Privacy policy

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Privacy policy

Last updated: 3 June 2024

1. Who we are

We are QUMARON SERVICES LIMITED, a company incorporated under the laws of the Republic of Cyprus, registration number HE 348702, registered address at 79 Spyrou Kyprianou Avenue, Protopapas Bldg, 2nd floor, office 201, 3076 Limassol Cyprus.

2. This Privacy Policy

This Privacy Policy sets out how we collect and use your personal information when you use our website as well as products and services (collectively the "Services") offered by QUMARON SERVICES LIMITED and its subsidiaries, through internet-capable hardware platforms including gaming consoles, personal computers, mobile computers, or mobile devices, or in-game applications or software platforms including third-party hosts.

This Privacy Policy should be read alongside, and in addition to, our terms and conditions at https://qumaron.com/terms-of-service/ (Terms) and our Cookie Policy (accessible online at https://qumaron.com/cookie-policy/).

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

3. Information we collect about you

3.1. 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, organize, extract, compare, use, and supplement your data (hereinafter “processing”).

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 to get Services including your email and/or mobile phone number.	We use this information to manage and administer the Services provided to you. We use this data to enable us to fulfill our obligations to you as part of the Services (e.g. in cases where you request restoration of your account) We also use this information to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.	Legitimate interests Performance of our contract with you
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 to verify your account.	We use this data 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
3	Additional data you provide when you edit your profile page or on dedicated Services profile page that may include your first and last name, nickname, gender, date of birth, avatar picture and language preferences.	We use this information to provide our Services to you, to manage and administer Services and as additional information to verify your account to prevent abuse and infringements of your or other persons' rights. We also use this information to provide you with updates and information on our and selected third parties' products and services we think you may be interested in. We use this information to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.	Legitimate interests Performance of our contract with you
4	Additional data received when you access the Services, including information regarding technical devices, technical interaction with the Service such as your IP-address, time of registration in the Service, device ids, country and language settings, device model and operating system used, your installed apps, type of browser, your Internet provider and/or phone network operator, network type, screen resolution, RAM size and your browsing behavior.	We use your data for internal review to constantly improve the content of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalize the use of our Services. We use this information to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.	Legitimate Interests
5	Information that is automatically received at the time of access to the Services 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. We use this information to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.	Consent
6	Information that is created by you while using the Services (if there is such technical possibility in the Services) this information can be available to some or all other users of our Services.	We use this information to manage and administer the Services including providing our services to you.	Legitimate interests, which inter alia, include the processing of manifestly made public by your data where it is accessible by other users of the Services Performance of our contract with you
7	Information that is obtained in your account, such as Information that is received as the result of your behavioral actions when using the Services, that is received as the result of your using payment functionality of the Services (e.g. first and last four digits of your card number that are required to match these details with your account), etc.	We use this information to manage and administer the Services including providing our services to you. We use this information to tailor and improve the adverts that may be presented on the Site and in our others different products and services that you choose to use and measure the effectiveness of these advertisements.	Legitimate interests, which inter alia, include the processing of manifestly made public by your data where it is accessible by other users of the Services Performance of our contract with you
8	Information that is created by you while placing requests to our Services support.	We use this information to verify your identity and to fulfil your support request. We may also use this data to investigate any complaints on your behalf and to provide you with a more efficient service.	Legitimate interests Performance of our contract with you
9	Data collected via third parties, including your social network ids, application store ids, nickname, email and friends list, when you register in our Services via you social or application store accounts and/or connect your social account to our Services (e.g. Facebook, Twitter).	We use this information to manage and administer the Services provide d to you. We use this information for certain social functions of our Services, such as to show you who of your friends play the same game as you. We also use this information to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.	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.

3.6. 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 through our Services.

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

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

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

4. Data sharing and data transfer

4.1. We take technical and organizational measures to ensure that your data is safe. Please note 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 may become available to other Service users and internet users and be copied and/ or disseminated by such users.

4.2. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms.

4.3. We may also share your data with our third-party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by your use of the applications they offer. The developers use the information provided to them to provide you with additional services. Data will only be shared with these developers with your consent.

4.4. Our ad management and recommendation system are 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 or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups, you will receive an advert or recommendation.

4.5. An advertiser or maker of recommendations may also choose to upload a list of emails, 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.

4.6. Our affiliates (including any parent and sister companies) and selected third party partners with our permission, using their own ad servers, can show advertisements to you.

4.7. By default, the data is stored on the servers located in France, but we may need to process your personal data in another country. We use adopted Standard Contractual Clauses for data protection while transfer and storage. However, if a data transfer is required to perform a contract or to provide you services, we have the right to do so without your consent. We want to draw your special attention that we do not sell, rent, or trade your personal data to anyone.

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 our Services.

6. Children’s privacy

We do not and will not knowingly collect personal data from any child under 16 years of age, without additional explicit consent from their parent or guardian.

If you are a parent or guardian and became aware that a child improperly registered on our website or used fake information to use our services or if you are simply concerned about the transfer of personal data about your child, please let us know.

7. Retention Periods

7.1. We'll retain your personal information solely for the duration required to accomplish the objectives laid out in this Privacy Policy. Once your personal data is no longer necessary, we may delete it or render it anonymous.

7.2. Specific storage periods:

We store personal data during the performance of the contract and 24 months after completion.

After the expiration of the specified period, we anonymize the data and store it for statistics and analytics purposes.

We store payment data for 36 months. The data is stored to provide support, for verification of the ownership and for activation of a copy of the game or until you withdraw your consent.

We process data based on your consent during the performance of the contract/ while your interaction with our service and 24 months after or until you withdraw your consent.

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.

(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.

8.2. You also have a right to 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.

8.3. If you would like to exercise these rights, please contact Support Service at https://qumaron.com/support-service/ or write us an email at qumaron.supp@gmail.com or send your request to us, in writing to 79 Spyrou Kyprianou Avenue, Protopapas Bldg, 2nd floor, office 201, 3076 Limassol Cyprus and specify in your request which right you wish to exercise. In order to process your request we must be sure to correctly identify you. For this reason, please provide us with a copy of an official document that can prove your identity. This copy will be safely destroyed within two months of your request being received and closed. We will look into your request and will answer you within 14 days, unless your request requires further investigation. You’ll be specifically informed if that is the case.

If your request was not satisfied, you can file a complaint to the regulatory body, the Office of the Commissioner for Personal Data Protection at P.O.Box 23378, 1682 Nicosia, Cyprus or via email at commissioner@dataprotection.gov.cy

9. Residents Of The European Economic Area, The United Kingdom, and Switzerland

If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

You may have the right to access, correct, or delete personal data we have collected about you. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the “Contact Us” section below to learn more about reaching out to us with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

EEA: https://edpb.europa.eu/about-edpb/board/members_en

UK: https://ico.org.uk/global/contact-us/

Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

10. California Residents

The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

11. Security Measures

11.1. 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.

11.2. Access to the Services 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.

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

11.4. 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.

12. Changes to this Policy

12.1. 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.

13. Contact Us

13.1. If you have any questions, please send your inquiries to Service support https://qumaron.com/support-service/ or in writing to 79 Spyrou Kyprianou Avenue, Protopapas Bldg, 2nd floor, office 201, 3076 Limassol Cyprus. So, we can deal with your enquiry effectively, please quote this Privacy Policy. We will respond to you within 14 days from receipt of request.

13.2. 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.

13.3. The e-mail address of our DPO is qumaron.supp@gmail.com