_aov@proximabeta.com.

Canada

 

If a user located in Canada wishes to obtain written information about our policies and practices with respect to our service providers located outside Canada, they may contact us at dpo_aov@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.

 

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.

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 Germany, the United States, Brazil, Singapore, Belgium, Frankfurt, Amsterdam,and Ireland.

 

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.

 

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer and storage of your Personal Information.

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 authorize 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 "The types of personal information we use” and section “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 “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.

You can also register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising on your phone number.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Service may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy.

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:

 

 

b)    the purposes of the processing for which the data are intended are set out in the table in Section 2 (“How We Use Your Personal Information”).

 

c)    recipients or categories of recipients are set out in the second paragraph of Section 3 (“How We Store and Share Your Personal Information”).

 

d)    whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 2 (“How We Use Your Personal Information”) and Section 5 (“Your Rights”, sub-paragraph “Objection”).

 

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

Correction

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

If you happen to be using the Service in Russia, this section “Russia” applies to you. By using the Service you consent to:

• for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Service or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
• the cross-border transfer of your information to any country where we have databases or affiliates, in particular Germany, the United States, Brazil, Singapore, Belgium, Frankfurt, Amsterdam,and Ireland;
• for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy.

 

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.

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 “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_aov@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.

·      Name: Karanovic& Partners o.a.d. Beograd

·      Address: Resavska 23, Belgrade, 11000, Serbia

·      Telephone Number: +381 11 3094 200

South Africa

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, 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.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information, we will provide you with our response to the request within 21 working days.

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 turkeydatarep_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):

 

 

·      learn whether or not your personal data has been processed;

·      request information about processing if your personal data has been processed;

·      learn the purpose of processing of your personal data and whether they have been used accordingly;

·      know the third parties in the country or abroad to whom personal data has been transferred;

·      request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

·      request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

·      object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and

·      demand compensation for the damages that you have suffered as a result of unlawful processing of your personal 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), sharing 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 also 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.