Privacy Policy

1. INTRODUCTION

This Privacy Policy will be effective from January 20, 2022.

This document aims to inform you regarding the processing, collection, use and disclosure of information, including your personal data in conjunction with your access to and use of Our Products and Services.

Zariba Ltd observes and complies with the applicable laws and regulations relating to the protection and storage of personal information.

This Privacy Policy is applied to all services, products, websites, games, content, together referred as “Products” and/or “Services”, managed by Zariba Ltd.

When this policy mentions “Zariba Ltd”, “Zariba” “we,” “us,” or “our,” it refers to the Zariba company that is responsible for your information under this Privacy Policy (the “Data Controller”).

This Privacy Policy does not apply to any third-party services or websites linked from or integrated in any Product of Zariba Ltd. Such third parties have their own Privacy Policies and Terms of Service, which Zariba does not control in any way.

We are committed to protecting your privacy and take special measures to ensure the confidentiality of Personally Identifiable Information collected from or about you. This Privacy Policy explains what information we collect, how we collect it and why, how we use it and with whom we share it, how you can access and update that information, the choices you can make about how we collect, use, and share your information, how we protect the information we store about you.

Please read this policy carefully. If you do not agree with this privacy policy, or any part of it, if you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you may not use our products.

In case you do not notify us in writing of disagreement or do not take the necessary measures to remove your application, it is considered that you agree fully with the Privacy Policy.

Your use of our Services is treated as an acceptance of the version of this policy in effect at the time of your use.

Applicable to this privacy policy and all relations deriving therefrom shall be the applicable Bulgarian legislation.

If you have any questions about this privacy policy, please contact us at [email protected] and do not use our Products and Services until you are satisfied and can accept this policy in its entirety.

2. TYPES OF INFORMATION WE COLLECT

There are three general categories of information we collect:

2.1. Information You Give to Us

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

2.1.1. Information that is necessary for the use of the Products

When you use our Services (whether through a social network, through third-party website integrations or through our Service directly), you may give us information directly (like when you’re setting up your application) and we will store that on our systems and use it for the purposes described in this Privacy Policy.

We ask for and collect the following personal information about you when you use the Products. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

We may collect personal information from you when you do any of the following on our website:

Submit applications
Enter any of our competitions, contests, sweepstakes, and surveys
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media

2.1.1.1. Application Information

2.1.1.1. 1. Name
2.1.1.1. 2. Email address
2.1.1.1. 3. Other information that helps us make sure it’s you or helps us improve our services;

2.1.2. Information you choose to give us

2.1.2.1. Additional Application Information

You may choose to provide additional information as part of your profile. Some of this information is part of your public profile page / application, and will be publicly visible to others.

2.1.2.1.1. Phone number
2.1.2.1.2. Short presentation
2.1.2.1.3. Name of your studio (team)
2.1.2.1.4. Info about your studio (team)
2.1.2.1.5. Company location (city)
2.1.2.1.6. Contact Phone
2.1.2.1.7. Links to your profiles on various social networks;

2.1.3. Information You Generate Using Our Communications Features

We consider “user-generated content” to be materials (text, image, video content, and/or games) voluntarily supplied to us by our users for the purpose of publication on our website, or broadcast on our social media and/or video channel(s). All user-generated content is associated with the name or email address used to submit the materials.

When you communicate with Us or use the Products to communicate with other users, we may collect information about your communication and any information you may choose to provide when you fill in a form, conduct a search, update or add information to your submission, respond to surveys, post to community forums, participate in promotions, or use other features of the Products.

Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.

We will collect and store the contact information you choose to provide in correspondence with Support team like your name and contact email address, information about your activity on the website. We will also store the communications you have with the Support team and any information in those communications in order to provide support and improve the Products.

2.2. Information We Automatically Collect from Your Use of the Products

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

When you use the Products, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Products.

2.2.1. Usage information

We collect information about your interactions with the Products and other actions on the Products. In some cases, we will connect this information with your social network ID or user ID.

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

2.2.2. Cookies and similar technologies

We use cookies and other similar technologies. We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:

2.2.2.1.cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
2.2.2.2.web beacons, which let us know if a certain page was visited or whether an email was opened;
2.2.2.3.tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and
2.2.2.4.local storage objects, which help us to reduce fraud, remember your preferences and speed up load times.
2.2.2.5.mobile identifiers

3. LAWFUL BASIS FOR PROCESSING DATA

We comply with all applicable laws including General Data Protection Regulation (the ‘GDPR’, Regulation (EU) 2016/679, https://www.eugdpr.org/). Under European law, companies must have a legal basis to process data.

3.1. Your consent

Where you have provided consent, we process your information, including personal information, as described at the time of consent.

3.2. Contract

as necessary to fulfill our Terms of Service;
adequate performance of the contract between you and us;

3.3. Legal obligation

to enable us to comply with legal obligations;

3.4. Vital interests

to protect your vital interests, or those of others;

3.5. Legitimate interests

our legitimate interest in being able to provide and improve the functionalities of the Products and Services;
our legitimate interest in protecting the Products and Services;
detect and prevent any fraudulent or malicious activity against our Products and Services or our users;
to measure the adequate performance of our contract with you;
as necessary for our (or others’) legitimate interests, including our interests in providing an innovative, personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

4. HOW WE USE INFORMATION WE COLLECT

We use, store and process information, including personal information, about you, to provide, understand, improve, and develop the Products, create and maintain a trusted and safer environment and comply with our legal obligations. It is our legitimate interest to research and optimize our Services; to undertake marketing campaigns personalized to you, that may be of your interest; to improve and measure the performance of the contract with you. It is our legitimate interest to protect us, our services and property from any harm and to comply with the law.

4.1. Provide, Improve, and Develop the Products

Provide access and use of the Products;
Operate and optimize the Products by researching and analyzing usage and performance;
Provide technical and customer support;
Communicate with you regarding the service, support and updates;

4.2. Create and Maintain a Trusted and Safer Environment

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity;
To protect Our rights and property in connection with our Products;
Comply with our legal obligations;
Resolve any disputes with any of our users;
Enforce our policies;

4.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing

Send you promotional messages, offers, marketing, advertising, and other information that may be of interest to you based on your preferences;
To notify you about updates, new products or promotional offers;
Personalize, measure, and improve our advertising;
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Us or our third-party partners;

5. HOW IS THIS INFORMATION SHARED

5.1. Aggregated Data

We may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

5.2. Your Consent

With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

5.3. Sharing between other users

When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

5.4. Other Public Information

The website may let you publish information, including personal information, that is visible to the general public. Parts of your profile page / application may be publicly visible to others.

5.5. Third-Party Service Providers

We use a variety of third-party service providers to help us provide services related to our Products.
We may share information with such third-party service providers like data analytics, statistics and research, email, hosting, customer service, consulting, marketing and audit, ad networks.
These providers have limited access to your information to perform tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

5.6. Advertising and Analytics

We may have advertising on our website so we can offer some of our Products or product functionalities for free. We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent.
Third-party advertisers may collect or we may share information like performance data, aggregated data, technical information.
This information is used to measure performance of the ad campaigns and to provide targeted advertising, whether you have provided consent for this.
Also we have analytics integrated in our Products which is used to monitor and measure user activity for the purposes of maintenance and improving our services.
Third-party advertisers may use of tracking technologies like browser cookies and web beacons and others.

5.7. Safety, Security and Compliance with Law

We access, preserve and share your information with regulators, law enforcement or others:
In response to a legal request and if required by law;
To detect, prevent and address crime, fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect our rights and property;
To protect you or others, to prevent death or imminent bodily harm;

5.8. New owner

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.

6. HOW YOU CAN EXERCISE YOUR RIGHTS PROVIDED UNDER THE GDPR

6.1.1. Exercise your rights

You may exercise any rights you have to correct, amend or delete information about you. If you want to exercise any of the rights described in this section, review, delete, or change the information we have about you or have additional questions, email us at [email protected].
Providing the rights and freedoms of others are not affected, we will help you to exercise your rights.
All requests connected to your personal data must be sent only to the specific email address listed above. For us to be able to process your request, in the email sent to the special privacy email address, You should include a detailed description of your request and all needed information to prove that you are the lawful owner of the personal data in question. Such email should be sent from the email address connected to your personal data and your submission. Any privacy related message that does not comply with the above requirements will not be processed.
We will respond to your request within thirty (30) days.
Please note that we may ask you to verify your identity before taking further action on your request.

6.1.2. List of rights under GDPR

6.1.2.1. The right to be informed

You have the right to be informed about the collection and use of your personal data.

6.1.2.2. The right of access

You have the right to access your personal data.

6.1.2.3. The right to rectification

You have the right to have inaccurate personal data rectified, or completed. You are responsible for keeping your personal information up-to-date.

6.1.2.4. The right to erasure

You have the right to have personal data erased. The right to erasure is also known as ‘the right to be forgotten’. The right is not absolute and only applies in certain circumstances.

6.1.2.5. The right to restrict processing

You have the right to request the restriction or suppression of use of personal data. This is not an absolute right and only applies in certain circumstances. When processing is restricted, we are permitted and may store the personal data, but not use it. If you want to stop receiving promotional emails from us and our partners or third-party, click on the “unsubscribe” link in the email.

6.1.2.6. The right to data portability

You have the right to obtain and reuse your personal data for your own purposes across different services. The right only applies to information that you have provided to us.

6.1.2.7. The right to object

Individuals have the right to object to: processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); processing for purposes of scientific/historical research and statistics.

6.1.2.8. Rights in relation to automated decision making and profiling

If you do not want to be subject to profiling, contact us following the above procedure.

6.1.3. Third-Party Targeted Advertising

If you choose to opt-out from seeing “interest based” targeted web advertising, delivered by third parties, you may visit listed third-party websites. These websites are operated by third parties. We do not control or operate them.

If you choose to opt-out from seeing “interest based” targeted in-application advertisements, delivered by third parties, you may adjust the ad tracking settings on your mobile device. The operating system of your mobile device lets you see your advertising identifier in the settings of your mobile device, and you control how it is used.
Please note that you may still receive advertisements from third parties within our Products even if you opt-out of targeted advertising but they will not be based on your activity across unrelated web sites or apps.

6.1.4. Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow.
In addition, your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. For more information about these controls, visit your browser or devices’ help material. Certain parts of the Products may not work properly if you have disabled browser cookie use.
If you disable cookies, you may lose some of the features and functionality of our Services because the cookies are necessary to track and enhance your game activities.

6.2. THIRD-PARTY SERVICES AND ADVERTISERS

Our Products may contain advertisements from Third-Party Services, which are companies other than us, that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

7. HOW LONG WE KEEP YOUR INFORMATION

How long we retain your information depends on why we collected it and how we use it. We store data as long as it is necessary to provide our services to you (performance of the contract), or until your account / submission is deleted – whichever comes first. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.
In some specific cases it is possible to retain some information for a certain period after this:

as necessary for our legitimate business interests, such as fraud detection and prevention, and security;
As necessary to comply with our legal obligations like tax, legal reporting, auditing;
Information you have shared with others may continue to be publicly visible on the Products, even after your submission is deleted. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
As we undertake continuous measures to prevent any accidental or malicious data loss on the Products, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

8. SECURITY OF YOUR INFORMATION

We are continuously implementing and updating administrative (including appointment of Data Protection Officer), technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
Some of the safeguards we use to protect your information are firewalls, data encryption, SSL encrypted communication between client and server, Secure certificate keys, and information access level controls.

While we take precautions against possible security breaches of our Products and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Products.

9. DATA TRANSFER OUTSIDE EEA

Because of the global nature of our products and to provide better service we may transfer, store, and process information about players and visitors to our Products, including personal information, on servers and equipment, and with service providers based in and outside EEA (European Economic Area), like United States or Canada, for the purposes described and in accordance with this policy.
These data transfers are necessary to provide the services set forth our Terms and to globally operate and provide our Products to you.
The data we hold may also be processed by employees operating outside of the EEA who work for us or our partners and service providers. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services.
When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

Where we transfer, store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

10. CHANGES TO THIS PRIVACY POLICY

To comply with the latest legislations and to apply the best possible protection, We reserve the right to modify this Privacy Policy at any time in accordance with this provision.

If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Products and on this page, and update the “effective date” at the top of this Privacy Policy.

We will announce the changes by placing a notice on Products, or by sending a message to the email address we have on file for you. We may also publish additional notices on social network pages, and on other our websites.

If you disagree with the revised Privacy Policy, you may cancel your submission. If you do not cancel your submission before the date the revised Privacy Policy becomes effective, We will treat your continued use or access to the Products, websites or any other Services as acceptance of the revised Privacy Policy from their effective date as shown above.

11. CONTACT US

If you have any questions or complaints about this Privacy Policy or Our information handling practices, you may email us or contact us at:
[email protected]

All other inquiries should be directed to:
Sea Game Jam support email
[email protected]

Zariba Ltd
58 DEBAR STR.
9000, VARNA
BULGARIA