Privacy Policy

This Privacy Policy explains how OTEBE Smart collect, use and protect your personal data when you use OTEBE Smart's products or interact with OTEBE Smart.

By using our products, you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.

The data controller is responsible for the collection and use of your personal data. In order to comply with data protection legislation, the data controller will be the us entity with which you contracted for the product. For more information, please see the "Your Questions and How to Contact Us" section of this Privacy Policy.

Our Privacy Policy will help explain what information we collect, how we use it and the choices you have regarding it. Highlights of our Privacy Policy are provided below, but you can also learn more by clicking on the "Read More" link below.

We will only collect and process personal data about you where we have a lawful basis in your country. Our lawful bases, as described in this Privacy Policy, include consent (you have consented to receive updates and marketing emails), contract (requested for the performance of a contract with you (for example, to provide you with products)) and "legitimate interest ".

1. What information do we need to provide the Game Services

We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data”):

Data automatically collected or generated:

When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed below).

Such data consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, game statistics, game preferences, unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions ), non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, in-App or Game activity (such as game play content/product interaction and advertising data); diagnostic data (i.e. crash data and game performance data). We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 8 below.

Data received from you:

You may provide us Personal Data voluntarily, such as when you set up an account with us, contact us (through Facebook, Messenger, e-mail, in-game chat or any other channel, including any support services), when you post on our public forums or groups, when you provide us your e-mail address (such as when you sign-up to receive e-mail updates or gifts), when you participate in competition, contest, tournaments and other promotions, when you place any purchases in any of our Games, when you interact with other users through the in-game chat or when you choose to connect your Facebook, Google, Apple or similar account to any of our Games.

Data received from Facebook and other channels:

Once you connect the Games to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you defined it as “public”), as applicable, your full name, e-mail address(es) provided to Facebook, Google or Apple, gender, profile picture or similar photo, location, time zone, and a list of your friends playing the Games (along with their photos and other public profile information). This will also allow us to present your and your friends’ public profile images inside the Games and to create your in-game friends list. In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession.

2. Collected information may be used in the following ways

(A) REGISTRATION INFORMATION:

(i) to create your profile and so you can access our Products;

(ii) to identify you when you sign-in;

(iii) to give you access to your user preferences;

(iv) to contact you for your views on our Products;

(v) to notify you of changes or updates to our Products;

(vi) for marketing purposes, based on your communication preferences.

(B) BILLING INFORMATION:

(i) to verify your purchase of our Products and process any refunds;

(ii) to reply to any queries and questions and to resolve problems;

(iii) to carry out analysis and research to develop our Products;

(iv) to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.

(i) to provide you with an optimal experience;

(ii) to understand how you interact with our Products

(iii) to provide Products you request;

(iv) to measure and analyse the use and effectiveness of our Products;

(v) to understand which of your devices are using our Products and playing our videogames;

(vi) to provide safe and fair gaming environments;

(vii) to customise and optimise the targeting of our advertising both within our Products and across our websites;

(viii) to operate and improve our Products;

(ix) to fix errors.

(D) FEEDBACK / SURVEYS / USER RESEARCH:

(i) to reply to your questions or queries;

(ii) to record comments and information which you provide on our gaming forums;

(iii) to conduct analysis and research to improve and develop our Products.

(E) THIRD PARTY INFORMATION:

(i) to enable us to provide tailored offers to you;

(ii) to facilitate sharing on social networks;

(iii) to facilitate your gameplay.

(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:

(i) to understand the community sentiment about our Products.

(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:

(i) to track the performance of our Products;

(ii) to communicate with our platform operators and partners;

(iii) to improve our advertising and targeting systems.

(H) INFORMATION ABOUT YOUR PARTICIPATION IN SWEEPSTAKES:

(i) to verify your identity; and

(ii) to distribute prizes to you.

(I) INFORMATION ABOUT YOUR USE OF SOCIAL MEDIA PLUG-INS:

(i) to allow you to easily share our content via social media platforms.

(J) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES: :

(i) to detect illegal or malicious activity in our Products.

(K) INFORMATION FROM LIVE-OPS SOFTWARE:

(i) to provide certain in-game features and functionality.

(L) INFORMATION FOR USER ACQUISITION AND CORE / CUSTOM / LOOKALIKE AUDIENCES:

(i)to acquire new users for our Products, to measure the performance and effectiveness of our marketing campaigns and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.

3. sharing of your information

We may share information we collect for the following purposes:

Service Providers. With service providers that perform services on our behalf or enhance our Services, including hosting services, customer service, analytics services and to assist us in our marketing efforts;

Payment Processors. With third-party payment processors that process payments you make;

Advertising Partners. Advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts, including as described in the Online Advertising section below;

Affiliates. With our parent company, subsidiaries and other affiliates;

Professional Advisors. With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;

Authorities and others. With law enforcement and public authorities, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above;

Business Transferees. With acquirers and other relevant participants (and their advisors) in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Studio or our affiliates (including, in connection with a bankruptcy or similar proceedings); and

Your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

4. Children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not knowingly collect Personal Data from them. We define “children" as follows:

Residents of the UK: anyone under 13 years old.

Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.

Residents of the Republic of Korea, anyone under 14 years old.

Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.

5. Data Protection Rights

You, and your legal guardian if you are a minor, have certain data protection rights under applicable law. Your rights under applicable law may include:

a) Access to the personal information we process about you as well as the right to data portability,

b) The right to have personal information corrected or erased,

c) The right to restrict the processing of your personal information

d) The right to withdraw your consent at any time for consent we have obtained from you, although this will not affect the lawfulness of the processing prior to the withdrawal.

e) You also have the right to object, at any time, to the processing of your personal information which is based on BNEI’s legitimate interests.

f) Where we process your personal information for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your personal information for such purposes. In that case we may still send you transactional or relationship messages, but only about our ongoing business relations.

g) The right to not be discriminated against for exercising these rights.

To exercise these rights, you should make a request using our contact details set out below. If you are not satisfied with the way we handle your request, and your country of residence has a supervisory authority, you may lodge a complaint with such supervisory authority in your country of residence. We do not provide different levels of service if you exercise these rights. However, if you request that we delete or cease collecting information which is necessary to ensure adequate functioning of the Services, you may not be able to use all or some parts of our Services.

Storing and deleting data：

Personal information collected through the Services is being stored and deleted in compliance with privacy requirements. All data will be de-identified or deleted if no longer required for the purposes mentioned above, unless further retention is required by law.

6. Your information security

We will not sell or rent your personal data to others, we will only share your personal data as described below:

- other users.

Share with other users/friends if you choose to share such information;

- service provider.

Third party suppliers, service providers, contractors or agents who perform functions on our behalf may not be located in your home country.

- Business transfer.

We may transfer the information we collect from you to another company if we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of bankruptcy proceedings .

- Responding to legal process.

To comply with the law, judicial process, court order, or other legal process, such as in response to a court order or subpoena.

- Protect us and others.

We believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or participation as evidence in litigation.

- We may share and disclose aggregated or de-identified information about users of the Services with third parties for marketing, advertising, research, analytical or similar purposes.

- For any other purpose with your consent. To help ensure a safe and secure player experience, we continually develop and implement administrative, technical and physical security measures to protect your data from unauthorized access or loss, misuse or alteration.

Right of access and portability: You have the right to request that we notify you of, and obtain a copy of, the PI we collect, use and share about you.

Right to rectification: You have the right to rectify your information, restrict processing and object to the use of your PI in certain circumstances provided by law.

Right to object: In certain circumstances, you have the right to object to the processing of your PI. For example, you have the right to object to the use of your PI for direct marketing purposes.

Right to restriction: In certain circumstances, you have the right to restrict the processing of your PI.

Right to erasure: Under certain circumstances provided by law, you have the right to request that we delete the PI we have collected or retained about you.

In some cases, your choice to provide, change or delete information may affect our ability to provide services or your user experience.

We may refuse to process a request that is not otherwise required by applicable law.

You have the right not to be unlawfully discriminated against for exercising these rights.

If the user requests to modify the personal information, the user information shall not be used or provided until the modification is completed to ensure the use and provision of accurate personal information.

If such information has been provided to any third party, the recipient will be notified immediately of the change so that the information can be amended.

If you wish to delete your personal data,

- Withdraw your consent in game settings

7. Contact us

If you have any questions or concerns about any matter relating to this Privacy Policy, including exercising any of your rights, please contact us at: otebe.smart@gmail.com