PBL BITDOTGAMES PUBLISHING LIMITED PRIVACY POLICY

Last updated: July 9, 2020

1. Who we are

1.1. We are PBL BITDOTGAMES PUBLISHING LIMITED located at 28 Oktovriou, 365 VASHIOTIS SEAFRONT, Flat/Office 402, Neapoli, 3107, Lemesos, Cyprus.

1.2. This Privacy Policy sets out how we collect and use your personal information when you use the mobile games and services("Services") offered by PBL BITDOTGAMES PUBLISHING LIMITED and its subsidiaries, including website https://bit.games (the “Site”), and the choices available to you in connection with our use of your personal information (the Privacy Policy).

This Privacy Policy should be read alongside, and in addition to our Terms of Use (at https://bit.games/en/terms_of_service) (Terms) and our Cookie Policy (accessible online at https://bit.games/en/cookie_policy).

In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

1.3. Please pay your attention that in case of using others different products and services suggested by PBL BITDOTGAMES PUBLISHING LIMITED and/or on the Site, and in case of registration of an “extra” accounts, the certain privacy policies should be applied and accepted by you.

2. This Privacy Policy

2.1. By making available the Services we, acting reasonably and in good faith, believe that you:

(a) have all necessary rights to register on and use the Services;

(b) provide true information about yourself to the extent necessary for use of the Services;

(c) understand that by the posting your personal information, if there is such technical possibility in the Services and where it is accessible by other users of the Services, you have manifestly made this information public, and this information may become available to other Site users and internet users, be copied and disseminated by them;

(d) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.

	Information Collected	Purpose	Legal Basis
1	Data you provide for registering in the Game such as nickname	We use this information in order to manage and administer the Game provided to you. We use this data to enable us to fulfill our obligations to you as part of the Game (e.g. in cases where you request restoration of your login).	Legitimate interests Performance of our contract with you Consent
2	Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and another additional data, with that you may provide us, including through our support service.	We may take additional verification steps where we consider reasonable in order to verify your account. We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.	Legitimate Interests Performance of our con-tract with you Processing is neces-sary for compliance with a legal obligation (e.g. right of access granted by GDPR).
3	Additional data you provide when you edit your Game profile (inter alia any settings) including, if applicable, your first and last name, nickname, gender, date of birth, avatar picture and language preferences.	We use this information in order to provide our Game to you, to manage and administer Game.	Legitimate interests Performance of our contract with you Consent
4	Additional data received when you access the Game, including information regarding technical devices, technical interaction with the Service such as your IP-address, time of registration in the Service, device ids, IDFA, ADFV, country and language settings, device model and operating system used, your installed apps, type of a browser, your Internet provider and/or phone network operator, network type, screen resolution, RAM size.	We use your data for internal review in order to constantly improve the content of our Game and web pages, optimizing your user experience, to understand any errors you may encounter when using the Game, to notify you of changes to the Game and to personalise the use of our Game. We may also use this data in order to tailor and improve the adverts that are presented to you to and measure the effectiveness of these advertisements.	Legitimate Interests Performance of our contract with you
5	Information that is automatically received at the time of access to the Site with the use of cookies.	Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for.	Information that is automatically received at the time of access to the Site with the use of cookies.
6	Information that is created by you while using the Game (including information that you post in any game forums and/or chat rooms). Depending on the place of posting (chat room or forum) this information can be available to some or all other users of our Game.	We use this information in order to manage and administer the Game including providing our Game to you.	Legitimate interests, which inter alia, include the processing of manifestly made public by you data Performance of our contract with you
7	Information that is created by you while placing requests to our Game support.	We use this information in order to verify your identity and to fullfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.	Legitimate interests Performance of our contract with you
8	Information that is received as the result of your behavioral actions when using the Game (including your game actions and achievements, badges). This information can be available to other users of our Game (e.g. on Leaderboards).	We use this information in order to manage and administer the Game including providing our Game to you. We may also use this data in order to tailor and improve the adverts that are presented to you to and measure the effectiveness of these advertisements.	Legitimate interests, which, inter alia, include the processing of data manifestly made public by you, where it is accessible by other users of the Services Performance of our contract with you
9	Information that is received about you as the result of other users’ actions on the Game (in particular, information posted in chat rooms and forums by other users).	We use this information in order to manage and administer the Game including providing our Game to you.	Legitimate interests
10	Information that is received as the result of your using payment functionality of the Game (e.g. first and last four digits of your card number that are required in order to match these details with your account).	We use this information in order to manage and administer the Game including providing our Game to you. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.	Legitimate interests Performance of our contract with you
11	Data obtained via third parties, including your social network ids, application store ids, social network nickname, avatar, email and friends list, when you connect your social account (e.g. Facebook, Google, VK, Apple ID or Apple Game Center) to our Game.	We import this information into your profile. We use this information in order to manage and administer the Game provided to you. We use this information for certain social functions of our Game, such as to show you who of your friends play the same game as you or to provide you the ability to post your achievements into your social account. We also use this information to retain the data about your usage of our Game (such as game progress and achievements) across your different mobile devices, connected to the same social account.	Legitimate interests Performance of our contract with you

3.3. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4. As part of maintaining and administrating the Services we use the information to analyze user activity and ensure that rules and terms of use for the Services are not violated.

3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

We will not delete personal information if it is relevant to an investigation or a dispute.

It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.6. In case you provided us with a consent to the sending of marketing information, You may withdraw your consent to sending you marketing information by amending your privacy settings of your account. An option to unsubscribe will also be included in every SMS or email sent to you by us or our selected third party partners.

3.7. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Site.

Once you have provided this data it will be accessible by other Service users and it becomes difficult for us to remove this data.

3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages.

3.9. If we intend to further process your data for any other purpose besides those set out in this Privacy Policy, we shall provide you with details of these purposes before we commence data processing.

4. Data sharing

4.1. Publicly available data. Your username and other information that you provide or post while using the Services can be available to all users of the Services. We take technical and organisational measures to ensure that your data is safe. Please note, that by posting your personal information in publicly accessible areas (resources accessible by other users of the Services), you have manifestly made this information public, and it may become available to other users of the Services and Internet users and be copied and/ or disseminated by such users. Please keep in mind that once other users have gained access to or copied your data, neither you nor we are able to delete or remove such data from possession of those other users.

4.2. Sharing with third parties. We may share your personal information with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to MGL My.com (Cyprus) Limited, Mail.ru LLC, and our other affiliated entities, as well as our partners, in order to provide you with the Services offered by PBL BITDOTGAMES PUBLISHING LIMITED and its subsidiaries, to administer the Services, for example, if you choose to share your data across other social media platforms, to administer the billing Services or to personalize, adjust and improve our Services or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal information to third parties.

4.3. The transmissions of personal data with the recipients (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure manner and in application of an agreement between us and each recipient as may be necessary under applicable law. We undertake to ensure that each recipient knows the directive principles of personal data protection and submit to them in application of the law and/or of a particular contract.

4.4. Confidentiality obligations. In case we share your data with selected third parties, including our third party contractors and application developers, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use of the Services or applications they offer. The developers use the information provided to them in order to provide you with additional Services, including technical support, if applicable. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.

4.5. Advertising disclaimer. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender, location (country, city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.

4.6. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

4.7. Sharing in the general conduct of business. We may also share your data with MGL My.com (Cyprus) Limited, Mail.ru LLC and our other affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, we may also disclose your personal information to a third party if we decide to transfer a business to that third party, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to our successor or assignee.

4.8. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities in case it is necessary because of your participation in public tournaments. We may also publish your data as part of the tournament score tables on our and third party Websites.

4.9. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of Services provided by us or our affiliates or any applicable law, for the purpose of defence of our rights and interests. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

5. Privacy Settings

5.1. The Services may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party Services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.

5.3. We bear no liability for the consequences of use of the information which, due to the Services nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site or in the Services.

6. International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.

6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

7. Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. You may delete your personal data by removing the data from your account; alternatively, you can delete your account.

7.3. You may request to remove your account and data on our Services by contacting the Services Support (see section 11 for details).

7.4. We may remove your account, or the information you post as provided by the Terms.

8. Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:

(a) Right to access your personal information;

(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing;

(d) Right to request that your personal information is erased if:

- it is no longer required in relation to the purposes for which it was gathered or processed in another way;

- you withdraw your consent concerning processing subject to consent;

- you are justifiably opposed to the processing;

- it has been subject to illicit processing; or

- it is imposed by law.

(e) Right to object to processing of your personal information;

(f) Right to data portability (in certain specific circumstances);

(g) Right not to be subject to an automated decision;

(h) Right to lodge a complaint with a supervisory authority;

(i) For processing based upon your consent, the right withdraw that consent at any time;

(g) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.

8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.fr.

8.3. If you would like to exercise these rights, please contact Support Service at support@bit.games or send your request to us, in writing to 28 Oktovriou, 365 VASHIOTIS SEAFRONT, Flat/Office 402, Neapoli, 3107, Lemesos, Cyprus. We will aim to respond to you within 30 days from the date of receipt of your request. We will need to verify your identity before we are able to disclose any personal data to you.

9. Security Measures

9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9.2. Access to the Game is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

9.3. If you forget your login details, you can request us to send you an email, which will contain a restoration code.

9.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your account.

10. Changes to this Policy

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

11. Contact Us

11.1. If you have any questions, please send your inquiries to Service support at support@bit.games or in writing to 28 Oktovriou, 365 VASHIOTIS SEAFRONT, Flat/Office 402, Neapoli, 3107, Lemesos, Cyprus. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3. The e-mail address of our DPO is legal@bit.games