Effective date: November 1, 2021
Last modified: April 26, 2023
Terms & conditions.
Vira Games Inc. - refers to "Vira Games Inc.", and its affiliates, parents, and subsidiaries (hereinafter - "Company", "We", "Our").
Games - games developed by Vira Games and published on behalf of the Publishers.
Personal Data – any information that directly, indirectly, or in connection with other information allows for the identified or identifiable natural person (hereinafter - Personal Data, Personal Information).
Processing of Personal Data – means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Controller – Company which determines the purposes and means of the Processing of Personal Data (hereinafter - Controller).
Data Subject – the individual who uses the Games and who, unless otherwise specified, coincides with the Data Subject (hereinafter - "You", "Yous", "User").
Third party - a legal entity, public authority, agency, or body other than the Data Subject, the Controller, the Processor, and individuals authorized to process Personal Data under the direct supervision of the Controller or the Processor, which other services integrated into the Games, and individuals who may receive any information from the Games, including the Company's partners, such as Publishers and analytics and management services providers, etc.
Supervisory authority – an independent public authority which is established by a EU Member State to solve disputes, arising within Personal Data protection.
Cross Border Data Transfer (CBDT) – Transfer of Personal Data by Controllers established in the European Union (EU) to recipients established outside the territory of the EU/EEA who act either as Controllers or as Processors.
GPDR – General Data Protection Regulation of the European Parliament and Council No. 2016/679 of 27.04.2016 on the protection of natural persons in connection with the processing of Personal Data and free movement of such data, and cancellation of Directive 95/46/EC.
UK GDPR - regulation included in the United Kingdom and Northern Ireland legislation with changes made in accordance with the Data Protection, Privacy and Electronic Communications Regulations.
CCPA - California Consumer Privacy Act 2018, a state statute intended to enhance privacy rights and consumer protection for residents of California, United States.
CalOPPA - California Online Privacy Protection Act of 2003.
Legal grounds & purposes.
Purpose of Data Processing is to provide and deliver Games You request and send You related information as requested by You as agreed with You; to provide, maintain and the game experience; and to send You technical notices, updates, security alerts, and support and administrative messages.
Legal grounds of Data Processing are the purposes for which the Personal Data are intended as well as the legal basis for the Processing. For example, Personal Data which could be related to criminal convictions and offenses or related security measures is processed (requirement of Art. 6.1 of GDPR).
Processing and/or transmission of Personal Data is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data, in particular where the Data Subject is a child.
EU residents are subject to GDPR and EU-US Privacy Shield, due to origin of the Controller.
US residents are subject to the: 1st, 4th, 9th and other Amendments of the Constitution of the United States of America, which regulates such legal relationships; COPPA; CCPA and Federal Laws.
EEA residents are subject to EEA Data protection legislation that apply to those Users.
All other worldwide Users (third countries) are subject to its domestic Data protection legislation.
Company adheres to the worldwide principles of Personal Data protection as envisaged in the EU GDPR and the UK GDPR, CalOPPA, CCPA, and other applicable laws. In accordance with these principles, We assure You that the User’s Personal Data is:
- Processed fairly and lawfully and in a transparent manner in relation to the Data Subject;
- Processed for specified, explicit, and legitimate purposes only and not further Processed in a manner that is incompatible with those purposes;
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are Processed;
- Kept accurate and up to date;
- Retained in a form permitting identification of Data Subjects for no longer than is necessary for the purposes for which they are Processed;
- Processed in a manner that ensures their appropriate security.
Purposes of Personal Data Processing.
To help us improve the Games and fix any problems. We may Process information about You so that we can analyze and improve Our Games.
This Processing is also necessary for us to pursue Our legitimate interests of (i) ensuring that Our Games function properly so that You and other Users have the best experience when playing any of Our Game(s); (ii) identifying and correcting any bugs in the Games; and (iii) understanding the effectiveness of Our marketing to attract new Users.
To improve the monetisation of the Games. We may process information to understand how Users use Our Games, and to compile statistical reports regarding that activity. This processing is necessary for Us to pursue Our legitimate interests of improving the Games and increasing the amount of revenue generated via Games purchases.
For advertising purposes. We may process Advertising Data to show You advertisements for Third Party services. The information We collect about You may be used to understand how advertisements placed in Our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify You or permit You to be treated individually.
For analytics purposes. Such Personal Data is used to evaluate User behavior or Game performance. For example, to understand the effectiveness of existing Games features, monitor Games performance, diagnose and fix bugs or crashes, or to make future performance improvements.
What Personal Data do We collect?
We do not collect Your Personal Data such as name, postal address, email address, telephone number, gender, date of birth, country, preferred language, User name, password, credit card information, as well as any other information that may be used to identify You.
PLEASE, NOTE THAT:
We do not collect any special categories of personal data about you (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political or religious opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Moreover, We cannot access or use Your financial information. When making a transaction, You enter Your credit card details into a form supplied by the payment provider that will be Processing the payment, and this information goes directly to the payment provider's server. We do not serve Your credit card information.
As We do not store any credit card details or transaction information, it is impossible for us to handle complaints regarding payment Processing – any disputed payments are the responsibility of the third parties who take payments, payment providers, and banks that participated in the exchange.
PLEASE NOTE, THAT THIRD PARTIES MAY COLLECT YOUR PERSONAL DATA
We use Third Party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via our Games (Advertising ID or Android ID for Android devices). Some integrated advertising or analytics tools launch automated processing of Your Personal Data, including profiling, which means any form of automated processing of Personal Data used to evaluate certain personal aspects relating to You, in particular, to analyze or predict aspects concerning Your personal preferences, interests, behavior, location or movements.
Information used for the purposes of serving advertisements (“Advertising Data”) or providing analytics.
Through Our Third Party advertising network partners, we may gather information about Your devices when You install or play our Games, depending on the permissions You’ve granted. The list of Personal Data that may be collected and shared with Us by Third Parties can be found in cl. 8 by clicking on the appropriate link.
Where store Your Personal Data?
Which services may store Your Personal Data?
Please note, that We do not control or influence Third Parties’ tracking technologies or how they may be used. But by integrating external tools and services we choose legal entities that can assure they apply all necessary technical and organizational measures to protect Personal Data. We are not responsible for any accidental loss or unauthorized access to Your Personal Data through the fault of such legal entities. These legal entities are separately responsible for their privacy policies and practices.
The following Third Party providers and advertising partners might be may be engaged by us in the processing of Your Data:
Ad Management Service Providers
Google Ad Manager
Analytics Service Provider
Attribution Service Provider
Period of storing of Personal Data.
Personal Data shall be processed and stored for as long as required by the purpose it has been collected for, but not more than 3 years from the date of last interaction, unless otherwise is derived from the purpose of Data Processing.
The Third party may be allowed to retain Personal Data for a longer period whenever the User has given consent to such Processing, as long as such consent is not withdrawn. Furthermore, the Сontroller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Personal Data concerning children.
Protecting the privacy of young children is especially important to Company. For that reason, Company does not knowingly collect or maintain Personal Data or non-personally identifiable information from underage Users other than as permitted by law in support of our internal operations.
Cross-border Data Transfer.
A Cross-Border Data Transfer may take place if the transfer is necessary for the conclusion or performance of a contract between the Controller and a Third party, where it is in the interests of the Data Subject.
Personal Data may be transferred to: (1) a third country only if a set of conditions are fulfilled; (2) countries whose legal regime is deemed by the European Commission to provide for an "adequate level of Personal Data protection".
You have certain rights with respect to Your Personal Data, including those set forth below.
The Right to Access to Your Personal Data
You have the right to obtain from the Company confirmation as to whether or not Your Personal Data is being processed, and where that is the case, access to Your Personal Data.
The Right to Be Forgotten
You can withdraw Your consent if You believe Your fundamental rights to Data Privacy and protection outweigh Our legitimate interest in continuing the Processing, We may retain an anonymous history of User actions (excluding Personal Data). Within 30 (thirty) days of Your request for deletion of information, the Company deletes all information it possesses about You. If You have any questions, please contact Us at: main @vira.games or relevant Third Party.
The Right to Change Your Personal Data
You can refuse to consent to the collection of Your Personal Data, withdraw Your consent at any time, restrict the Processing of Your Data. You can also ask Us to correct a mistake at Your Data or to erase Your Personal Data from Our Platform if it is no longer necessary for the purpose for which it was submitted.
Right to Request Data, We Have about You
We can provide You with the information We maintain about You. We promise to do Our