1. INTRODUCTORY PROVISIONS
("Site") or use any Prequel’s application or games provided on any mobile platform (for example, iOS and Android) (collectively, the "Service(s)"). It also tells you how you can access and update personal information and/or data and make certain choices about how personal information and/or data that you provide to Prequel is used.
1.2. Please note that the scope of this Policy is limited to information and data collected or received by Prequel through or in relation to your use of the Service. Prequel is not responsible for the actions of third parties, the content of third party websites, the use of information or data you provide to third parties, or any products or services they may offer. Any link to third party websites does not constitute our sponsorship of, or affiliation with, such third parties.
1.3. Prequel acts as a Data Controller in relation to personal data that you provide to Us.
1.5. Prequel Inc as Data Controller does not and will not process any special categories of personal data.
2. INFORMATION THAT WE COLLECT
2.1. We collect and combine different types of information and/or data (including personal data) together. Here you can find more about what information and/or data We collect about you, when We collect it and what information and/or data We do not collect about you:
2.1.1. Registration, account, and sign-up information.
We collect data in the course of your use of, or registration with Prequel. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal data. This type of personal data can include: name, postal address, telephone number or email address. We can also receive data about your interest in and use of various products, programs, services, and content available.
2.1.2. Product/service purchase.
Where you make a purchase on our Site, We provide you third party services for purchasing and your payment data (e.g. credit/debit card, billing information and delivery address) is not collected by Us.
2.1.3. From other sources.
2.1.4. Social media.
2.1.5. Location information.
We have access to certain data about your location, such as your country or address, when you provide it to Us directly or when we receive it via device information (such as an IP address). With your consent (where required by law), we can also collect data about your device's precise location (e.g. geolocation via mobile device(s)) for the purpose of tailoring content specific to your area (such as area based content packages), and to match your device location to certain points of interest for purposes of interest based advertising as described in this Policy. Please note, participation in this part of the Service is not a requirement for all Our applications and games. You may at any time opt-out from sharing your location by turning it off in the settings of your device.
2.1.6. Technical and usage information.
We also collect certain technical and usage information such as your application data (including interaction with in-app facial mapping tools used for facial manipulation features and with other Users inside the application via server log files and your user ID), access, session times and in-app purchases, device type, browser, and operating system you are using, your Internet service provider and/or mobile carrier, unique device ID (persistent/non-persistent), device hardware type, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest based advertising as described elsewhere in this Policy.See "Cookies and Other Technical Information" section for more information on how we may use these technologies to collect this data.
2.1.7. Customer enquiries.
Where you contact Us through one of our customer helpdesks or customer support centers, We may collect and process contents (including data) of your correspondence with Us and/or your contact details.
2.1.8. Tracking Technologies.
We and Our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify User's computer/device and to "remember" things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal data, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable all cookies apart from the cookies necessary for the functioning of the site and/or an app.
3. HOW WE USE THE INFORMATION
3.1. We use collected information and/or data (including personal data) for the following purposes:
3.1.1. Providing and marketing products and services.
We use the information and/or data that we collect about you in order to analyze your use of our products, applications, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings.For example, we use information and/or data that we collect from you to enable you to:
(i) watch trailers and video clips;
(ii) get entertainment news and updates;
(iii) get information about our products, services, and content;
(iv) locate and access personalized information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times);
(v) play games;
(vi) engage with interactive features, activities, and Social Media Sites;
(vii) read and post comments, content, and reviews, or enter promotions, contests, and sweepstakes.
In addition to this, we use this information and/or data for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.
• Fulfilling contractual obligations;
• Legal obligations;
• Your consent (where required);
• Our legitimate interests:
- improving and developing new products and services;
- being more efficient;
- preventing fraud;
- retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which We believe you will also be interested in.
3.1.2. Communicating with you.
We use information and/or data that we collect about you to communicate with you, in order to:
(ii) respond to your inquiries;
(iii) communicate with you about your purchases or transactions;
(iv) contact you about your account; or
(v) send you information about promotions, offerings, and Our features. You can also choose to receive push notifications from Us on your mobile device.
• Fulfilling contractual obligations;
• Legal obligations;
• Your consent (where required);
• Our legitimate interests:
- Communicating important information;
- Improving and developing actual and prospective products and services;
- Compiling statistics.
3.1.3. Third party social networks.
We use information and/or data that we collect about you when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social network.
• Your consent (where required);
• Our legitimate interests:
- Defining types of customers for new products or services;
- Developing a profile on you and your interactions with Us so that we can provide tailored offers, opportunities and services that may be of interest to you.
3.1.4. Use of technical and usage information.
We use technical and usage information to improve Our design, functionality and content and to enable Us to personalize your experience with Our content and offerings. We use this Information in order to:
(i) provide, develop, maintain, personalize, protect, and improve our products, applications, services and video games, and to operate our business,
(ii) perform analytics, including to analyze and report on usage and performance,
(iii) protect against, identify, and prevent fraud and other unlawful activity,
(iv) create aggregate data about groups or categories of Our Users.
• Legal obligations
• Our legitimate interests:
- Protecting our business interests and rights, privacy, safety and property, or that of the public;
- Sharing your data with third parties in order to permit us to pursue available remedies or limit damage that We may sustain.
4. INFORMATION SHARING AND DISCLOSURE
4.1. We share and disclose information and/or data (including personal data) for the following purposes:
4.1.1. Law enforcement bodies and courts.We disclose information and/or data when provided by law, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose information and/or data to third parties:
(i) in connection with fraud prevention activities;
(ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities;
(iv) to protect Our rights and the rights and safety of third parties; and
(v) as otherwise required by law.
4.1.2. Change of control.
We will transfer information and/or data regarding our Users in the event of a business transaction, such as if We or one of Our business units or Our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
4.1.3. Service providers.
Our agents and contractors have access to information and/or data regarding our Users in order to carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, marketing, processing of payments, email and order fulfillment, administration of contests, research and analytics, and customer service.
4.1.4. Advertising networks.
We share certain information and/or data regarding our Users with third parties to provide advertising to you based on your interests. For more information, please see "Cookies and Other Technical Information" and "Ad Choices" sections below.
5. YOUR CHOICES
5.1. Marketing communications and sharing with third parties.
We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from Us, and Our sharing of information and/or data relating to you with Our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at email@example.com
5.2. Ad Choices.
.You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
5.3. Precise location information.
To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
6. COOKIES AND OTHER TECHNICAL INFORMATION
6.1. Cookies and other technologies.
6.1.1. We, and Our affiliates, third party service providers, and trusted partners send "cookies" to your device and use similar technologies in order to analyze and enhance your user experience with Us, as well as for advertising purposes and social features.
6.1.2. Cookies are small text files placed in your browser. We may also use pixels or "web beacons" that monitor your use of Our websites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.
6.1.3. We may also integrate "Software Development Kits" ("SDKs"), java script or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with Our app.
6.1.4. Our websites may use locally stored objects ("LSOs") to provide certain content, such as video on demand, video clips, or animation, and better user experience.
(i) to provide, develop, maintain, personalize, protect, and improve Our websites, products, apps, services and video games, and to operate Our business;
(ii) to perform analytics, including to analyze and report on usage and performance of Our content and marketing materials;
(iii) to protect against, identify, and prevent fraud and other unlawful activity;
(iv) to create aggregate data about groups or categories of our users;
(v) to synchronize users across devices, affiliates, and trusted partners; and
(vi) for Us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through Us.
6.4. We use following types of cookies and similar technologies:
6.4.1. Strictly necessary cookies or similar technologies.
They are essential in order to enable you to move around Our websites and apps and use their features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
6.4.2. Performance cookies or similar technologies.
They collect information about how you use Our websites and apps, so that We can analyze traffic and understand Users' interactions. We may use third party service providers such as Google Analytics, who may use their own cookies or similar technologies, for this purpose.
6.4.3. Functionality cookies or similar technologies.
They allow Our websites and apps to remember choices that you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog.
6.4.4. Social media cookies or similar technologies.
They are used when you share information using a social media sharing button or "like" button on Our websites or apps, or when you link your account or engage with Our content on or through a social media site such as Facebook, Twitter or Google+. The corresponding social network will record that you have done this. This information may be linked to targeting/advertising activities.
6.4.5. Advertising cookies or similar technologies.
Some of Our websites or apps may use a third party advertising networks to deliver targeted advertising. They may also have the capability to track your browsing across websites, apps and Social Media Sites.
7. DATA RETENTION
7.1. We will only retain your personal data for as long as is necessary for the purposes described in this Policy. This means that the retention periods will vary according to the reason of collection. Generally, your service-related personal data will be kept for as long as you remain Our User. Yet, some personal data relating to the provision of services to you will be kept for a longer period, as long as necessary to comply with various finance- and tax-related legal obligations. After a retention period has elapsed, the personal data is securely deleted.
8. HOW YOU CAN EXERCISE RIGHTS IN RELATION TO YOUR DATA
8.1. Under certain conditions, you have the right to ask Us for a copy of your personal data, as well as to correct it, delete it or restrict its processing, and to obtain the personal data that you provided to Us in a structured, machine-readable format. You have the right to object to the processing of personal data on the basis of Our legitimate interests.Where We have asked for your consent to process your personal data, you have the right to withdraw this consent at any time.
8.2. To exercise any of the above rights, please contact Us at firstname.lastname@example.org
8.3. In addition to the above rights, as a resident of EU/EEA you also have a right to lodge a complaint to your local supervisory authority.
8.4. In cases permitted by law We reserve the right not to allow access to your personal data or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal data even if you withdraw your consent.
9. INTERNATIONAL TRANSFER
9.1. We operate internationally, this means that personal data that we collect will be processed by Us in states where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.
9.2. When we transfer your Information to our group members outside the European Economic Area (EEA), we make use of standard contractual clauses
which have been approved by the European Commission. We also use these clauses when we transfer your personal data to third parties outside the EEA.You may obtain a copy of the documents we use to protect your personal data when it is transferred outside the EEA by contacting us via email at email@example.com
10. HOW TO CONTACT US
10.1. As a non-EEA resident controller we have appointed a local representative in the EEA. Our local EEA representative can be contacted as follows:
Fanariou 10, apt. 102, Limassol, Cyprus, 3106
Privacy Notice for California Residents
Effective date: 8 September 2021.
1. INFORMATION WE COLLECT
1.1. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").
1.2. In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
Examples: A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).
Examples: A name, signature, physical characteristics or description, address, telephone number. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Examples: Age, race, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Examples: Physical location or movements.
H. Sensory data.
Examples: Audio, electronic, visual, or similar information.
K. Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
1.3. Personal information does not include:
(i) Publicly available information from government records;
(ii) De-identified or aggregated consumer information;
(iii) Information excluded from the CCPA's scope, like:
i. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
ii. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
1.4. We obtain the categories of personal information listed above from the following categories of sources:
(i) Directly from our consumers or their agents. For example, from information consumers provide to Us related to the Services for which they engage Us.
(ii) Directly from you when you provide it to Us. For example, if you share your name and contact information to ask a question about Our website or app.
(iii) Indirectly from you. For example, from observing your actions on Our websites and in Our apps.
(iv) From third parties, for example, Our service providers.
2. USE OF PERSONAL INFORMATION
2.1. We may use or disclose the personal information we collect for one or more of the following purposes:
(i) To fulfill or meet the reason for which you provided the information. For example, if you share your name and contact information to ask a question about Our website, app or product we will use that personal information to respond to your inquiry.
(ii) To provide, support, personalize and develop our websites, apps and products.
(iii) To process your requests and respond to your inquiries, including to investigate and address your concerns and monitor and improve Our responses.
(iv) To notify you about changes to Our websites, apps or any products or services we offer or provide through Our websites and apps.
(vi) To maintain a record of Our dealings with you.
(vii) To understand and analyze the usage trends and preferences of Our Users, to improve Our websites, apps and other products and to develop new features, and functionality.
(ix) To engage features of third party social networks.
(x) For testing, research, analysis and product development.
(xi) To help maintain the safety, security, and integrity of Our websites and apps, and our databases, other technology assets and business.
(xii) To diagnose or fix technological problems in relation to Our websites, apps and products.
(xiii) To carry out Our obligations and enforce Our rights arising from any contracts entered into between you and Us.
(xiv) To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
(xv) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us is among the assets transferred.
(xvi) As described to you when collecting your personal information or as otherwise set forth in the CCPA.
3. SHARING PERSONAL INFORMATION
3.1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
3.2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Personal information categories listed in the California Customer Records statute.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
3.3. We disclose your personal information for a business purpose to the following categories of third parties:
(i) Our affiliates.
(ii) Service providers.
(iii) Third parties to whom you or your agents authorize Us to disclose your personal information in connection with products or services We provide to you.
(iv) Law enforcement bodies and courts.
3.4. We share your personal information for the following general purposes:
(i) Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
(ii) Protecting our Rights: We may disclose personal information to third parties if We believe that doing so is legally required or is in Our interest to protect Our property or other legal rights (including, but not limited to, enforcement of Our agreements), or the rights or property of others.
(iii) Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of Company’s assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of Our business assets.
3.5. In the preceding twelve (12) months, we have not sold any personal information.
4. YOUR RIGHTS AND CHOICES
4.1. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
4.2. Access to Specific Information and Data Portability Rights.
You have the right to request that We disclose certain information to you about Our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see "Exercising Access, Data Portability, and Deletion Rights" section), we will disclose to you:
(i) The categories of personal information We collected about you.
(ii) The categories of sources for the personal information We collected about you.
(iii) Our business or commercial purpose for collecting and selling that personal information.
(iv) The categories of third parties with whom We share that personal information.
(v) The specific pieces of personal information We collected about you (also called a data portability request).
(vi) If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
4.3. Deletion Request Rights.
You have the right to request that We delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request (see "Exercising Access, Data Portability, and Deletion Rights" section), We will delete (and direct our service providers to delete) your personal information from Our records, unless an exception applies.We may deny your deletion request if retaining the information is necessary for Us or Our service provider(s) to:
(i) Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(iii) Debug products to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
(v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
(vii) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
(viii) Comply with a legal obligation.
(ix) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4.4. Exercising Access, Data Portability, and Deletion Rights.
4.4.1. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to Us by either:
Emailing Us at: firstname.lastname@example.org.
Contacting Us by mail:
Fanariou 10, apt. 102, Limassol, Cyprus, 3106.
4.4.2. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
4.4.3. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
(i) Provide sufficient information that allows Us to reasonably verify that you are the person about whom We collected personal information or an authorized representative of such person; and
(ii) Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
4.4.4. We cannot respond to your request or provide you with personal information if We cannot verify your identity or authority to make the request and confirm the personal information relates to you.
4.4.5. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
4.5. Response Timing and Format
4.5.1. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to 90 days), We will inform you of the reason and extension period in writing.
4.5.2. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
4.5.3. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell you why We made that decision and provide you with a cost estimate before completing your request.
4.6. Personal Information Sales Opt-Out and Opt-In Rights.
4.6.1. If you are a California resident and 16 years of age or older, you have the right to direct Us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
4.6.2. To exercise the right to opt-out, you (or your authorized representative) shall submit a variable notice to email@example.com.
4.6.3. Once you make an opt-out request, We will wait at least twelve (12) months before asking you to reauthorize personal information sales.
5.1. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:
(i) Deny you goods or services.
(ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.(iii) Provide you a different level or quality of goods or services.
(iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. CHANGES TO OUR PRIVACY NOTICE
6.1. We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Site and update the Privacy Notice's effective date. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes.
7. CONTACT INFORMATION
Fanariou 10, apt. 102, Limassol, Cyprus, 3106