1. Introduction
1.1. Richman Online Private Limited and its affiliates and related corporations (individually and collectively, the “Company”) takes its responsibilities under applicable privacy laws and regulations (the “Privacy Laws”) seriously and is committed to respecting the privacy rights and concerns of all users of the Company’s games (“Games”), website and mobile applications (collectively, the “Site”) (the Games, Site and the other services referred to in the Terms of Service collectively as the “Services”). Users refers to a user who registers for an account or who otherwise uses or accesses the Services (individually and collectively, “Users”). The Company recognizes the importance of the Personal Information and Sensitive Personal Data and Information (as defined hereinafter) the Users have entrusted to the Company and believe that it is the Company’s responsibility to properly manage, protect and process the Users Personal Information and Sensitive Personal Data and Information. This policy (“Privacy Policy”) is designed to assist the Users in understanding how the Company collects, uses, discloses, transfers and/or processes the Personal Information and Sensitive Personal Data and Information provided to the Company and/or possess, whether now or in the future, as well as to assist the Users in making an informed decision before providing the Company with any personal information.
1.2. Users of the Game and any of its features shall be bound by this Privacy Policy and all its subsequently modified versions.
1.3. Capitalised terms used in this “Privacy Policy” that are not otherwise defined have the meanings given to them in the Company’s Terms of Service (the “Terms of Services”) and Company’s Rules of Conduct (the “Rules of Conduct”).
1.4. “Personal Information” including Sensitive Personal Data or Information (as defined hereinafter) is information through which Users can be directly or indirectly identified, such as their name, e-mail address, information made available on social media, telephone number, password, Services purchased, products purchased, etc. (provided that the Company can connect them to the Users’ email address). It includes limited Personal Information connected with use of the Site e.g. IP address, browser type, operating system, referring domains and exit links.
1.5. “Sensitive Personal Data or Information” means such personal information which consists of information relating to:— (i) password; (ii) financial information such as Bank Account or Credit Card or Debit Card or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011).
1.6. The Company respects the privacy of its Users and is committed to protect its Users’ Personal Information and Sensitive Personal Data or Information in all respects. In this regard, this Privacy Policy describes what information the Company collects at the time of registration or in the future, the purpose, use, disclosure of such information and the reasonable security practices and procedures followed by the Company in respect of Personal Information. This Privacy Policy also explains the Users’ rights regarding their Personal Information and Sensitive Personal Data or Information and assists the Users in making an informed decision before providing such Personal Information and Sensitive Personal Data or Information.
1.7. By using the Services or accessing the Site, Users agree to the terms and conditions of this Privacy Policy. The Users hereby consent to the Company’s use and disclosure of their Personal Information and Sensitive Personal Data and Information in any manner as described in this Privacy Policy. At any time, the Users have the right to not provide the Company certain information, or withdraw their consent with respect to the collection, processing or disclosure of the same. However, please note that in such cases, the Company reserves the right to limit the Services offered to such Users or refuse the provision of such Services in its entirety.
1.8. The Company reserves the right to periodically change the Privacy Policy to incorporate such future changes as may be considered appropriate. Any material changes to the Privacy Policy will be posted on the Site and where appropriate, notified to Users by e-mail.The Users continued use of the Services, including making any purchases or orders after such changes shall constitute their consent to such changes made to this Privacy Policy.
1.9. This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of the Personal Information and Sensitive Personal Data or Information by the Company and is not intended to override those notices or clauses unless the Company state expressly otherwise.
2. Collection Of Personal Information and Sensitive Personal Data or Information
2.1. The Company receives Personal Information and Sensitive Personal Data and Information from the Users including but not limited to the following cases:
2.1.1. Registering an account: The Company stores the information that the Users provide to the Company when Users create an account (“Account”) on the Site or uses the Services. Additionally, the Company collects and stores such information provided by the Users during the Game or while registering for a contest or Game specific events and any additional information Users may voluntarily provide to the Company;
2.1.2. Submission of form: The Company stores any information which the Users provide to the Company when Users submit any form, including but not limited to, application forms or other forms relating to any of the Company’s products and Services, whether online or by way of a physical form. In addition, when the Users enter into any agreement or provide other documentation or information in respect of their interactions with the Company;
2.1.3. Interaction: The Company stores data that the Company collects when the Users interact with the Company via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including interaction with the Company’s customer service agents;
2.1.4. Use of the Site: The Company stores details of any pictures/materials shared by Users for publication on social media and details pertaining to any promotion sponsored by the Company. Additionally, the Company collects and stores details pertaining to Users visits to the Site (such as pages visited) and Users interactions including any e-mails that the Company sends to such Users. For more information, please see Clause 5 (cookies) below.
2.1.5. Permission: The Company stores certain information which the Company collects from the Users’ device when the Users grant permissions on their device to share information with the Game or Site;
2.1.6. Link to Social Media: The Company collects and stores certain information which it collects when the Users’ Account is linked with their social media account (the “Social Media Account”) or other external account or use other social media features, in accordance with the provider’s policies;
2.1.7. Mapping User Journey in the Game: The Company collects certain information while providing the Services to verify Users’ identity, date and type of Service request. The Company collects such information from the transactions made on Games or Site or with the Company’s authorized third-party payment service providers; and
2.1.8. Feedback: The Company collects information pertaining to the Users name, email address and any other media, as provided by the Users during the process of providing feedback.
3. Types of Personal Information and Sensitive Personal Data or Information Collected
3.1. The Personal Information and Sensitive Personal Data and Information collected by the Company includes but is not limited to:
3.1.1. Name, username and user ID;
3.1.2. Contact information (including email address, telephone number, and/or address);
3.1.3. Transaction information, including bank account and payment information where applicable and subject to applicable laws;
3.1.4. Chat details and other information about the people and accounts the Users’ interact with;
3.1.5. Gender, age, and/or date of birth;
3.1.6. Information sent by or associated with the device(s) used to access the Services;
3.1.7. Photographs or audio or video content that the Users submit to use the Services;
3.1.8. Location related information, including IP address;
3.1.9. Government issued identification or other identification the Users share, where applicable;
3.1.10. Marketing and communications data, such as the Users’ preferences in receiving marketing materials, communication preferences and history of communications with the Company and its service providers;
3.1.11. Survey responses, competition, contest or tournament related information, and/or other information provided by the Users to the Company;
3.1.12. Any other information provided by the Users while using the Services, including information shared via any linked Social Media Account; and
3.1.13. Usage and transaction data, including data of the activities, orders, use of the Services and the advertising and other content the Users engage with.
3.2. The Users agrees not to submit any information to the Company which is inaccurate or misleading, and the Users agrees to inform the Company of any inaccuracies or changes to such information. Subject to applicable law, the Company reserves the right at its sole discretion to request for further documentation to verify the information provided by the Users.
3.3. If the Users link their Account to their Social Media Account or use any of the Company’s social media features, the Company may access and use information which the Users have voluntarily provided to their Social Media Account provider in accordance with such provider’s policies, subject to this Privacy Policy.
3.4. If the Users do not wish the Company to collect the information in accordance with Clause 3, the Users may opt out at any time by notifying the Company in writing. For further information on opting out, please see Clause 12 (withdrawal of consent, request access to or update information) below. Please note, that opting out or withdrawing consent for the Company to collect, use or process Personal Information may affect the Users use of the Services and Company’s ability to effectively deliver the Services.
4. Collection Of Other Data:
4.1. The Company collects and stores data pertaining the information sent from the Users’ device which may include data collected by the web server when the Users’ use the Services. This typically includes without limitation: device’s internet protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID), the address of a referring web site (if any) and the pages visited on the Site and the times of visit. For more information, please see Clause 5 (Cookies) below.
4.2. The Site may collect precise information about the location of the Users’ device using technologies such as GPS, Wi-Fi, etc. The Company shall collect, use, disclose and/or process this information for one or more purposes including, without limitation, location-based services requested by the Users or to deliver relevant content based on the Users’ location or to allow the Users to share their location to other Users as part of the Services. For most mobile devices, the Users may be able to withdraw their consent to provide such information through their device settings. Please contact the mobile device service provider or the device manufacturer for clarification on such settings changes.
5. COOKIES
5.1. The Company uses cookies and other technology like pixel tags. Cookies are small files which are sent from the Site and then stored on Users’ devices. Pixel tags, also called web beacons are clear image (i.e. non-visible) files that may be placed on the Site which request information from Users’ devices (collectively, “Cookies”).
5.2. The Company sometimes collects anonymous information from visits to the Site and uses this data to analyse trends and statistics and to help provide better customer service. This anonymous information is sometimes known as “clickstream data”.
5.3. Cookies may be set in Users’ devices when the Users access the Site or may be set when Users visit third-party websites or Site.
5.4. The Company is an authorized service provider and its advertising partners may from time to time implement Cookies or other features to allow the Company or third parties to collect or share information in connection with the use of the Services. These features help the Company improve the Services, offer new services and features, and/or enable the Company’s advertising partners serve more relevant content to the Users, including through remarketing, subject to applicable law.
5.5. Cookies are identifiers transferred to the Users’ computer or mobile device that record data about the Users’ computer or device, how and when the Services or websites are used or visited, by how many people and other activity within the Company’s Site and Games.The Company may link Cookie information to Personal Information and Sensitive Personal Data or Information. Cookies may also link to information regarding the items the Users have selected for purchase, pages the Users have viewed, or games the Users have played. Depending on the relevant Services, this information shall be used to keep track of the Users’ shopping cart, to deliver content specific to the Users’ interests, to enable the Company or its third party advertising partners to serve advertisements through the Services or on sites across the internet, and to monitor usage of the Services.
5.6. If the Users do not wish to accept Cookies or web beacons, Users are free to modify the settings or adjust the same as per the Users’ preferences. However, please note that changing such settings in the Site may affect Users’ experience therein and the Company’s ability to effectively deliver the Services.
5.7. The Users may be able to opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
5.8. Types of Cookies
5.8.1. The Company uses Cookies for different purposes, which can be categorised as follows:
· Required Cookies: These Cookies enable the Users to navigate the Site and use its features, such as accessing secure areas of the Site and using the Company Services. Each time a User logs into the Services, a Cookie containing an encrypted, unique identifier tied to the Users’ Account is placed on the Users’ browser. These Cookies allow the Company to uniquely identify the Users when using the Site and to process the online transactions and requests.
· Functional Cookies: These Cookies are required for the Site to function. They include, for example, Cookies that enable Users to log in. They may also enable the Company to recognise Users when Users return to the Site and store information about Users preferences, so they allow the Company to customise the Site according to individual preferences (such as the language chosen by the Users, changes made to text size and fonts, etc.). the Company uses local shared objects, also known as “Flash” cookies, to store the Users’ preferences or display content based upon what Users view on the Site to personalize Users’ visit.
· Performance Cookies: These Cookies collect information about how the Users use the Site, including which pages the Users go to most often and if they receive error messages from certain pages. These Cookies do not collect information that individually identifies a User. All information these Cookies collect is aggregated and anonymous. It is only used to improve how the Company’s Site functions and performs. From time to time, the Company engage third-parties to track and analyze usage and volume statistical information from individuals who visit the Site. The Company may also utilize “Flash” cookies for these purposes.
· Targeting/Advertising Cookies: The Company may engage third-parties to track and analyze usage and volume statistical information from the Users who visit the Site. The Company may use Cookies delivered by third-parties to track the performance of the Company’s advertisements, such as Google Analytics. For example, these Cookies remember which browsers have visited the Site. The information provided to third-parties does not include Personal Information and Sensitive Personal Data or Information, but this information may be re-associated with Personal Information and Sensitive Personal Data or Information after the Company receive it.
· Analytical Cookies: These Cookies analyse how the Users navigate around the Site (pages visited, links used etc.) or use e-mails the Company sends to the Users. They enable the Company to better understand the interests of the Users and to improve the Site.
· Third-party advertising: The Company uses third-party service providers to display advertisements (banners or links) on behalf of the Company across the internet. These advertising service providers may collect information about visits to the Site and interactions with the Services, as well as User visits to other websites. Such information does not include user names, addresses, e-mail addresses but may contain Site related information.
6. Usage Of The Information:
6.1. The Company may collect, use, disclose and/or process Personal Information and Sensitive Personal Data and Information for one or more of the following purposes (collectively, the “Purposes”):
6.1.1. to consider and/or process the Users application/transaction with the Company or the Users’ transactions or communications with third parties via the Services;
6.1.2. to manage, operate, provide and/or administer the Users’ use of and/or access to the Services (including, without limitation, Users preferences), as well as the Users’ relationship and Account with the Company;
6.1.3. to respond to, process, deal with or complete a transaction and/or to fulfil Users’ requests for certain products and Services and notify the Users of Service issues and unusual Account actions;
6.1.4. to enforce the Terms of Service or any applicable end user license agreements;
6.1.5. to protect personal safety and the rights, property or safety of others;
6.1.6. for identification and/or verification;
6.1.7. to maintain, administer and improve any software updates and/or other updates, to support the Services, including troubleshooting, reporting or addressing any issues (e.g., to respond to errors or crash reports) that may be required from time to time to ensure the smooth running of the Services;
6.1.8. to deal with or facilitate customer service, carry out the Users’ instructions, deal with or respond to any enquiries given by (or purported to be given by) or on behalf of the Users;
6.1.9. to contact or communicate with the Users via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing the Users’ relationship with the Company or usage of the Services, such as but not limited to communicating administrative information to the Users relating to the Services. The Users acknowledge and agree that such communication could be by way of the mailing of correspondence, documents or notices, which could involve disclosure of certain personal information to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
6.1.10. to allow other users to interact, communicate, or connect with other Users, to notify the Users when other Users have sent a private message or posted a comment for the Users via the Games or Site;
6.1.11. to conduct research, analyse and for development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse the usage the Services, to improve the Services or products and/or to enhance customer experience;
6.1.12. to allow for advertising and other audits and surveys (via offline and online surveys, including on third parties platforms (e.g. Google Forms), among other things, validate the size and composition of the Company target audience, and understand their experience with the Services;
6.1.13. for marketing and advertising permissible under applicable law, and in this regard, to recommend products and/or services relevant to the Users’ interests, notifying the Users by various mediums and modes (including email or SMS) of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties with whom the Company may collaborate or tie up with) that the Company may be selling, marketing or promoting, whether such products or services exist now or are created in the future. The Users can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. The Company may use the Users contact information to send newsletters or marketing materials;
6.1.14. to respond to legal proceedings or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on the Company;
6.1.15. to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
6.1.16. to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or the Company’s risk management procedures that may be required by law or as per the Company’s policies;
6.1.17. to audit the Services or the Company's business;
6.1.18. to prevent or investigate any actual or suspected violations of the Terms of Service, fraudulent or unlawful activity, omission or misconduct, whether relating to the usage of the Services or any other matter arising from the Users relationship with the Company;
6.1.19. to store, host, back up (whether for disaster recovery or otherwise) of Personal Information, whether within or outside of the Users’ jurisdiction;
6.1.20. to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves the Company or a third party as a participant. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal, transfer of or financing of an organisation or a portion of an organisation or of a portion of or all of any of the business, business activities, or assets of an organisation;
6.1.21. to verify the Users’ qualification and/or to submit the Users’ application/request when the Users register for participation in the game specific contests, events or tournaments, and to give rewards where applicable;
6.1.22. to protect the security or integrity of the Site and the Company’s business;
6.1.23. to help learn more about the Users’ preferences (to enable the personalisation of the Site or any offers according to Users interest and preference), to help address problems with and improve the Site, to analyse trends and statistics, interact with banks and financial institutions and to present content with the most clarity and usability; and
6.1.24. other purposes which are permissible under applicable law and which the Company shall notify the Users at the time of obtaining consent.
6.2. The Users acknowledge, consent and agree that the Company may access, preserve and disclose Account information and content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over the Company or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over the Company, (c) enforce the Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against the Company or other claim that any Content violates the rights of third parties; (e) respond to the requests for customer service; or (f) protect the rights, property or personal safety of the Company, Users and/or the public.
6.3. As the purposes for which the Company may collect, use, disclose or process Personal Information depend on the circumstances at hand, such purpose may not appear above. However, the Company shall notify the Users of such other purpose at the time of obtaining consent, unless processing of the applicable data without consent is permitted by the Privacy Laws.
7. Protection and Retention of Information
7.1. The Company implements a variety of security measures and operational controls, and strive to ensure the security, integrity and privacy of Users’ Personal Information and Sensitive Personal Data or Information and to protect Personal Information against unauthorised access, use, disclosure, alteration or destruction stored. The Company’s databases are stored on servers secured behind a firewall; access to such servers being password-protected and strictly limited based on a need-to-know basis. However, the Company understands that no security system is impenetrable and does not guarantee of security of its database, and as such disclaims all responsibility for any breach of security or any action of any third-parties that are receiving Users’ Personal Information and Sensitive Personal Data or Information.
7.2. The Company retains Personal Information and Sensitive Personal Data and Information in accordance with the Privacy Laws and/or other applicable laws. That is, the Company shall destroy or anonymize Personal Information when it is reasonably determined that: (i) the purpose for which that Personal Information was collected is no longer being served by the retention of such information; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such Personal Information. If the Users cease using the Services, or permission to use the Services is terminated or withdrawn, the Company may continue storing, using and/or disclosing Personal Information and Sensitive Personal Data and Information in accordance with this Privacy Policy and the Company obligations under the Privacy Laws. Subject to applicable law, the Company may securely dispose the Personal Information and Sensitive Personal Data and Information without prior notice to the Users.
8. Disclosure and Sharing Of Information:
8.1. The Company shall disclose the Personal Information and Sensitive Personal Data or Information to third party service providers, agents and/or other third parties, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing the Personal Information and Sensitive Personal Data and Information either on the Company’s behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
8.1.1. the Company's subsidiaries;
8.1.2. other users of our Services in connection with the usage of the Services and for one or more of the above-stated Purposes;
8.1.3. contractors, agents, service providers and other third parties in connection with the Company. These include but are not limited to those which provide administrative or other services to the Company such as mailing houses, game development partners, payment or financial services providers, advertising and marketing partners, telecommunication companies, game development partners, information technology companies, and data centres;
8.1.4. governmental or regulatory authorities having jurisdiction over the Company or as otherwise permitted under Clause 6.2;
8.1.5. a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, or transition of any of the Services, in which Personal Information and Sensitive Personal Data or Information held by the Company is among the assets transferred; or to a counterparty in a business asset transaction that the Company is involved in, including any entity which succeeds or to which the Company transfer the operation of the Services; and
8.1.6. third parties to whom disclosure by the Company is for one or more of the Purposes and such third parties would in turn be collecting and processing the Personal Information for one or more of the Purposes.
8.2. The Company may, among other things, disclose the Users’ gaming history and/or disclosing records showing which games were viewed or accessed by which IP addresses. The Company may also share statistical and demographic information of the Users and their use of the Services with advertising partners and third party suppliers of advertisements, remarketing, and other programming subject to the applicable law.
8.3. Additionally, the Users may elect to export their user activity feeds as RSS feeds which may be subscribed to by other Users, which may include information regarding game play, installation of games, connections with other users and other information about the Users account activity which is published as a feed on the Site or Games.
8.4. For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as the Company to collect, use or disclose Personal Information without the Users’ consent, such permission granted by the laws shall continue to apply.
8.5. Third parties may unlawfully intercept or access Personal Information and Sensitive Personal Data or Information transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of the Company. The Company will nevertheless deploy reasonable security arrangements to protect the Users’ Personal Information and Sensitive Personal Data and Information as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of the Company. For more information, please see the Company’s policy on protection and retention of information above.
8.6. In compliance with the Privacy Laws, the Company will take reasonable steps to ensure that all dealings in Personal Information and Sensitive Personal Data or Information, shall be:
8.6.1. processed lawfully, fairly and in a transparent manner;
8.6.2. obtained only with the consent of the information provider;
8.6.3. available for review by the information provider, as and when requested;
8.6.4. kept secure against unauthorized or unlawful processing and against accidental loss, destruction or damage, as per the prescribed standards;
8.6.5. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; and
8.6.6. collected, only when:
· the information is collected for a lawful purpose connected with a function or activity of the Company; and
· the collection of the sensitive personal data or information is considered necessary for that purpose.
9. Information Collected By Third Parties
9.1. The Site and Games use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on the Users device, to help the website analyse how Users use the Services. The information generated by the cookie about the usage of the Services or device (including IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating the Users use of the Services, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate the Users’ IP address with any other data held by Google.
9.2. The Company and third parties may from time to time make software applications downloads available for the Users usage on or through the Services. These applications may separately access, and allow a third party to view, the Users identifiable information, such as name, User ID, device’s IP Address or other information such as what game played during any given session, and any cookies that the Users may previously have installed or that were installed for the Users by a third party software application or website. Additionally, these applications may ask the Users to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by the Company. The Users are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
10. Disclaimer Regarding Security And Third Party Sites
10.1. The Company does not guarantee the security of Personal Information and Sensitive Personal Data and Information and/or other information that the Users provide on third party sites. The Company has implemented a variety of security measures to maintain the safety of Personal Information and Sensitive Personal Data or Information that is in the Company’s possession or control. Personal Information and Sensitive Personal Data and Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the Personal Information and Sensitive Personal Data or Information confidential. When the Users place orders or access Personal Information and Sensitive Personal Data or Information, the Company offer the use of a secure server. All Personal Information and Sensitive Personal Data or Information or sensitive information the Users supply is encrypted into the Company’s databases to be only accessed as stated above.
10.2. To provide the Users with increased value, the Company may choose various third party websites to link to, and frame within, the Site or Games. The Company may also participate in co-branding and other relationships to offer e-commerce and other services and features to the visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with the Company, the Company shall have no control over these linked sites, as each of which has separate privacy and data collection practices independent of the Company. Data collected by the Company’s co-brand partners or third party web sites (even if offered on or through the Site or Games) may not be received by the Company.
10.3. The Company therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for the Users’ convenience and therefore the Users can access them at their own risk. Nonetheless, the Company seeks to protect the integrity of the Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
11. Transfer Of Information Overseas
11.1. The Users Personal Information and/or other information may be transferred to, stored or processed outside of the Users’ country. The Company shall only transfer such information overseas in accordance with Privacy Laws and this Privacy Policy. By accepting this Policy, the Users agree to the cross-border transfer of such information to where the Company’s developers, servers and/or databases are located. As different jurisdictions may have different data protection requirements, the Company shall take steps to implement adequate safeguards to protect the Personal Information and Sensitive Personal Data or Information transferred, stored or processed outside of the Users’ country.
11.2. The Company shall transfer Personal Information and Sensitive Personal Data or Information or sensitive Personal Information and Sensitive Personal Data or Information to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by the Company as provided for under Privacy Laws. The transfer may be allowed only if it is necessary for the performance of the lawful contract between the body corporate or any person on its behalf and the Company or where the Users have consented to data transfer.
11.3. The Company shall transfer such information overseas in accordance with Privacy Laws, and the Users hereby consent to such transfer and processing.
12. Withdrawal Of Consent, Request Access To Or Update Information
12.1. Withdrawing Consent:
12.1.1. The Users may withdraw their consent for the collection, use and/or disclosure and/or request deletion of their Personal Information in the possession or control of the Company, by sending an email to the Company at richman_service@gamebase.com.tw. The Company shall process such requests in accordance with this Privacy Policy and the Company’s obligations under applicable Privacy Laws and other applicable laws.
12.1.2. However, the Users withdrawal of consent and/or request to delete Personal Information and Sensitive Personal Data and Information in the Company’s possession or control may mean that the Company may not be able to continue providing the Services, and may need to terminate the Users existing relationship and/or the contract with the Company.
12.2. Requesting Access to, or Correction of Personal Information and Sensitive Personal Data or Information
12.2.1. The Company will need enough information from the Users in order to ascertain identity as well as the nature of request so as to be able to deal with the request. Please submit the written request by sending an email to the Company. In addition, where required by law, the Company will take steps to inform any third parties who have received or used Personal Information of such correction.
12.2.2. Where permitted under applicable law, the Company reserves the right to reject certain requests and/or may charge a reasonable fee for the handling and processing of the request to access Personal Information. In such cases, the Company shall inform the Users and will provide a written estimate of any applicable fees. Subject to applicable law, the Company will provide the Users the requested Personal Information within a reasonable time after the payment of the applicable fees.
12.2.3. Please submit the written request by sending an email to the Company. Subject to applicable law, the Company reserves the right to only respond to data subject requests submitted in accordance with this Privacy Policy.
13. Access to/ Updating Personal Information and Sensitive Personal Data or Information
13.1. The Users may contact richman_service@gamebase.com.tw., in order to view and change the Personal Information and Sensitive Personal Data or Information provided within the Site. The Users may also ask to erase, restrict or port their Personal Information and Sensitive Personal Data or Information and further intimate objections, if any, to use of Users’ Personal Information and Sensitive Personal Data or Information by the Company. Additionally, Users may access information the Company holds about Users, and request a correction where data is incorrect or a deletion of the data, unless the Company has to retain the data for legal reasons.
13.2. Users are solely responsible for the accuracy of the Personal Information and Sensitive Personal Data or Information provided, and for any changes, updates or modifications to such information.
14. CONTACT US
14.1. Any questions, clarification, issues or grievance in relation to the collection and processing of the Personal Information or with respect to this Privacy Policy, the Users may reach out to the Company at:
richman_service@gamebase.com.tw.
The Company shall respond to the concerns and queries at the earliest and in compliance with applicable law. For more information on grievance redressal mechanism, please see the Terms of Services of this Site.
SITE DISCLAIMER
By continuing to access this Site, the Users hereby confirm that the Users has read and understood the latest versions of the Privacy Policy and the Terms of Service and confirm unconditional acceptance of the same.