Introduction:
The Service is operated by holding company DFY STUDIO-FZCO with registration number DSO-FZCO-24944 at Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates, a company registered in United Arab Emirates with registered license number: DSOA/App/LIC-0062948 ("Company", "we", "us", "our").
This Privacy Policy (“policy”) forms part of and is incorporated by reference into our standard Terms and Conditions and Terms and Conditions. This policy governs the data which we collect from users and other third parties in the course of our business and the way in which we protect and process such information. Please read this policy carefully to understand how we will treat your personal data.
Data Protection:
Your privacy and personal information are important to us. Any personal information that you provide to us shall mean personal information as defined in the relevant Data Protection laws. We obtain this information either directly from you or from Representatives who may provide it to us. We may collect the following personal information about you:
- Your name and contact details (title, surname, first name, any other name(s), postal and/ or physical address, e-mail address, telephone numbers);
- Your date of birth and place of residence;
- Information on your purchases from the Company;
- Payment card details;
- The communications you exchange with us (for example, your emails, letters, calls, or posts and messages on social media), or with your Representatives on systems that the Company provides;
- Information about how you use our website;
- Identifiers such as your computer’s IP address or your mobile’s MAC address.
If you choose to click through to third party websites via our website, third parties may collect information about your use of our website, using certain technologies available to them, for example cookies. Similarly, where you choose to interact with the Company content on social media, third parties may collect information about these interactions. Information collected by these third-party services is governed by the privacy policies of those third parties. The business purposes for which we will use your personal information include accounting, billing, security and legal purposes (including to investigate complaints or claims, statistical and marketing analysis, systems testing, maintenance and development. This will include the use of your personal information to comply with our legal obligations, for example, our obligation to maintain records for tax and audit purposes. Where there is no specific legal obligation we are required to meet, we process this personal information to meet our legitimate interests in managing our business and keeping our records accurate and up to date. The Company may run certain competitions and will need to process your name and contact details if you enter, as well as to let you know if you have won. We do this on the basis of your consent, which you can withdraw at any time by contacting us as set out below. Specific uses of personal data in this context will be detailed in the competition rules. We may share your personal information with: Company Representatives, other Group companies, suppliers providing services to us in order to help us run our business and improve our services and your customer experience, an acquiring party, service providers or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets; and government authorities. Where your
personal information is transferred outside of the United Arab Emirates, the Company uses Data Protection compliant mechanisms and ensures that appropriate safeguards are in place to protect personal information which is transferred to countries outside of the United Arab Emirates which are considered to provide a lower level of protection for personal information. Further, data protection compliant transfer mechanisms are in place with our email system provider and IT support and IT system maintenance suppliers. Your personal
information will be used and stored by the Company for the length of your association with the Company and for a length of time needed after (i.e. to achieve the purpose for which it was collected), to take into account any ongoing obligations we may have (e.g. to store the information for accounting purposes), or the length of time given to commence or defend any legal claims. If you would like more specific timescales please contact us. We will stop processing your data for direct marketing, including profiling activities, if you object to such processing of your data or if you withdraw your consent to processing, where your consent has previously been obtained. You have a right to request access to the personal information that we hold about you and to have any inaccurate personal information we hold about you rectified/ deleted in terms of data protection laws. If you have an issue or complaint about how we handle your personal information, please contact our Information Officer.
Changes to the agreement:
The Company reserves the right to amend the Agreement and its prices in its sole and absolute discretion. By executing the Terms and Conditions you agree to abide by all amendments or modifications that the Company elects to make. Amendments shall be effective immediately after publication. Amendments shall not apply
retroactively to conduct that occurred prior to the effective date of the amendment. Notification of amendments shall be published by one or more of the following methods: (1) posting on the Company’s official website; (2) electronic mail (e-mail); (3) posting in back-offices; (4) inclusion in Company periodicals; (5) inclusion in product orders or bonus checks; or (6) special mailings.
Policies and Provisions Severable. If any provision of the Agreement, in its current form or as may be amended, is found to be invalid, or unenforceable for any reason, only the invalid portion(s) of the provision shall be severed, and the remaining terms and provisions shall remain in full force and effect. The severed provision, or portion thereof, shall be reformed to reflect the purpose of the provision as closely as possible.
The data we collect:
Data you provide us. Contact information (such as name and email address); Player name and password; Profile information (such as profile photo); Your messages to the Service (such as chat logs and player support tickets); Your Survey and Feedback responses; Other data you choose to give us (such as data to identify a lost
account); Data we collect automatically.
General location data:
Geo-location data. Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service. Data we collect from our partners. Data we receive if you link a third-party tool with the Service (such as Facebook or Google). Data from third party Analytic and Advertising Network providers. Demographic data (such as to determine the coarse location of your IP address). Data to fight fraud (such as refund abuse in games or click fraud in advertising). Data from platforms that the games run on (such as to verify payment). Data for advertising and analytics purposes, so we can provide you a better Service.
Why do we collect your data:
To perform the contract, we process data necessary to Create accounts and allow you to play our games and use our Service. Operate and improve our games and the Service. Understand you and your preferences, to enhance your and other player’s experiences with and enjoyment of our Apps and related products and
services. Verify and confirm payments. Provide and deliver products and services you request, send you Service-related communications, to make the Service more suitable for our players. To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to Update and develop player profiles, develop and improve the Service and player experience, manage our relationship with you, provide social features as part of the Service, Customise your Service experience, respond to your comments and
questions and provide player support, Provide you offers in the Service as well as in other web sites and services, and by email, Send you related information, such as updates, security alerts, and support messages, allow you to enrol in reward programmes and receive extra information and rewards as part of the Service, Enable you to communicate with other players, to show personalised advertisements, to show you personalised advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to Track the content you access in connection with the Service and your online behaviour, deliver, target and improve our advertising and the Service.
To keep the service safe and fair:
Ensuring a fairness in the Service is a top priority for us.
For more information on our acceptable use policy, see the Company Terms and Conditions.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to analyse and monitor use of the Service and its social features; Moderate chats either automatically or manually; Take action against fraudulent or unauthorised conduct. To analyse, profile, and segment. In all of the above cases and purposes, we may analyse, profile and segment all collected data.
With your consent:
With your consent, we may process your data for additional purposes, such as game specific marketing emails, or for events we think you may be interested in attending and taking part.
who can see your data:
Apart from the Company, your data can be accessed by others in the following situations:
other players and users:
Social features are a core component of our games. Other players and users may for example see your profile data, in-game activities and read the messages you have posted.
other companies and public authorities:
In order to combat fraud and illegal activity, we may exchange data with other companies and organisations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent to comply with the law or to protect the rights, property or safety of us, our players or others.
Legal Basis for processing your information (EEA):
If you are a player from the European Economic Area (“EEA”), we normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as our Terms of Service), (ii) where the processing is in our legitimate interests, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. We may have other legitimate interests and will make clear to you at the relevant time what those legitimate interests are.
Your rights and options:
Opt-out of marketing emails and other direct marketing. You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Access the personal data we hold about you:
In response to any reasonable data request, we will provide you a copy of your personal data in an electronic format.
Your other rights:
You also have the right to correct and update your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by changing your advertising settings on your mobile device. We will respond to all requests within a reasonable
timeframe.
Cookies and similar technologies:
Like most online services, we and our partners use cookies and similar technologies to provide and personalise the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.
Security safeguards:
In order to help ensure a secure and safe player experience, we are continuously reviewing, developing and implementing administrative, technical and physical security measures to protect your data from unauthorised access or against loss, misuse or alteration. Despite our efforts, please be aware that no security measure is ever perfect or impenetrable. To that end, we will notify users of a data breach as reasonably necessary and
in accordance with applicable law.
data retention:
We retain your data for as long as your account is active or as needed to provide the Service. We will for example periodically identify unused game accounts and we regularly review and identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
Age limits:
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, 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 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, 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 13, please contact us.
DISPUTE RESOLUTION AND DISCIPLINARY PROCEEDINGS:
Violation of the Agreement, these Policies and Procedures, violation of any common law duty, including but not limited to any applicable duty of loyalty, any illegal, fraudulent, deceptive or unethical business conduct, or any act or omission by an Customer that, in the sole discretion of the Company may damage its reputation or goodwill (such damaging act or omission need not be related to the Customer’s the Company business), may result, at the Company’s discretion, in one or more of the following corrective measures:
- Issuance of a written warning or admonition;
- Requiring the Customer to take immediate corrective measures;
- Suspension of the individual’s Customer Agreement;
- Involuntary termination of the offender’s Customer Agreement;
- Suspension and/or termination of the offending Customer the Company website or website access;
- Any other measure expressly allowed within any provision of the Agreement or which the Company deems practicable to implement and appropriate to equitably resolve
injuries caused partially or exclusively by the Customer’s policy violation or contractual breach; - In situations deemed appropriate by the Company, the Company may institute legal proceedings for monetary and/or equitable relief.
Grievances and complaints:
When you have a grievance or complaint with another customer regarding any practice or conduct in relationship to their respective Company businesses. If the matter involves interpretation or violation of Company policy, it must be reported in writing to the Customer Services Department at the Company. The Customer Services Department will review the facts and attempt to resolve it.
Mediation:
Prior to instituting an arbitration, the parties shall meet in good faith and attempt to resolve any dispute arising from or relating to the Agreement through non-binding mediation. One individual who is mutually acceptable to the parties shall be appointed as mediator. The mediation shall occur within 60 days from the date on which the mediator is appointed. The mediator’s fees and costs, as well as the costs of holding and conducting the mediation, shall be divided equally between the parties. Each party shall pay its portion of the anticipated shared fees and costs at least 10 days in advance of the mediation. Each party shall pay its own attorneys’ fees, costs, and individual expenses associated with conducting and attending the mediation. Mediation shall be conducted online and shall last no more than two business days.
arbitration:
If mediation is unsuccessful, any controversy or claim arising out of or relating to the Agreement, or the breach thereof, shall be settled by arbitration. The Parties waive all rights to court. The arbitration shall be filed with, and administered by, the Dubai International Arbitration Centre (“DIAC '') under its respective rules and procedures. The DIAC Arbitration Rules are available on the DIAC’s website at www.diac.ae. Copies of
DIAC’s Arbitration Rules will also be emailed to you upon request to the Company’s Support Department. Notwithstanding the Arbitration Rules of the DIAC, the following shall apply to all Arbitration actions: The arbitration shall occur within 180 days from the date on which the arbitrator is appointed, and shall last no more than five business days;The Parties shall be allotted equal time to present their respective cases, including
cross-examinations.
All arbitration proceedings shall be held in Dubai, United Arab Emirates and conducted in English. There shall be one arbitrator selected from the panel that the Alternate Dispute Resolution service provides. Each party to the arbitration shall be responsible for its own costs and expenses of arbitration, including legal and filing fees. The parties shall be allotted equal time to present their respective cases. The decision of the arbitrator shall be final and binding on the parties and may, if necessary, be reduced to a judgment in any court of competent jurisdiction. This agreement to arbitrate shall survive the cancellation or termination of the Agreement. The parties and the arbitrator shall maintain the confidentiality of the entire arbitration process and shall not disclose to any person not directly involved in the arbitration process: The substance of, or basis for, the controversy, dispute, or claim; The content of any testimony or other evidence presented at an arbitration hearing or obtained through discovery in arbitration; The terms or amount of any arbitration award; The rulings of the arbitrator on the procedural and/or substantive issues involved in the case. Notwithstanding the foregoing, nothing in these Policies and Procedures shall prevent either party from applying to and obtaining from any court having jurisdiction a writ of attachment, a temporary injunction, preliminary injunction, permanent injunction or other relief available to safeguard and protect its intellectual property rights, and/or to enforce its rights under the non-solicitation provision of the Agreement.
Governing Law, Jurisdiction, and Venue:
Jurisdiction and venue of any matter not subject to arbitration shall reside exclusively in the United Arab Emirates. The law of the United Arab Emirates shall govern all other matters relating to or arising from the Agreement.
