Welcome to Arena of Valor!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the mobile game Arena of Valor and its website (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are accepting our rules regarding your personal information as described in this Privacy Policy.

This Service is operated by Proxima Beta Pte. Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

The registered address of Proxima Beta Pte. Limited is 10 Anson Road, #21-07 International Plaza, Singapore (079903).

Our representative in the EU for the purpose of EU data protection laws is Proxima Beta Europe B.V., which is a Dutch company within our corporate group. The registered address of Proxima Beta Europe B.V. is Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands and can be contacted at dpo@proximabeta.com. Our data protection officer can be contacted at dpo@proximabeta.com.

Our data protection officer can be contacted at dpo@proximabeta.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands	dpo@proximabeta.com
UK	Image Frame Investment (UK) Limited	Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB	dpo@proximabeta.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Turkey	Özdağıstanli Ekici Avukatlık Ortaklığı.	Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey	turkeydatarep_proximabeta@iptech-legal.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at dpo@proximabeta.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

Account registration information: You give us your nickname when you log-in as a ‘guest’ in order to use the Service. If you login via your Google Play account, you give us your Google ID and Google display name. If you login via your Apple (iOS game centre) account, you give us your Apple ID, Apple display name and profile picture. If you login via your Facebook account, you give us your Facebook username and ID and you may choose to give us your email address and friends list as well. You may also choose to provide your gender during account registration.
Survey information (aggregated data): If you choose to participate in a survey about the Service, you may be asked to provide certain personal information, e.g. your age, gender, email, address, phone number geographic (country) location, game information (game habits and preferences) and any other content you choose to provide as part of the survey response. We will use your survey response the purpose of improving the Service. In such case, your personal data will be processed in accordance with iMUR’s privacy policy. We will only process your aggregated information which we receive from the iMUR platform once you complete the survey and for the purpose of improving the Service.
Marketing information: Advertising information about you that we collect directly from you and from third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer), such as your IP address, IDFA, Android advertising ID (AAID), which users click/view our campaign and creative materials, e.g. photos and videos that are advertised on the ad partner’s platform, your advertising ID and other user engagement data (purchase behaviour and in-app behaviour) (collectively, “advertising identifiers”), Facebook campaign ID, user search terms and Google Adwords campaign information and identifiers. We also collect certain advertising information about you which we share with third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer) to monitor the success of our advertising campaigns, such as your advertising identifiers, user in-game activities (including login, purchase activities, friends invited and user retention) and other tracking information (mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website / app).
Forum (website only) information: If you choose to use and post on a forum, your username, password, email address and the content of your forum posts and messages.

2. Information about you generated as part of the Service

We automatically collect certain data from you when you use the Service, namely:

IP address and open ID to facilitate account registration;

game data and log information: open ID, IP address, device model, geographic ranking based on your selected country location and information regarding your use of the Service, such as gameplay statistics (e.g. level, heroes and scores);

GPS information to enable you to find users near you;

game analytics information: your user region and device information to enable us to perform overall game analytics, including error fixing, troubleshooting and debugging;
transaction records: when you make purchases within the Service, your Open ID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to your player ID;
your text and audio chat data when you communicate with other users in the Service; and
for the purposes of providing customer support (in-app or via email): name, open ID, device ID, application version, battery level, WiFi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate your problem;
for the purposes of sending you push notifications while using the Service: your device model, device name, device manufacturer, running process information, SDK version, application package name, application version, operator name and network type; and
security information: your device (iOS or Android)’s technical device information, for the purposes of detecting and preventing cheating and any domain name hijacking on the Service.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here [LW1].

Children

Our Service is not intended for children. Children must not use the Service for any purpose.

By children, we mean users under the age of 13 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries, we have listed the relevant minimum age in the table below.

Country in which the user is located	Minimum age of the user
Algeria	19
Argentina	13
Australia	18
Brazil	18
Bangladesh	18
Colombia	18
Cambodia	18
Canada	13
Egypt	18
European Economic Area/Switzerland	16
Kingdom of Saudi Arabia	15
Kuwait	21
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Qatar	18
Russia	14
Serbia	15
South Africa	18
Sri Lanka	18
Tunisia	18
Turkey	18
United Arab Emirates	21
United Kingdom	13
United States	13

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo@proximabeta.com and we will delete such information.

2. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area, United Kingdom, Switzerland, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis ( only relevant if you are located in a Relevant Jurisdiction)
Information you provide to us (either directly or through a third party).
Nickname	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Google Play Login: Google ID and Google display name	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Apple Login: Apple ID, Apple display name and profile picture	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Facebook Login: Facebook username and ID. You may also choose to provide your Facebook friends list (name of friends who you have found and added) and email address (optional).	We use this information to create your account for the Service in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Gender (if you elect to provide this information)	We only receive this information if you voluntarily provide it. It is used in order to customise gameplay.	Necessary to perform our contract with you to provide the Service with customised gender-specific features.
Survey information (aggregated data): age, gender, email, address, geographic location (country), phone model, device configuration preference, game habits and preferences (including recently played games, game duration and favourite game categories and experience, language preference and any other content you choose to provide as part of the survey. These will be processed and stored by us as aggregated data containing no personal information.	We use this information to better understand our users and to improve the Service.	We collect this information with your consent.
Marketing data: data collected from you: IP address, IDFA and advertising ID; data collected from third party ad partners (Facebook, Google, Apple Search Ads, Twitter, Snapchat) via a third party SDK (Appsflyer): which users click/view campaign and creative materials (e.g. screenshots, videos) of our ads, such as photos and videos, that are advertised on the ad partner’s platform; device information (advertising ID, AAID) and other user engagement data (purchase behaviour, in-app behaviour)); Facebook campaign ID (where data is collected from Facebook); and user search terms and Google Adwords campaign information and identifiers (where data is collected from Google). data collected by us and shared with third party ad partners via a third party SDK (Appsflyer): device information (advertising ID and Facebook ID); user in-game activities, including login, purchase activities, friends invited and user retention; and Appsflyer’s tracking information, such as, mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website / app.	If you click on a link or interact with content that advertises the Service, we store this information and that advertisement and certain marketing analytics data with your profile in order to measure the performance of our advertisements.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Forum (website) information: username, password, email address and the content of your forum posts and messages	We use this information to allow you to use the forum feature and to post content on the forum.	Necessary to perform our contract with you to provide the Service.
Information generated as part of the Service
IP address and open ID	We use this information to facilitate your account registration.	Necessary to perform our contract with you to provide the Service.
Game data and log information: open ID, IP address, device model, geographic ranking based on your selected country location and information regarding your use of the Service, such as gameplay statistics (e.g. level, heroes and scores)	We use this information to provide you with feedback and information about your gameplay and progress.	Necessary to perform our contract with you to provide the Service.
GPS information	We use this information to allow you to connect with users nearby your location. Your GPS information is not shared with other users.	Necessary to perform our contract with you to provide location based services to you as part of the Service.
Game analytics information: User region information (country, province, city, carrier id, region, IP address) Device information (application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, IDFV, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Google advertising ID, IDFA, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information), XWID	We use this information to: conduct general game analytics to improve our Service; reviewing game performance and payments; ensure smooth gameplay; and provide troubleshooting, such as addressing and remediating technical issues, error fixing and debugging.	Google advertising ID and IDFA: It is in our legitimate interests to monitor the success of our advertising and marketing programs. Other game analytics information: Necessary to perform our contract with you to provide the Service.
Transaction records (in-app): your open ID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to your player ID	We use this information to facilitate your payment and maintain a record of your transaction history.	Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.
Chat text data: your chat contents (this is stored locally on your device and processed momentarily by our servers)	We facilitate the posting of your text chat communications with other users.	Necessary to perform our contract with you to provide the Service where you seek to use chat services.
Audio chat data: voice message data; device information (device OS version, device manufacturer, RAM, system time, device model, device name, CPU model, network type, IP address); log file and reporting data (open ID, room ID, SDK version, GME chat room status, packet loss rate)	We facilitate your audio communications with other users.	Necessary to perform our contract with you to provide the Service where you seek to use chat services.
Customer support information: name, open ID, device ID, application version, battery level, WiFi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate your problem.	We use this information to provide you with customer service support, whether in-app or via email, in accordance with your request.	Necessary to perform our contract with you to provide the Service.
Push Notification information: device information (device model, device name, device manufacturer, running process information); and other information (SDK version, application package name, application version, operator name, network type)	We use this information to send you push notifications about announcements, updates or information relating to the Service.	Necessary to perform our contract with you to provide the Service.
Security information: Android: device root status, list of installed hack software, list of running hack software, hash values of game files (encrypted), host file tampered, running in Android simulator, Android SDK API Level, equipment boot time, equipment brand and model, CPU structure and CPU model, resolution, Sensor status, device kernel version, country code, language, available memory and available space, internet type (WiFi/4G/3G) iOS: device jailbreaking status, hash values of game files (encrypted), host file tampered, IDFV, equipment brand and model, iOS version, Internet type (WiFi/4G/3G)	We use this information to detect and prevent cheating and any domain name hijacking on the Service.	It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Service.

3. How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Service are located in:

Brazil
Germany
Singapore
United States
Russia
India

Marketing data about you that is collected or shared with third party ad partners (e.g. Facebook and Google) may also be stored and processed on our third party SDK’s (Appsflyer) servers in the United States, Belgium and Ireland. Customer support information may also be stored in our third party partner (AIHelp)’s servers in the United States.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, to allow you to login through an existing social network account (e.g. Google Play), and for the purpose of providing marketing and advertisements on ad partners’ platforms ( Facebook, Google, Apple, Twitter, Snapchat and Appsflyer) and monitor the success of our marketing and advertising programs on such platforms. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
Companies within our corporate group who process your personal information in order to operate the Service and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission of your information which you do at your own risk.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

5. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Nickname Google Play, Apple, Facebook login Gender IP address and open ID Game analytics information Transaction records Push notification information Forum (website) information	Stored for the lifetime of your use of the Service. Data will be deleted manually upon your request within 30 days from receipt of the request.
Survey information (aggregated data)	Stored for 1 year from collection, after which it will be deleted.
Game data and log information	Stored for either (i) the lifetime of your use of the Service and data will be deleted manually upon your request within 30 days from receipt of the request; or (ii) three months, whichever is earlier.
GPS information	Deleted after you log out.
Chat text data and audio chat data (except device information and log file and reporting data)	We do not store this on our servers. This is only processed momentarily by us to deliver the Service.
Audio chat data (device information and log file and reporting data)	Stored for 90 days.
Customer support information	Stored for 2 years unless user requests for account deletion, in which case deletion will be made within 30 days upon such request
Security information	Stored for 1 month
Marketing data	Stored for 30 days unless user requests for account deletion, in which case deletion will be made within 7 days upon such request.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., game play statistics), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@proximabeta.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at dpo@proximabeta.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo@proximabeta.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend the Service’s access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

7. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy, we will post the updated policy here and notify our users within the Service. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

9. LANGUAGE

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you, in addition to the terms set out in our Privacy Policy above.

Algeria

By using this Service, the user gives his/her consent for the collection, the storage, the treatment, the use, the transfer of your personal information to a third party (local cloud providers or to back up your data or our affiliates around the world to help us to deliver the Service) located in Singapore, the United States, Belgium and Ireland (as detailed in the Privacy Policy), where it is manually and electronically treated.

Argentina

Your rights

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Access

Correction

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-game purchases.

Your rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorize us to collect, use, store, and process your personal data, including, disclosing to third parties, to the extent provided by this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, India, the United States, Belgium and Ireland.

Age Restriction

In order to use the Service, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

This section applies to users located in Brazil:

Language

This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact dpo@proximabeta.com. This may affect our provision of the Service to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

Identifiers, such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and other device information as described in the main policy. This information is collected directly from you and your device.
Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
Geolocation data such as your GPS information if you use location based services. This information is collected directly from you.
Audio and visual information such as your social media profile picture and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
Other information described in subdivision (e) of Section 1798.80, including information about your gender. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

To provide you the Service, including offering the Service, maintaining your account, processing payments, and delivering audio and text messages;
To process surveys;
To improve our services, including the functionality of the Service;
For security and verification purposes, including to prevent and detect fraudulent activity;
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

We disclose personal information to the following types of entities:

Other companies within our corporate group who process your personal information in order to operate the Service
Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us
Regulators and judicial authorities and law enforcement agencies
Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at dpo@proximabeta.com.

Canada

If a user located in Canada wishes to obtain written information about our policies and practices with respect to our service providers located outside Canada, they may contact us at dpo@proximabeta.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Colombia

Language

This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy.

Proceedings For The Exercise Of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us.

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.

Egypt

This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Service.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular Singapore, India, United States, Belgium and Ireland.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at dpo@proximabeta.com.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer and storage of your Personal Information.

Kuwait

You represent that you are at least 21 years old or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorize us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Mexico

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

Age Restrictions

You won’t be able to use the Service unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section "The types of personal information we use” and section “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations and advertising. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.

Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section “How we store and share your personal information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 3 “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Service and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data included in section “Your Rights” above also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at dpo@proximabeta.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at dpo@proximabeta.com.

You can also register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising on your phone number.

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Service may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy [A2].

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Service.

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Service.

Kindly note:

a) the identity of the data responsible or the Data Controller is Proxima Beta Pte. Limited, email: dpo@proximabeta.com.

b) the purposes of the processing for which the data are intended are set out in the table in Section 2 (“How We Use Your Personal Information”).

c) recipients or categories of recipients are set out in the second paragraph of Section 3 (“How We Store and Share Your Personal Information”).

d) whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 2 (“How We Use Your Personal Information”) and Section 5 (“Your Rights”, sub-paragraph “Objection”).

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@proximabeta.com.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Data Protection Team, responsible for the management and safety of your personal information
Contact: dpo@proximabeta.com

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Russia

If you happen to be using the Service in Russia, this section “Russia” applies to you. By using the Service you consent to:

for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Service or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore, the United States, Belgium and Ireland;
for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy.

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, “Objection” of the section “Your Rights” above apply to users in the Russian Federation.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.

As regards the representative for Russia, you can contact us at dpo@proximabeta.com. Please include the word “Russia” in the subject line of your email.

Separate consent for using certain data

By using the Service you also consent to the sharing of your personal information with certain third parties for the purposes set out under section “How We Store and Share Your Personal Information”.

You determine, in your discretion, the terms of disclosure to the general public of your personal data, by choosing to use certain features of the Service and by choosing the appropriate privacy settings in respect of your personal information in the Service.

We process your personal information subject to the terms of this Privacy Policy and your chosen features and settings.

This consent is granted for as long as you use the Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (dpo@proximabeta.com): please include the word “Russia” in the subject line of your email.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200
E-mail: local.representative@karanovicpartners.com

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information, we will provide you with our response to the request within 21 working days.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.