1. Privacy and data policy

 

ISSUED BY BEMIL MT INTERNATIONAL DOO (BEMIL MT INTERNATIONAL DOO).


  1. INTRODUCTION AND GENERAL TERMS

These terms are relating to the use of games and other products developed by BEMIL INTERNATIONAL DOO.

This privacy and data policy (Privacy Policy) has effect in respect of all games, related services (i.e. online network play, connectivity and interactivity) and other products made available by us. Additionally, any other online features relating to the Games including our User Support Centre (the Support Centre). Together the Game(s) and Support Centre are referred to as Services.

If users have any questions or comments relating this Privacy Policy, please contact us at [email protected].

We are committed to protecting and respecting user privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Services is processed, we are the “controller”. We will comply with all Gameslicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:



This Privacy Policy forms a part of and should be read in conjunction with our terms of use. These are linked below:



The Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be updated on this Account Info of Game. You should check this from time to time to ensure you are aware of any changes. Where Gamesropriate we may notify you of changes through the Games.


  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.


  1. a) Information provided by you when using the Games

Basic Information


We will collect the following information from you when you play our Games:



  1. b)    Information used for the purposes of serving advertisements

Advertising Data


Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:



  1. c)    Information collected for the purposes of providing analytics

Analytics


We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:


We use a third party analytics provider called Adjust when conducting our analysis on our marketing campaigns.

Adjust may collect analytics and some advertising data on our behalf and in accordance with our instructions, and its Gameslicable privacy notice.


  1. d)    Information about you collected from third parties

Third Party Login Information



When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.


For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information. The information that we request will be retained on your device and is not collected by us in any way.

The Games does use third party services that may collect information used to identify you.

Link to privacy policy of third party service providers used by the Games


  1. f)    Content created by our users which we host and displayin the Support Centre

User Content


When users submit their own User Content to the Support Centre, this content may contain personal and non-personal information. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Services.


  1. WHY WE COLLECT INFORMATION ABOUT YOU

  2. a) To provide our Services to you

We will use information about you (including Basic Information, Third Party Login Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience.


  1. b) To help us improve the Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Services; (ii) improving the quality of our Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Online Services; and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.


  1. c) To respond to your enquiries and requests for support

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre [email protected]


  1. d) To acquire new users and engage current users

We may process information (including some Advertising Data and Analytics) to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.

We may process this information to pursue our legitimate interests of acquiring new users for our Games.

We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of lookalike audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.


  1. e) To improve the monetisation of the Games via in-Games purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-Games purchases. This may include the implementation of dynamic pricing models, so that in-Games purchases are priced according to relevant factors, such as geography and gameplay progression so that we can offer temporary promotional discounts.

We will not pass your information to third parties for the purposes of dynamic pricing unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.


  1. f) For advertising purposes

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.

The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.

We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.

We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content.


  1. g)    To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any Gameslicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

We work with Gamesle and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-Games purchases made through iTunes and Google Play).


  1. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy.

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or Gamesly the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of BEMIL INTERNATIONAL DOO Group, our customers, or others.

Digital Content Stores: Where the Games are downloaded through, we may disclose your personal information for the purposes of facilitating any in-Game payments made through these platforms.

Support Centre: We use email : [email protected] to manage any requests or issues raised by users


  1. AUTOMATED DECISION MAKING

User personal information is processed via automated decision making methods in order to identify anyone suspected of cheating within the Games. Our automated decision making methods are designed to detect and form of cheating by monitoring (i) excessive currency stores in relation to gameplay; and (ii) excessive content against purchases made and gameplay.

If users are suspected of cheating the following action(s) may be taken:



Users may be blocked from the Game and/or Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Online Services.


  1. DATA RETENTION

User personal information is held within our systems for as long as necessary for the relevant service /as otherwise described in our Privacy Policy.


  1. CHILDREN

Our Services are not knowingly used to solicit information from to viewers under the age of  18. These terms of use prohibit users under 18 years from accessing our Services. In the event that personal information has been collected from anyone under the age 10 years, that information will be deleted as quickly as possible.


  1. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as BEMIL MT management or employees whose main role requires system access).


Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


CONTACT INFORMATION


All questions, comments or enquiries should be directed to BEMIL MT at [email protected] We will endeavour to respond to any query or questions within three business days.