PRIVACY POLICY
Effective Date: 25 November 2022
1. Scope and Contact
This Privacy Policy applies to all of our games, websites and related services, collectively referred here as our Services. Your use of our Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including its limitations on damages and the resolution of disputes.
The data controller, for the purposes of the General Data Protection Regulation 2016/679 (the «GDPR»), shall be: The Plaza Real Group OÜ
For any questions about this Privacy Policy, please contact us through the game’s support email:
The Plaza Real Group OÜ
Email: support@contentrap.com
Address: Lootsa 2a, 11415 Tallin, Estonia
2. Data Collection
We may collect, use and process your personal data in different ways. In all cases we are committed to protecting your personal data.
We collect personal data related to current, prospective, and former customers (“users”) of our Services.
A – Sources OF PERSONAL DATA
We may obtain your personal data from the following sources:
a) from you directly (through the game, website, or online forms); and/or
b) from other entities, service providers that are assisting us in providing you with a service (including data analytics providers, operating systems, and internet services providers), or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google, Game Circle, Weibo).
B – DATA THAT WE COLLECT AND PROCESS
We may collect the following categories of personal data relating to our users:
a) Contact information (such as name or nickname or email you submit as part of your register for our Services or log-in or via social networks);
b) Data about the build version, your account, game progress and in-game events, we create a Contentrap-specific ID for you when you use the Services, our partners may create their own IDs;
c) Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
d) Data about your device, such as manufacturer, operating system, CPU, RAM, frame rate, browser type and language, current time;
e) Broad location data (e.g. country or city-level location);
f) Precise geolocation data (GPS, with your consent);
g) Usage data, such as data we collect with cookies and similar technologies;
h) Data (such as your nickname, email, profile picture) we receive if you link another provider’s tool with the Service (such as Facebook, Google or Weibo);
i) Purchase history, including details of orders (purchase ID, amount spent, currency, date, time, vouchers or offers used);
j) Data to fight fraud (such as refund abuse in games or click fraud in advertising);
k) Data from platforms that the games run on (such as to verify payment);
l) Data for advertising and analytics purposes, so we can provide you a better Service;
m) Your email address, your messages to the Services, such as chat logs and player support tickets sent by email or another service we can use in the future) and any feedback you submitted about your experience with us; and/or
n) Other data you choose to give us.
C – WHY WE COLLECT THE DATA
Our guiding principle is to collect only the data needed for a better service experience with our products.
– We may use your personal data to:
Provide you with our products or services (for example, play one of our online games and make online purchases).
Our lawful basis for doing so is: Contract
– We may use your personal data to:
Establish and manage our relationship (including maintaining or servicing accounts, providing customer service, and making your experience with us personalised).
Learn about how our products and services are or may be used to verify or maintain the quality of, and improve, our products and services (for example, when we ask you to fill out surveys about the experience you had with us).
Security (ensuring confidentiality of personal data, preventing unauthorised access and modifications to our systems and otherwise maintaining the security of personal data).
Perform advertising or marketing services, including letting you know about our products, services and events that may be of interest to you by email or other forms of electronic communication.
Our lawful basis for doing so is: Legitimate Interests, which are:
-Account Management
-Management Reporting (including at an intra-group level)
-Exercise or defend legal claims
-Understand the market in which we operate
-Management Reporting (including at an intra-group level)
-Managing security, risk and fraud prevention
-Management Reporting (including at an intra-group level)
-Promote our goods and services
-Management Reporting (including at an intra-group level)
– We may use your personal data to:
Send you marketing communications via email
Our lawful basis for doing so is: Consent
If you object to us using your personal data for the above purposes, including direct marketing, let us know using the email address provided in section 1.
Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. If we learn that we have collected personal data about a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us.
D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
3. Who do we share your personal data with?
Our Partner Organisations and Service Providers
We may disclose information about you to organisations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
a) technical support providers who assist with our website and IT infrastructure,
b) software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
c) professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
d) providers that help us generate and collate reviews in relation to our goods and services;
e) our advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
f) service providers that assist us in providing our services.
Law enforcement or government bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
4. Transfers of personal data outside the EU/European Economic Area
We share your personal data with our affiliates/partners in the EU/EEA and outside the EU/EEA. Where a data transfer outside the EU/EEA is not covered by an EU Commission adequacy decision, we rely on lawful safeguards referred to in Article 46 GDPR. You will find the full text of the EU Commission-approved Standard Contractual Clauses through this link.
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organisations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.
5. Your rights under the GDPR
You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data.
We do not carry out any decision-making based solely on automated processing, including profiling.
If you gave us your consent to use your data, e.g. so that we can send you marketing emails or display personalised ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.
You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. Legitimate interests we rely on are explained in section 2c above.
If you would like to exercise any of your above rights, you may contact us as set forth in the section 1 above.
Please also see our Terms of Use.
TERMS OF USE
Last modified: 27 November 2022
Terms of Use govern the relationship between you and The Plaza Real Group OÜ, an Estonian company (reg. # 16569297), with its address at Lõõtsa tn 2a, 11415 Tallin, Estonia («Contentrap» or «Us» or «We») regarding your use of Contentrap’s games, websites and related services (the «Service»), including all information, text, graphics, software, and services, available for your use. By using this website and the services offered on it, downloading any software, or browsing the website, as well as by downloading any of Contentrap’s mobile games from app stores or playing web-versions of the games, you accept the following Terms of Use. If you do NOT agree to all these Terms of Use, please do NOT use this website and/or download and/or play any of our games.
Contentrap is authorized to amend the Terms of Use at any time, with the amended Terms of Use effective as soon as they are posted on this website. Please check the most current Terms of Use to ensure that you are aware of all the terms and conditions regulating your use of this website and Contentrap’s games.
Contentrap reserves the right to make changes to or update the content of the website and its games or the format thereof at any time and without any notice. Contentrap reserves the right to terminate or restrict access to the website for any reason whatsoever at its sole discretion.
WARRANTIES AND DISCLAIMERS
ALL INFORMATION, SOFTWARE, AND SERVICES OFFERED ON THIS WEBSITE ARE PROVIDED «AS IS» CONTENTRAP HEREBY EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.
CONTENTRAP MAKES NO WARRANTY, REPRESENTATION, OR GUARANTY AS TO THE CONTENT, SEQUENCE, ACCURACY, TIMELINESS, OR COMPLETENESS OF ITS INFORMATION, SOFTWARE, OR SERVICES. CONTENTRAP MAKES NO WARRANTY, REPRESENTATION, OR GUARANTY THAT THE INFORMATION, PRODUCTS, OR SERVICES WILL BE UNINTERRUPTED OR ERROR FREE OR THAT ANY DEFECTS WILL BE CORRECTED.
CONTENTRAP ASSUMES NO RESPONSIBILITY FOR ERRORS OR OMISSIONS IN THE INFORMATION, SOFTWARE, OR SERVICES REFERENCED OR LINKED TO ON THIS WEBSITE.
IN NO CASE SHALL CONTENTRAP BE HELD LIABLE FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, PUNITIVE, SPECIAL, OR INCIDENTAL DAMAGES (INCLUDING, BUT NOT LIMITED TO, THOSE RESULTING FROM A LOSS OF BUSINESS, DATA, OR REVENUE; RELIANCE ON THE MATERIALS PRESENTED; DELAYS; OR BUSINESS INTERRUPTIONS ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF CONTENTRAP INFORMATION) REGARDLESS OF WHETHER CONTENTRAP HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
DOWNLOADING AND USING ANY OF THE SOFTWARE OR SERVICES OFFERED ON THE WEBSITE IS DONE AT YOUR OWN DISCRETION AND RISK AND YOU ARE SOLELY RESPONSIBLE FOR ALL DAMAGE TO YOUR DEVICE SYSTEM, LOSS OF DATA, OR OTHER HARM THAT RESULTS FROM SUCH ACTIVITIES.
Copyright
Copyrights, trademarks, and all other proprietary rights shown in the content (including, but not limited to, software, services, text, graphics, and logos) are reserved to Contentrap and protected by intellectual property laws. You agree not to copy, republish, modify, download, distribute, license, sublicense, reverse engineer, or create derivatives based on the site, its software, or its services except as expressly authorized herein. Except as otherwise provided, the content published on this website and/or in the app stores may be reproduced or distributed in unmodified form for personal, non-commercial use only. Any other use of the content, including, without limitation, distribution, reproduction, modification, display, or transmission, without the prior written consent of Contentrap is strictly prohibited. All copyright and other proprietary notices shall be retained on all reproductions.
Contentrap disclaims all proprietary interests in its intellectual property rights other than its own. References to third-party services and software are given by Contentrap «AS IS» without warranty of any kind, either expressed or implied.
In-Game Currencies and Goods
Contentrap’s mobile and social games include virtual in-game currency («Virtual Currency»), such as coins, food, and/or gems, that can be purchased for real money and in turn used to purchase virtual in-game items («Virtual Items»). Please note that Contentrap does not handle and is not responsible for handling transactions acquiring Virtual Currency. All Virtual Currency transactions are handled by third-party e-commerce payment providers. By purchasing in-game Virtual Currency, you are bound by and agree to the third-party payment providers’ Terms of Use.
In addition to all third-party obligations, the following shall apply. In no way can Virtual Currency or Virtual Items be exchanged with us or anyone else for real money, goods, other items, or services of monetary value. Transferring Virtual Currency or Virtual Items outside the Games is strictly prohibited, meaning that you may not buy or sell Virtual Currency or Virtual Items for real money or otherwise exchange Virtual Currency or Virtual Items for items of value outside the Games.
You also agree that all prices and sales of Virtual Currency and Virtual Items are final. Neither third-party payment providers nor Contentrap issue refunds for completed transactions except as provided in this Terms of Use. Please note that you only purchase a limited, revocable, non-transferable license to use in-game Virtual Currency or Virtual Items, and you agree that you do not own them. In the event your account is limited, terminated, suspended, modified, or deleted for any reason, at Contentrap’s sole and absolute discretion, or if Contentrap discontinues its Games, you forfeit any and all Virtual Currency and Virtual Items earned or purchased. Contentrap has the absolute right to manage, regulate, control, modify, and/or eliminate Virtual Currency and/or Virtual Items as it sees fit and at its sole discretion, and Contentrap is under no obligation to compensate you or anyone else for any resulting losses.
Rights to Content
«Content» refers to all software (including without limitation all games, titles, and computer code), communications (including without limitation all stories, dialogues, concepts, documentation, and character profile information), images, sounds, audio-visual effects, accounts, Virtual Currency and Virtual Items, and material produced by Contentrap and/or received or made available while playing the Games or developed during the course of the Games. Content also includes all feedback, comments, or suggestions that Contentrap receives from you regarding the Games. Unless otherwise expressly stated in writing, you understand and agree that all Content is owned, controlled, and/or licensed by Contentrap. Contentrap reserves the right to use all Content for any purpose, including without limitation all commercial and/or promotional use, without restriction by or compensating you. All Content is copyrighted under the copyright laws of the Republic of Estonia and/or similar laws of other jurisdictions, protecting it from unauthorized use. Contentrap reserves all rights, including, without limitation, all intellectual property rights and other proprietary rights to and relating to its Games. You are not permitted to copy, redistribute, publish, create any derivative work from, or otherwise exploit our Content or any part of our Content in violation of Contentrap’s and/or any other third party’s intellectual property rights. Contentrap, its logos, Game titles, and all related characters and elements are trademarks of Contentrap and may not be used without its prior written consent.
If you are deemed to have retained any right to, title of, or interest in our Content or any part of our Content, you agree to and hereby assign solely and exclusively to Contentrap all of your rights to, titles of, and interests in such Content or any part of such Content without additional consideration and in perpetuity under all applicable laws. If, for any reason, such assignment is ineffective under applicable law, you hereby grant Contentrap the sole, exclusive, irrevocable, sublicensable, transferable, worldwide, royalty-free license to reproduce, modify, create any derivative work from, publish, distribute, sell, transfer, transmit, publicly display, use, and practice such Content or any part of such Content, and to incorporate the same in other works in any form, media, or technology now known or later developed. To the extent permitted by applicable laws, you hereby agree to waive all moral rights or rights of publicity or privacy you may have to such Content.
At our discretion, Contentrap representatives or technology may monitor certain Content in the Games, though it cannot and makes no undertaking to monitor all Content. We may edit, refuse to post, or remove any Content posted in the Games or in any Games-related sources that is deemed objectionable or violates these Terms or the spirit of these Terms at our sole discretion and determination. If you encounter something you find objectionable and in violation of these Terms, you can bring it to our attention by contacting us. You understand and agree that we are not responsible or liable for any Content generated by users of the Games. This implies that users, not us, are entirely responsible for the completeness, accuracy, and/or usefulness of all the Content they upload, communicate, transmit, and/or otherwise make available via our Games and related services.
You acknowledge and agree that Contentrap may use built-in tracking features to obtain information regarding your use of the Games in order to improve the services we provide, and agree that such information is deemed to be Content for all intents and purposes under these Terms.
Information Provided by You
The use of all materials and information sent through or in connection with this website and/or Contentrap’s software by you is subject to our Privacy Policy.
Use of Software
The software available for download on this website or in app stores, as well as available on social networks, and all its documentation are the copyrighted work of Contentrap. Use of that software is governed by the terms of the end-user license agreement that accompanies or is included in it. You are not able to use, download, or install any software without first agreeing to the terms of the end-user license agreement that accompanies or is included in it.
You may not use, copy, republish, download, modify, distribute, license, sublicense, decompile, disassemble, create a derivative work based on, or reverse engineer the software or other products, services, or processes accessible through our website or Games except as expressly authorized herein or in the applicable end-user license agreement. You also acknowledge and agree that you will not transmit, upload, or attempt to transmit or upload viruses, adware, spyware, worms, or any other malicious or invasive code.
The software is supplied «AS IS» Contentrap disclaims all warranties, expressed or implied, including, but not limited to, warranties of merchantability and fitness for any purpose with respect to the software. You assume the entire risk of using the software.
You understand that Contentrap’s introduction of various technologies may not be consistent across all platforms and that the performance and some features offered by us may vary depending on your device and other equipment.
Contentrap grants you a non-exclusive, non-transferable, revocable, and limited license to use our software. You may not use Contentrap software for any purpose other than that described in the license granted to you. Any illegal use of our software is solely your responsibility.
Minors
You must be at least 16 years old to access and/or use our website or Games. If you are a minor over the age of 16, we recommend seeking consent from a parent or legal guardian before accessing and/or using our website or Games.
Applicable Law
These Terms of Use and all disputes relating to them shall be governed by and construed in accordance with the laws of Estonia.
Severability
You and Contentrap agree that if any part of these terms is or becomes, in whole or in part, invalid or unenforceable under any applicable local laws or court, it is to be deemed severed from these terms to the extent of its invalidity or unenforceability, and the rest of the terms shall remain in full force and effect.
YOU AGREE THAT YOUR USE OF THE INFORMATION, CONTENT, OR SERVICES ACKNOWLEDGES THAT YOU HAVE READ THIS AGREEMENT, UNDERSTAND IT, AND AGREE TO BE BOUND BY ITS TERMS AND CONDITIONS.
If you have any questions or comments, please contact us at support@contentrap.com. Please also see our Privacy Policy.