Privacy Policy

DATED: 21 October, 2024

A. GENERAL PRINCIPLES

a. This Privacy Policy is issued on behalf of GODAAM TECHNOLOGIES. When we refer to "Company", "we", "us" or "our" in this Privacy Policy, we are indicating the relevant entity within GODAAM TECHNOLOGIES responsible for handling your data.

b. We are dedicated to safeguarding and respecting your privacy while maintaining the trust and confidence of our customers. This privacy policy clarifies how your personal information is gathered, why it is collected, and how it is kept secure. We are committed to fulfilling our obligations under all applicable global data privacy laws, including the General Data Protection Regulation (‘GDPR’), the California Consumer Privacy Act (‘CCPA’), the Virginia Consumer Data Protection Act (‘VCDPA’), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), along with any provincial laws that are substantially similar.

B. INFORMATION COLLECTION SCOPE

a. Personal Information refers to any data about you where your identity is evident or can reasonably be determined. Whether the information is true or not, if it allows for the identification of you, it is considered Personal Information. When anonymous information is directly or indirectly linked with personal information, the resulting combination is also treated as Personal Information. Anonymous information is data that does not directly or indirectly identify and cannot reasonably be used to identify an individual. Aggregate information pertains to groups or categories of customers and does not single out an individual customer.

b. We collect two main types of information – Personal Information and anonymous information. We may also create a third type of information, aggregate information, by using personal and anonymous information.

c. We collect the following:

- Contact details such as your first and last name, email address, residential address, and mobile or other phone numbers.

- Personal details like your gender, age, age range, or image; account login information including your username, password, and pictures associated with your profile.

- Information exchanged bilaterally or within a small group through email, post, or other communication methods.

- Information obtained from third parties, like site or platform providers, regarding your use of or interest in our services.

- Location information, including that provided by a mobile or other device interacting with our Websites or associated with your IP address (where legally permitted).

- Activity, technical, and device information about your use of our Game, such as the content you view, the time and duration of your visits to our Game, how often you use our services, how you first discovered our Game, your preferences, and information about your interaction with the content offered through our Game. This also includes your hardware model, device type, unique device identifiers, operating system version, browser type, and IP address.

- Sensitive information like biometric data, geolocation, driver's licenses, and financial information for fulfilling our legal and regulatory obligations.

C. TECHNOLOGY-BASED DATA COLLECTION

a. When you interact with our Game, we strive to make the experience straightforward and useful. We and our partners employ industry-standard identifiers, such as cookies or other similar technologies.

b. Our Game may utilize technologies to enhance your experience. These technologies are small files placed on your computer, tablet, mobile phone, or other devices when you visit a website. They enable us to record specific pieces of information whenever you visit or interact with the Game. Usage information may partly include browser type, operating system, device type, an estimate of your geographic location based on your IP address, the location of your mobile device, the page served, the time, referring URLs, and other information typically transmitted in HTTP requests. This statistical data provides us with insights into your usage of the services, such as your engagement with a particular page, the type of content on that page, and how long you stay on that page. Generally, usage information is non-identifying. However, if the Company associates it with you as a specific and identifiable person, it will be treated as Personal Information.

c. Examples of these technologies are as follows:

- APIs: These work by enabling different types of software to communicate with each other. They make life easier for programmers and offer a better experience for end users.

- Cookies: Small text files placed in your device browsers to store your preferences. While most browsers allow you to block and delete cookies, doing so may affect the proper functioning of the service.

- Event tagging: Allows us to track actions on the Game, such as application installs and purchase events. By tracking these events, we can view analytics, measure ad performance, and build audiences for ad targeting.

- Mobile device identifiers: We may share the advertising identifier associated with your mobile device or tablet (like the Apple IDFA and Google Advertising ID) with advertisers. This is used to identify your device for internet-based advertising. For instructions on using the advertising choice mechanisms provided by popular mobile operating systems, visit the NAI’s Mobile Choices page here.

- Pixel tags/web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded in the Game that collects information about your engagement on a web page. For example, it allows us to record that a user has visited a specific web page or clicked on a particular advertisement. We may also include web beacons in emails to determine if messages have been opened, acted upon, or forwarded.

D. INFORMATION ACQUISITION METHODS

a. We collect information through various means, as detailed below. You confirm that any contact information you provide is accurate and true.

b. Information provided directly by you, including when you visit our Game, register on it, respond to a survey, fill out a form, or engage with other activities, services, features, or resources we offer on our Game.

c. In addition to collecting information via our Game, we gather information from you through telephone, video, or correspondence (including email, live chat, mail, text message, or social media). All telephone or video calls between you and Company representatives may be recorded for training, quality control, and compliance purposes. By continuing with any such call, you consent to it being recorded.

d. We also collect information about your use of our products and services through various technologies present when you visit our Websites, including the Game, or use our applications on third-party sites or platforms (whether or not you are logged in or registered). This includes cookies, flash cookies, pixels, tags, and application programming interfaces (“API”).

e. For more information, refer to the section titled “Personal Data Collected via Technology” below. Analytics tools are also used by us to collect information when you visit our Game or use our applications or services on third-party sites or platforms.

f. Finally, we use trusted sources to update or supplement the information you provided or that we have collected, including for the purpose of verifying or validating information (such as postal address, documentation, and names).

E. USAGE OF COLLECTED INFORMATION

a. We use the collected information to operate our Game, provide our products and services, answer your questions, and fulfill all applicable regulatory requirements.

b. In accordance with applicable laws and any options available to you, the Company may collect and use your information for specific purposes:

- To provide and manage the services you request. This includes processing your registration, setting up and maintaining your account, and conducting fraud prevention checks.

- To enhance customer service and our services. The information you provide helps us respond more efficiently to your customer service requests. We may also use your feedback to improve our products and services.

- To personalize the user experience. We may use aggregated information to understand how our users as a group use the services and resources provided on our Game.

- To contact you about our services, including for marketing purposes. This can be through email, live chat, telephone, text message, mail, or social media.

- To comply with our legal and regulatory obligations. We may use the information we collect about you for regulatory purposes, including detecting, investigating, and preventing activities that violate our terms and conditions or may be illegal.

- To offer alternative dispute resolution services. We may provide information we collect about you to our service provider partner for the specific purpose of resolving disputes that have not been satisfactorily resolved through our internal processes.

- To conduct market research and analysis. This involves analyzing how you interact with our products and services, monitoring and analyzing usage and activity trends, and for other research, analytical, and statistical purposes.

c. We do not engage in automated decision-making as defined by global data protection laws.

d. We may partner with a third-party service provider to display advertising on our Game or any application accessible via our Game or to manage our advertising on other websites. Our third-party service provider may use technologies such as cookies to gather information about your activities on our Game and other websites in order to provide you with advertising based on your browsing activities and interests.

F. YOUR RIGHTS

a. If we process your personal information for direct advertising purposes, you have the right to object at any time. This also applies to profiling, if appropriate, insofar as it is associated with such direct advertising.

b. You can opt out of receiving commercial messages from us by following the instructions in those messages or by contacting Customer Support. In the event of your objection to processing for direct advertising purposes, we will no longer process your personal information for these purposes.

c. By law and subject to certain conditions, you have several rights regarding the personal information we hold about you. These rights include the right to access the personal information we hold about you, the right to object to the processing of your data, the right to update and correct the information we hold about you, and the right to withdraw any consent provided. In some circumstances, you can request us to delete the personal information we hold about you.

d. We will not discriminate against you (for example, by denying products and services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

e. If you wish to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.

G. INFORMATION PROTECTION MEASURES

a. We have implemented physical, electronic, and operational procedures to safeguard the information we collect. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Game. Our security measures are regularly reviewed and updated to keep pace with technological advancements.

b. We use reasonable means to protect your personal information from misuse, interference, or loss, as well as any unauthorized access, modification, or disclosure.

c. If we believe that a reportable data breach has occurred, we will comply with the legislative requirements to notify you of the data breach and any steps taken by the Company to contain and investigate the data breach.

H. INFORMATION RETENTION PERIOD

a. We will retain your information for a period of time necessary to reasonably fulfill the purposes specified in this Privacy Policy, unless a longer retention period is required by law.

b. We will take reasonable steps to destroy or permanently de-identify any Personal Information when we no longer need it for any purpose for which it was collected or for a related purpose, and when we are not required by law, by a regulator, or by a court/tribunal order to retain it.

I. INFORMATION SHARING PRACTICES

a. We do not sell, trade, or rent your personal information. However, there are circumstances when we share your personal data with the following categories of third parties:

- Affiliates: Other companies within the Company.

- Service providers: Other companies that provide services to you on our behalf.

- Third parties that interact with us in connection with the services we perform.

If data is shared with a third party, we require them to maintain the same level of protection over your data as we do and to only perform services on our behalf. In other words, they are prohibited from using your personal information for purposes other than those requested by us or required by law.

b. We only share information with third parties in limited circumstances, including the following:

- When you allow us to share your information with third parties.

- When providing you with products and services and notifying you about important changes or developments in the features and operation of those products and services.

- In response to lawful requests by public authorities, including for national security or law enforcement purposes, when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law of a particular jurisdiction.

- When instructing and authorizing the financial institution holding a user’s account to disclose any information as may be requested by a regulator in respect of the user’s account.

- To enforce our terms and conditions set out on our Game, to protect our rights and property and the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with the law or legal processes.

- To perform customer due diligence, including ID verification.

J. POLICY UPDATES

a. This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our work is regulated. We will notify you of significant changes and, where required by law, obtain your consent. Notice may be provided by posting the changes on our Game or through other means in accordance with applicable laws.

b. Any changes to the Privacy Policy will take effect when the updated policy is posted on our Game.

c. We encourage you to regularly check this page for any changes to stay informed about how we are protecting the personal information we collect.

d. This Privacy Policy, effective as of the last modified date stated below, supersedes and replaces all previous Privacy Policies.

K. CONTACT US

a. If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at [email protected].