- When we say ‘we’, ‘us’ or ‘EG’ it’s because that’s who we are and we own and run the Sites.
The type of personal information we collect
4. We collect certain personal information about visitors and users of our Sites.
5. The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transactional details, tax information, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
How we collect personal information
6. We collect personal information directly when you provide it to us.
7. We collect your personal information when you provide it to us when you complete membership registration of the Sites and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
8. Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
A. financial and/or transaction details from payment providers located in the US, in order to process a transaction;
B. third party service providers (like Google, Facebook) who are located in the US or UK, which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service, this only occurs if you are using Branded Mini Games Studio. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider.
How we use personal information
9. We will use your personal information:
A . To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Sites, like where you make payments from our Sites.
B. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
I • operating the Sites;
II • providing you with services described on the Sites;
III • verifying your identity when you sign in to any of our Sites;
IV • responding to support tickets, and helping facilitate the resolution of any disputes;
V • updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites, website disruptions or security updates;
VI • carrying out technical analysis to determine how to improve the Sites and services we provide;
VII • monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
VIII • managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
IX • managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
X • training EG staff about how to best serve our user community;
XI • improving our products and services.
XII • providing general administrative and performance functions and activities; and
XII • processing your job application to EG.
C. Where you give us consent:
providing you with marketing information about products and services which we feel may interest you; and
D. For purposes which are required by law.
E. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
10. We will disclose personal information to the following recipients:
I • companies that are the Emoji Games affiliates which are located in Switzerland, UK, South Korea and Vietnam.
II • subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in Switzerland, UK, Germany ; technical and customer support services which are located in Canada, Singapore, South Korea, Vietnam and Thailand;
III • regulators and government authorities in connection with our compliance procedures and obligations;
IV • a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
V • a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
VI • a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
VII • a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
VIII • other recipients where we are authorised or required by law to do so.
Where we transfer and/or store your personal information
11. We are based in Switzerland, UK, South Korea, Vietnam so your data will be processed in. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based in the places mentioned in the section 10 ii). We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
How we keep your personal information secure
12. We store personal information on secure servers that are managed by us and our service providers. We also separated the location of EU user database in securered server from non-EU database server. We use Amazon cloud based secured server located in Ireland.
How you can access your personal information
13. You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.
Marketing Choices regarding your personal information
14. Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
15. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
Information about children
16. Our Sites are not suitable for children under the age of 16 years, so if you are under 16 we ask that you do not use our Sites . If you are from 16 to 18 years, you can browse the Sites but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
How you can contact us
20. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at Emoji Games GmbH ATTN: Data Protection Officer, Ruessenstrasse 12, 6340 Baar, Switzerland or email to email@example.com
If you’re a user or visitor in the European Economic Area these rights also apply to you:
1. For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
How you can access your personal information
2. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
3. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
4. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
5. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Emoji Games Private Policy V.1, effective date 25 May 2018