PRIVACY POLICY

(Last updated on July 22, 2019) External Games is committed to protecting the privacy of its users (“users” or “you”). This Privacy Policy has been created to inform you about how External Games manages, collects, stores and uses the information you provide in connection with any External Games game or application (“Service”). Please note that the scope of this Privacy Policy is limited only to information collected by External Games through your use of a Service. By using the Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy. External Games may amend the Privacy Policy from time to time, and External Games encourages you to consult the Privacy Policy regularly for changes.

1. Scope

1.1. This Privacy Policy (hereafter - Policy) shall govern any interaction between External Games and users related to personal data when using the Service.
1.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Service.
1.3. Please do not use the Service if you do not agree with the provisions and scope hereof.

2. Who determines the purposes and means of personal data collection?

2.1. The purposes and means of how your personal data is collected while using the Service are determined by the following entity:
External Games
40 Kimonos Street, Limassol, 3095, Cyprus
email: external.games@externalgames.com
tel.: +375 29 775-17-77

3. Personal data we collect

3.1. Personal data are any information relating to an identified or identifiable natural person.
3.2. The personal data types collected in accordance with a Service may vary depending on the activity and may include: (1) your Facebook ID; (2) your Facebook public profile and its information (friends, shares, etc.); (3) your purchases in a Service; (4) your gender and age; (5) your interest category (e.g. sports/electronics/food/travel); (6) your location and language; (7) your network operator; (8) your device unique identifier and model; (9) calendar; (10) email address. The Service may also record game play information such as your game session duration or your high scores.
3.3. Please note, that despite possible collection of the information concerning your purchases External Games does not have access to your credit card details or billing information because the purchases of virtual goods offered by the Service are managed by a third party site.
3.4. In addition to information collected as described above, you may choose to share additional information about yourself throughout the Service, such as on message boards and in games. Any actions you perform with other players are considered public, and are in your sole discretion.

4. Data Processing, Storage and Protection

4.1. “Processing” is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
4.2. In accordance herewith, personal data may be collected both directly and indirectly.Personal data are collected directly when you provide them voluntarily, e.g. when using the Services. You may agree to or refuse the said collection, processing and storage of your personal data. Indirect collection of personal data may occur automatically when accessing the Services, including through cookies.
4.3. We process your personal data to fulfill your specific requests, purchase orders and to send you purchase confirmation and other account-related information.
4.4. External Games may also process your personal data to better understand the behavior and preferences of its customers, to troubleshoot technical problems, to serve static and dynamic advertising, to enforce its Terms of Service, to ensure proper functioning of its products and services as well as to help improve Services and their content.
4.5. External Games may process your personal data such as an email address, to administer loyalty programs, tailor its offerings, web pages or game play experience to you.
4.6. By use of friend finder tools whether directly through the Service or through a social network or gaming service, you acknowledge that use of these friend finder tools will help you find your contacts and will also allow your contacts to associate your Service account (and related gaming entitlements, including games played) with your social networking profile and/or email address. Your resulting friends’ list will be subject to this Policy. If you choose to use a referral service to “tell a friend” about a Service, External Games may ask you for your friend’s name and email address. External Games will send your friend an email on your behalf or a text message inviting him or her to visit the relevant site or check out the Service. External Games stores your friend’s name and email for a short period for the sole purpose of sending this email and for redundancy checking, to be sure that your friend does not receive multiple copies of the same email message. External Games does not keep or use this information for any other purpose.
4.7. If you enter into a sweepstake, contest, or similar promotion, External Games may use the information you provide to administer those programs. Your participation in tournaments or other online game events is conditional upon you granting External Games permission to collect, use, store, transmit and display publicly statistical data, such as your scores, rankings and achievements, generated through your participation. In all cases of data access and collection, the information you provide will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose of providing you with and improving the Service and for any other purpose stated herein.
4.8. We consider all our purposes for personal data processing as our legitimate interest.
4.9. Subject to data anonymisation, your personal data may be used by External Games for any other purposes.
4.10. External Games will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that External Games no longer use your information contact External Games at the email address provided in the Contact Us section below. Note that there may be instances where External Games is legally required to retain your information.
4.11. Any personal data collected and processed hereunder shall be properly protected unless:
(1) you consent to their disclosure;
(2) such personal data are anonymised;
(3) such personal data are subject to disclosure under the applicable law.
4.12. We also guarantee that your personal data shall be used only for the purposes and time set hereunder and our employees and counterparties are aware of the security and privacy recommendations and shall comply with them.
4.13. External Games has made reasonable technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration or disclosure. However, External Games cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal data for improper purposes. Also please note that email and messaging systems are not considered secure, so External Games discourages you from sending External Games personal data through these media.

5. Transfer and Disclosure

5.1. External Games may employ third party companies and individuals to facilitate its Services, to provide the Services on its behalf, to perform tasks (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services) or to assist External Games in analyzing how its Services are used.
5.2. External Games may ask some third party contractors, such as credit agencies, data analytics or market research firms, to supplement personal data that you provide to External Games for marketing and demographic studies, so that External Games can consistently improve its sites and related advertising to better meet its visitors’ needs and preferences. To enrich its understanding of individual customers, External Games may tie these data to the data you provide to it.
5.3. In the event of cross-border transfer of your personal data received from the European Union to a jurisdiction not recognised by the European Commission as having an adequate level of personal data protection, we will sign data processing agreements that will include provisions that are recognised by the decisions of the European Commission as adequate for the purposes of personal data protection (EU Commission adequacy decisions).
5.4. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of External Games and third parties or for substantial public interest purposes.
5.5. To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of External Games should it be necessary. Reorganization includes at least merger, acquisition or sale of assets. The provisions of this point also apply in the event of bankruptcy.
5.6. Note that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. External Games has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

6. Children's Personal Data

6.1. To the extent to which it is not prohibited by the applicable law, we do not authorise the use of our Services by individuals who have not reached the age of legal capacity to enter agreements such as our Terms of Service in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.

7. Cookies

7.1. Like many websites, External Games may use “cookies” to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes.
7.2. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal data for purposes such as improving the quality of External Games’s service, tailoring recommendations to interests, and making the Service easier to use.
7.3. Third party advertisers on the Services may also place or read cookies on your browser. Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
7.4. If you do not accept cookies, however, you may not be able to use all portions or functionalities of a Service.

8. User Rights

8.1. The rights of users related to the collection and processing of personal data shall be determined in accordance with the applicable law.
8.2. In accordance with the applicable law you may:
(1) access your personal data;
(2) rectify personal data if necessary;
(3) erase your personal data. If you withdraw your consent, you may also request deletion of all your personal data from us. However, in this case, we may continue processing your personal data if required by applicable law and (or) any other legal obligations assumed by us;
(4) restrict the processing of your personal data in cases where: you dispute the accuracy of the personal data collected (for the period necessary to confirm the validity of such personal data); you claim to restrict illegal processing; you need your personal data for settlement of your legal dispute provided that we no longer need your personal data for the purposes specified herein; or you wait for the evidence that our legal grounds for personal data processing prevail over yours;
(5) receive your personal data, in particular, to obtain your personal data in structured (common machine-readable) format and transfer them to another party who determines the purposes and methods of processing where technically feasible;
(6) object to the processing of your personal data in case there are sufficient legal grounds for such processing. However, we may reject your objection to processing if we have sufficient evidence that our legal grounds for the processing prevail over yours;
(7) lodge a complaint with a supervisory authority.
8.3. You may review, update, correct or delete any personal data by changing the applicable information in your profile page. If you completely delete all of this information, your account may be deactivated.
8.4. If you would like External Games to delete your record in its system, please contact External Games and it will attempt to accommodate your request if it is not legally obligated to retain the record.
8.5. If you have granted External Games access to your Account Information through a Service, you may request that External Games delete your Account Information by following the directions available at http://www.facebook.com/settings/?tab=privacy. You can request deletion of your Account Information by dissociating or removing the External Games application from your social network or third party service account in accordance with the instructions provided by the social network or third party service.
8.6. External Games reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.

9. Final Provisions

9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, the new version of the Policy and date of its adoption will be published. The user of the Services must read and acknowledge the new version hereof.
9.2. The Policy is an agreement between us and the User on the subject of your use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby cancelled.
9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
9.5. The applicable law is the law of the Republic of Cyprus. The competent court at the location of External Games has the exclusive jurisdiction over all disagreements and disputes arising out of or in connection with the Policy.