1. Introduction
We, as Boa Ventures Yazılım Sanayi ve Ticaret Anonim Şirketi (“Boa”), are a technology company that designs and
develops mobile games. With this Privacy Policy, we intend to explain our online and offline information
practices, the kinds of information we may collect, how we intend to use, process, store, protect, disclose, and
share that information, and how you can opt out of a use or correct or change such information.
develops mobile games. With this Privacy Policy, we intend to explain our online and offline information
practices, the kinds of information we may collect, how we intend to use, process, store, protect, disclose, and
share that information, and how you can opt out of a use or correct or change such information.
This Privacy Policy applies to websites, mobile applications, forums, and every kind of blogs of Boa and any
other online or offline services provided by Boa. It also applies to our marketing and advertising activities
on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we
refer to our games and websites and other services collectively as our “Services”.
other online or offline services provided by Boa. It also applies to our marketing and advertising activities
on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we
refer to our games and websites and other services collectively as our “Services”.
By downloading our mobile application, accessing and/or playing our games, or interacting with our websites or
other Services; or somehow communicating with Boa, Boa may collect information about you in accordance with
the nature of the information and transaction within the current technical possibilities. You accept,
acknowledge, and promise that your personal information and data might be used in limited manner by Boa and/or
through Boa to the extent that it is limited to the format and purposes set forth in this Privacy Policy. If
you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you
should not use our games or other Services.
other Services; or somehow communicating with Boa, Boa may collect information about you in accordance with
the nature of the information and transaction within the current technical possibilities. You accept,
acknowledge, and promise that your personal information and data might be used in limited manner by Boa and/or
through Boa to the extent that it is limited to the format and purposes set forth in this Privacy Policy. If
you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you
should not use our games or other Services.
Every type of information related to an identified or identifiable natural person constitutes personal data.
Processing your personal data signifies all types of transactions performed on the data such as obtaining,
recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible,
alignment and preventing access.
Processing your personal data signifies all types of transactions performed on the data such as obtaining,
recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible,
alignment and preventing access.
Please note that Boa is not responsible for the actions of Platforms (defined below), the content of their
sites, the use of information you provide to them or any services they may offer.
sites, the use of information you provide to them or any services they may offer.
Boa reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your
acceptance of the changes to this Privacy Policy.
acceptance of the changes to this Privacy Policy.
2. The Identity of the Data Controller
The data controller is Boa Ventures Yazılım Sanayi ve Ticaret Anonim Şirketi, registered with the İstanbul Trade
Registry with number 238059-5 whose residing at Koşuyolu Mah. Cenap Şahabettin Sok. No:91 Kadıköy, İstanbul, Turkey.
Registry with number 238059-5 whose residing at Koşuyolu Mah. Cenap Şahabettin Sok. No:91 Kadıköy, İstanbul, Turkey.
3. How We Collect Your Personal Data
We may collect personal data automatically whenever you download or use or Services to your device, whenever
you send us your feedbacks or convey your information or support requests directly to Boa, from the
Facebook, Apple App Store and Google Play App Store (Referred to as “Platforms” together)
platforms and the business partners or other third-party companies who have obtained your consent or have
another legal right to share such personal with us (including advertising platforms and partners and data
aggregators who have obtained). This may include attributes about you and your interests, as well as other games
and services you use, demographic and general location information. We will use your personal data as described
in this Privacy Policy.
you send us your feedbacks or convey your information or support requests directly to Boa, from the
Facebook, Apple App Store and Google Play App Store (Referred to as “Platforms” together)
platforms and the business partners or other third-party companies who have obtained your consent or have
another legal right to share such personal with us (including advertising platforms and partners and data
aggregators who have obtained). This may include attributes about you and your interests, as well as other games
and services you use, demographic and general location information. We will use your personal data as described
in this Privacy Policy.
3.1. Personal data that is collected directly from you while you are using Services:
By downloading, accessing and/or playing our games or using our other Services, you consent to the collection
of your personal data by Boa. When you use Services via Platforms, Boa may collect certain personal data
from you and/or your device. Most of this data comes directly from you or your device, such as your unique
device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk
space, hardware type, Identifier For Advertising (IDFA for IOS devices and GAID for Android devices),
advertising ID, the version of your operating system (“OS”), your device name, game center ID,
and your location based on your Internet Protocol (“IP”). We use this data to provide our games
and Services to you, to provide better service to you, to make suggestions, to improve its services, to improve
and update our Services, to facilitate the use of Services at the works related to your interest and
preferences, including for the purposes of optimization, customizing and in-game offers and verifying purchases,
within the framework of legal legislation. We may also use it for the other purposes set out in this Privacy
Policy.
of your personal data by Boa. When you use Services via Platforms, Boa may collect certain personal data
from you and/or your device. Most of this data comes directly from you or your device, such as your unique
device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk
space, hardware type, Identifier For Advertising (IDFA for IOS devices and GAID for Android devices),
advertising ID, the version of your operating system (“OS”), your device name, game center ID,
and your location based on your Internet Protocol (“IP”). We use this data to provide our games
and Services to you, to provide better service to you, to make suggestions, to improve its services, to improve
and update our Services, to facilitate the use of Services at the works related to your interest and
preferences, including for the purposes of optimization, customizing and in-game offers and verifying purchases,
within the framework of legal legislation. We may also use it for the other purposes set out in this Privacy
Policy.
Payments for in-app purchases are being carried out by the Platforms. Boa does not collect personal data such
as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment.
Boa does not have access to your credit card or bank account data. However, Platforms may share non-financial
payment information for the items your purchase is being shared with us to fulfil your order.
as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment.
Boa does not have access to your credit card or bank account data. However, Platforms may share non-financial
payment information for the items your purchase is being shared with us to fulfil your order.
If you choose not to create a Boa profile by connecting your Facebook account, the personal data that we
collect when you play our games will be anonymous, but we will collect device level identifiers and other
information associated with those identifiers including:
collect when you play our games will be anonymous, but we will collect device level identifiers and other
information associated with those identifiers including:
- the type of device(s) you are using to play our games or access our Services, identifiers such as IP
address, device identifiers, ad identifiers, a Boa- player ID, and the country or region that you are
playing in; and - how you play our games and interact with our websites (such as level start, level end, session start,
booster use, spending, rewards, your progress through the games, session time and duration, number of
attempts at each level and purchases made). - your profile photo, your first and last name, your game username (your username and score can be viewed by
other users in our games that include a scoreboard feature).
Providing and optimizing our Services
We use your personal data to enable us to provide our websites, advertising, and other Services to you and to
optimize all of them so that we can make them the best they can be for you and all our players. This will
include use and analysis of aggregated data to make sure that our websites work properly on all devices and are
as enjoyable as they can be for all our players.
optimize all of them so that we can make them the best they can be for you and all our players. This will
include use and analysis of aggregated data to make sure that our websites work properly on all devices and are
as enjoyable as they can be for all our players.
Customer Services
We use your personal data, including contact information (e-mail) that you provide directly to us in
communications, to provide you with technical support through our customer service channels when you need it or
contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests,
communicating with you, as part of customer service or to send you updates about our games and Services.
Finally, we will use your data to manage your account and relationship with us and improve your experience when
you use our Services.
communications, to provide you with technical support through our customer service channels when you need it or
contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests,
communicating with you, as part of customer service or to send you updates about our games and Services.
Finally, we will use your data to manage your account and relationship with us and improve your experience when
you use our Services.
User Reviews/Comments
From time to time, you may share your comments about our games and provide certain information that may include
personal data. All personal data collected from your participation in such reviews is provided by you
voluntarily. We may use such personal data to solve issues you encountered, to fulfil your requests, to improve
our products, websites and/or Services and in any manner consistent with the policies provided herein.
personal data. All personal data collected from your participation in such reviews is provided by you
voluntarily. We may use such personal data to solve issues you encountered, to fulfil your requests, to improve
our products, websites and/or Services and in any manner consistent with the policies provided herein.
Analytics and Research
We use analytics tools, which may include third party analytics tools, to collect information about how you
play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may
use your data to carry out research, surveys or to engage directly with you, for example by sending you
communications (including by email), for these purposes.
play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may
use your data to carry out research, surveys or to engage directly with you, for example by sending you
communications (including by email), for these purposes.
Promotions and Competitions
From time to time we may run promotions or competitions during which we may collect certain personal data from
you, such as your name, address, post code, email address or other information or content submitted in order for
you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use
personal data that you provide in relation to that competition for the purposes of running the
competition.
you, such as your name, address, post code, email address or other information or content submitted in order for
you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use
personal data that you provide in relation to that competition for the purposes of running the
competition.
Chat
Some of our Services include chat functionality. Users of our chat service(s) can send messages to other
players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your
recipients to view your message history (although please note that after the relevant period of time which is
determined by us, your in-game chat messages will no longer be accessible). We reserve the right to review the
content of your messages, including by using automatic filters, to ensure that you are complying with our terms
of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of
any message for any reason.
players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your
recipients to view your message history (although please note that after the relevant period of time which is
determined by us, your in-game chat messages will no longer be accessible). We reserve the right to review the
content of your messages, including by using automatic filters, to ensure that you are complying with our terms
of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of
any message for any reason.
Cheating, Crime and Fraud Prevention
We may use personal data that we hold to prevent cheating, crime, or fraud. We may also need to pass your
information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as
the police.
information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as
the police.
Legal Uses
We may use your data as required or permitted by any applicable law.
We may use your data as required or permitted by any applicable law.
3.2. Personal Data Collected from Third Parties
As mentioned above, most of the
information that we collect about you comes directly from you when you play our games, or interact with our
websites, advertising, or other Services. However, when you allow third party companies to access to your
personal data (e.g., downloading our mobile applications through Platforms), we also collect information from
such Platforms.
As mentioned above, most of the
information that we collect about you comes directly from you when you play our games, or interact with our
websites, advertising, or other Services. However, when you allow third party companies to access to your
personal data (e.g., downloading our mobile applications through Platforms), we also collect information from
such Platforms.
Connection of Facebook Account
Boa may collect your first and last name if you are
connected to the Services via Facebook. When you log in to your Boa profile using your Facebook account
details, we will receive some of your Facebook account information. If you choose to play our games online, your
basic Facebook account information will automatically be associated with your Boa profile. Exactly what
information we receive is Facebook ID, profile picture and your name. If you do this, you will be able to use
your account to log in on multiple devices and synchronize progress across those devices. Where available, you
will also be able to see which of your friends are playing the same game and their progress through the games
(and they will be able to see you and your progress), or access other functionality we make available in our
games and other Services, such as inviting friends to play.
Boa may collect your first and last name if you are
connected to the Services via Facebook. When you log in to your Boa profile using your Facebook account
details, we will receive some of your Facebook account information. If you choose to play our games online, your
basic Facebook account information will automatically be associated with your Boa profile. Exactly what
information we receive is Facebook ID, profile picture and your name. If you do this, you will be able to use
your account to log in on multiple devices and synchronize progress across those devices. Where available, you
will also be able to see which of your friends are playing the same game and their progress through the games
(and they will be able to see you and your progress), or access other functionality we make available in our
games and other Services, such as inviting friends to play.
We will also collect the email account associated with your Facebook account and the name and avatar of those
of your Facebook friends that are already playing our games. You can choose not to allow us to access your email
address in the Facebook dialog box the first time at which you associate your Facebook account with your Boa
profile.
of your Facebook friends that are already playing our games. You can choose not to allow us to access your email
address in the Facebook dialog box the first time at which you associate your Facebook account with your Boa
profile.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will
not receive any information about your Facebook friends who do not play our game. If you do not wish your
Facebook friends to be able to see you and your progression in our game, you can prevent this by disconnecting
from Facebook from our game and updating your app permissions from within your Facebook settings.
not receive any information about your Facebook friends who do not play our game. If you do not wish your
Facebook friends to be able to see you and your progression in our game, you can prevent this by disconnecting
from Facebook from our game and updating your app permissions from within your Facebook settings.
We would recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/privacy/explanation) and
review your privacy settings from time to time to make sure that you understand fully how your Facebook data is
shared.
review your privacy settings from time to time to make sure that you understand fully how your Facebook data is
shared.
Installation of our Mobile Applications via App Store and Google Store
When you install or
purchase items related to our mobile apps (such as those you can purchase/download via Platforms), Boa does
not have access to your credit card or bank account data. However, Platforms stated above may share
non-financial payment information with us related to your purchases, like the items purchased to fulfill your
order. The personal data received from the Platforms will depend on privacy settings on relevant Platform
applications.
When you install or
purchase items related to our mobile apps (such as those you can purchase/download via Platforms), Boa does
not have access to your credit card or bank account data. However, Platforms stated above may share
non-financial payment information with us related to your purchases, like the items purchased to fulfill your
order. The personal data received from the Platforms will depend on privacy settings on relevant Platform
applications.
4. Purposes for Processing of Your Personal Data
We collect and use your personal data
for the following purposes:
- to enable us to provide our games, to ensure that your purchases are activated in the games, and to provide
you with player support if you need it; - to enable us to optimize our games for you and for the device that you are using, as well as to deliver
customized in game events, offers and promotions; - For the other purposes as set out in this Privacy Policy, including for marketing and advertising purposes;
- to operate, improve and optimize our games and other Services;
- to personalize our Services, understand our users and their preferences to enhance user experience and
enjoyment using our Services and improve our users’ experience; - to provide access to certain areas, functionalities and features of our Services;
- to notify you about in-game updates, new products, or promotional offers;
- to send related information, including confirmations, technical notices, updates, and security alerts and
support and administrative messages; - to enable players to communicate with each other in games or on our social media accounts;
- to respond to your comments and inquiries and provide customer support services;
- to prevent potentially prohibited or illegal activities and protect of our players;
- to measure interest in our Services;
- to ensure internal quality control;
- to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our terms of
service or where necessary to defend, exercise or establish our legal rights - to contact you as a part of our recruitment processes; and
- as otherwise expressly set out in this Privacy Policy or as required by law.
5. The Legal Grounds of Processing Your Personal Data
The legal grounds that Boa
relies upon while processing your personal data are the following:
-
- Explicit consent and/or your request
- In cases where it is necessary to disclose such information in accordance with applicable laws or
regulations or a court judgment or administrative order issued - Being necessary for the establishment and execution of an agreement
- Being necessary for Boa to fulfil its legal obligations as a data controller
- Being necessary for the establishment, exercise, and protection of any right
- Without prejudice to your fundamental rights and freedoms, being compulsory for Boa’s statutory interests
In data processing activities where your personal data is processed based on the explicit consent, you have
the right to withdraw your consent at any time.
the right to withdraw your consent at any time.
Boa’s statutory interest in processing your device and usage data is to provide better service to you, to
make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services
at the works related to your interest and preferences, within the framework of legal legislation.
make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services
at the works related to your interest and preferences, within the framework of legal legislation.
Boa undertakes to keep your data and any confidential information strictly private and confidential, without
prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures
and act in due diligence to prevent all or any part of your information from entering into the public domain or
be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to
any third party. If, despite all necessary data security measures taken by Boa, the confidential information
is damaged because of attacks on the system or captured by third parties, Boa shall have no responsibility
with that respect.
prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures
and act in due diligence to prevent all or any part of your information from entering into the public domain or
be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to
any third party. If, despite all necessary data security measures taken by Boa, the confidential information
is damaged because of attacks on the system or captured by third parties, Boa shall have no responsibility
with that respect.
Boa shall not be responsible for damages caused by the use of information that you disclose in comments or
messages given by third parties in public areas. If you share your name, password, etc. used by you when
creating the membership record with third parties, the Boa shall not be responsible for any damages that may
arise from the information shared with third parties.
messages given by third parties in public areas. If you share your name, password, etc. used by you when
creating the membership record with third parties, the Boa shall not be responsible for any damages that may
arise from the information shared with third parties.
6. The Transfer of Your Personal Data
In case a public institution is authorized to
request personal data by the law, your personal data can be transferred to such authorized public institution in
accordance with the applicable personal data protection legislations. Requests from judicial authorities will
also be fulfilled in accordance with the applicable legislation.
Your personal data may be transferred to our business partners and service providers only if it is required to
provide Services with you. The types of Service Providers (data processors) to whom we entrust
include companies that provides:
provide Services with you. The types of Service Providers (data processors) to whom we entrust
include companies that provides:
(i) provision IT and related services;
(ii) provision of information and services you have
requested;
(iii) customer service activities;
(iv) analytics and search engine activities that assist us
in the improvement and optimization of the Services; and
(v) any supporting activities in connection with our
Services. Boa has executed appropriate contracts with the service providers that prohibit them from using or
sharing personal data except as necessary to perform the contracted services on our behalf or to comply with
applicable legal requirements.
(ii) provision of information and services you have
requested;
(iii) customer service activities;
(iv) analytics and search engine activities that assist us
in the improvement and optimization of the Services; and
(v) any supporting activities in connection with our
Services. Boa has executed appropriate contracts with the service providers that prohibit them from using or
sharing personal data except as necessary to perform the contracted services on our behalf or to comply with
applicable legal requirements.
We may access, preserve, and disclose your personal data, other account information and content if we believe
doing so is required or appropriate (e.g. required by Law and similar disclosures):
doing so is required or appropriate (e.g. required by Law and similar disclosures):
(i) to comply with law enforcement or national security requests and legal process, such as a court order or
subpoena;
(ii) to respond to your requests;
(iii) to protect yours, ours or others’ rights, property or
safety;
(iv) to enforce Boa Games’ policies or contracts;
(v) to collect amounts owed to Boa
Games;
(vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss
or in connection with an investigation or prosecution of suspected or actual illegal activity; or
(vii) if
we, in good faith, believe that disclosure is otherwise necessary or advisable.
subpoena;
(ii) to respond to your requests;
(iii) to protect yours, ours or others’ rights, property or
safety;
(iv) to enforce Boa Games’ policies or contracts;
(v) to collect amounts owed to Boa
Games;
(vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss
or in connection with an investigation or prosecution of suspected or actual illegal activity; or
(vii) if
we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes (e.g., to detect unauthorized
activity on the Services). In such cases, server log data containing IP addresses may be shared with law
enforcement bodies, so they may identify users in connection with their investigation of the unauthorized
activities.
activity on the Services). In such cases, server log data containing IP addresses may be shared with law
enforcement bodies, so they may identify users in connection with their investigation of the unauthorized
activities.
7. International Transfer
All personal data collected via or by Boa may be stored
anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the
cloud, on our servers and on the servers of our affiliates or the servers of our service providers. When we
transfer your personal data internationally, we will take reasonable steps to ensure that it is treated
securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to
jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored,
used, or processed in may be different from the privacy laws applicable to the place where you are
resident.
All personal data collected via or by Boa may be stored
anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the
cloud, on our servers and on the servers of our affiliates or the servers of our service providers. When we
transfer your personal data internationally, we will take reasonable steps to ensure that it is treated
securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to
jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored,
used, or processed in may be different from the privacy laws applicable to the place where you are
resident.
By providing information to Boa, you consent to the storage of your personal data in these locations.
If you are using our Services from the European Union or other regions with laws governing data collection and
use, please note that you are agreeing to the transfer of your information to Turkey and the United States and
to processing of your data globally.
use, please note that you are agreeing to the transfer of your information to Turkey and the United States and
to processing of your data globally.
By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any
dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of
Turkey.
dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of
Turkey.
8. Marketing
We and our third-party partners may use personal data collected about you to send you marketing communications
about our mobile applications and related Services based on your interests. For example, we may serve ads within
our Services or place ads on third party websites and apps.
about our mobile applications and related Services based on your interests. For example, we may serve ads within
our Services or place ads on third party websites and apps.
We may use the information that we hold about you to promote Boa’s Services in several ways. This might
include:
include:
- advertising within third party websites and apps;
- offering you customized promotions for our services in the game you play;
- offering you in-game advertisements and special offers regarding the Boa services and games.
Information used for Marketing
We use information about you to try to make sure you only see marketing from us that might be of interest to
you. This includes using information that we may have about you, such as:
you. This includes using information that we may have about you, such as:
- ad identifiers and other non-personal data collected from your device;
- the games you play and information about how you interact with our games and Services;
- country or region; and
- other information that we might acquire from our third-party marketing partners or other third parties who
have obtained your consent or have another legal right to share that information with us.
Marketing Partners
When we market our games in media published by other companies, we use various third-party marketing partners
to assist us on our behalf, and we may share data which we have collected about you with such third parties for
these purposes.
to assist us on our behalf, and we may share data which we have collected about you with such third parties for
these purposes.
Our marketing partners may help us to serve ads to you by combining this information with data which they have
collected about you elsewhere. They collect this information when you use their services or the websites and
services of third parties. Our partners use this information to make assumptions about the kinds of advertising
you would prefer to see. If they determine that you would be interested to see an advert for Boa’s games or
Services, they will serve you with a Boa ad while you are using other websites and services.
collected about you elsewhere. They collect this information when you use their services or the websites and
services of third parties. Our partners use this information to make assumptions about the kinds of advertising
you would prefer to see. If they determine that you would be interested to see an advert for Boa’s games or
Services, they will serve you with a Boa ad while you are using other websites and services.
If you would prefer that your personal data is not processed to receive interest-based ads, you can submit an
opt-out request by contacting us via [email protected]. You should
note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and
you may see advertising for Boa products, but that advertising will not be targeted using your personal
data.
opt-out request by contacting us via [email protected]. You should
note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and
you may see advertising for Boa products, but that advertising will not be targeted using your personal
data.
This Privacy Policy does not apply to the collection of your data by our marketing partners. We recommend that
you review our partners’ privacy policies for more information.
you review our partners’ privacy policies for more information.
Cookies Used by the Third Parties
Service providers acting on our behalf, may use cookies or similar technologies to automatically collect
information through the Services. Cookies are small text files placed in users’ computer browsers to store their
preferences. Cookies belonging to such service providers may be set on your device when using our website or
Services. Cookies relating to the website will be used by service providers for the purposes set forth
below:
information through the Services. Cookies are small text files placed in users’ computer browsers to store their
preferences. Cookies belonging to such service providers may be set on your device when using our website or
Services. Cookies relating to the website will be used by service providers for the purposes set forth
below:
- Operationally Necessary: We may use cookies, web beacons or other similar technologies that
are necessary to the operation of our sites, services, applications and tools. This includes technologies
that allow you access to our sites, services, applications and tools and that are required to identify
irregular site behavior, prevent fraudulent activity and improve security. - Performance Related: We may use cookies, web beacons or other similar technologies to
assess the performance of our websites, applications, services and tools, including as part of our analytic
practices to help us understand how our visitors use our websites. - Functionality Related: We may use cookies, web beacons or other similar technologies that
allow us to offer you enhanced functionality when accessing or using our sites, services, applications or
tools. This may include identifying you when you sign into our sites or keeping track of your specified
preferences, interests or past items viewed so that we may enhance the presentation of content on our sites. - Advertising or Targeting-related: We may use first-party or third-party cookies and web
beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites.
This includes using technologies to understand the usefulness to you of the advertisements and content that
have been delivered to you, such as whether you have clicked on an advertisement.
Opting Out of Cookie Tracking: You can set your web browser to warn you about attempts to
place cookies on your computer or limit the type of cookies you allow. Flash Cookies operate differently than
browser cookies, and cookie management tools available in a web browser may not remove flash cookies.
Please be advised that if you disable cookies, you may lose some of the features and functionality of our
Services because the cookies are necessary to track and enhance your activities.
Services because the cookies are necessary to track and enhance your activities.
9. Ad identifiers, Software Development Kits and Similar Technologies
To provide our
games, websites and interest-based advertising, we use ad identifiers, software development kits and similar
technologies. This section describes our use of these technologies.
Ad identifiers and similar technologies are used by us to provide our Services to you and in order to
collect data from your device. These technologies allow us and our third-party advertising partners to:
collect data from your device. These technologies allow us and our third-party advertising partners to:
- recognize you and your device;
- provide interest-based advertising to you;
- allow our Services to interact with a third-party social network or Platform (where you have chosen to allow
such interaction); - enable us and third parties to provide you with more customized services, for example to provide our
Services in the correct language.
Work of Ad Identifiers and Similar Technologies
Ad identifiers are non-permanent,
non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising, which are
uniquely associated with your device. Similar technologies include tracking pixels within ads. These
technologies allow companies (including marketers and advertisers) to recognize your device when you use
Websites and applications.
Options of Opt-out from Interest-based Advertising
- Opting out of interest-based advertising at a device level: You can choose to prevent your
device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad
identifier, by changing the settings of your device. Settings vary from device to device, but you will
usually find the ad identifier settings under “privacy” or “ads” in your device’s settings. - Opting out of Facebook advertising: To update your advertising preferences with Facebook,
you will need to log in to your account on Facebook and update your settings there.
10. Your Rights Regarding the Protection of Your Personal Data
You have certain rights in connection with your personal data and how we handle it. You can exercise these
rights at any time by contacting us via any of the methods set out in the Contact Us section below.
rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
- Access to personal data: You have the right to access your personal data that Boa Games
is using. - Correction or deletion of personal data: You have the right to ask Boa Games to correct
or complete your personal data if it is wrong or incomplete. You may also have the right to ask Boa Games
to delete your personal data, when certain conditions apply. Such requests should be sent to [email protected] - Account deactivation: Should you wish to completely deactivate your account include
disassociating your Facebook account from our current and future mobile games and deleting our games from
your mobile devices. Please note that if you completely deactivate your account all your progress in our
games and any unspent virtual items will be lost and we may not be able to restore them in the future. - Restriction on processing of personal data: You may have the right to ask Boa Games to
restrict the use of your personal data, when certain conditions apply. - Object to processing of personal data: You may have the right to object to the use of your
personal data by Boa Games, when certain conditions apply. - Portability of personal data: You may have the right to receive your personal data in a
structured and commonly used format so you can use this data with another company, when certain conditions
apply. - Right to opt-out (California, USA): California residents have the right to opt out of the
sale of personal data, which is defined in a way that may include the transfer of data to third parties to
personalize ads for you. If you opt out of the ‘sale’ of your data, we will not sell your data, including to
our advertising partners, but you may still see ads in the game and some of our partners may deliver ads to
you, based on information they hold on you. - Rights under GDPR: The GDPR is a regulation intended to strengthen and unify data
protection for all individuals within the EU. It aims to protect the fundamental right to privacy and the
protection of personal data. Boa Games is committed to data protection and has taken steps to align with
the GDPR. You can exercise your rights to review or request the permanent deletion of your personal data by
submitting a request to our support team at [email protected].
Please make sure to choose “Account Information” as the topic and “Privacy” as a sub-topic. If you do not
want to permanently delete your account, you may deactivate your account instead, and activate it again any
time. Please be advised that by deleting your personal data, all game progress and any related asset will no
longer be restorable. If you have any questions or comments in regards to privacy matters please send us a
message at [email protected].
There are other ways in which you can control the personal data that we collect about you. For instance,
you could disconnect your Facebook or other social network account from our games, or delete our games from your
mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the
settings in your phone.
you could disconnect your Facebook or other social network account from our games, or delete our games from your
mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the
settings in your phone.
We may occasionally send you push notifications through our mobile applications with game updates, high scores
and other notices that may be of interest to you. You may at any time opt out from receiving these types of
communications by changing the settings on your mobile device.
and other notices that may be of interest to you. You may at any time opt out from receiving these types of
communications by changing the settings on your mobile device.
If you believe we have misused your data or violated any data protection regulations, you may file a complaint
with a Data Protection Authority, for example, the Authority of your place of residence.
with a Data Protection Authority, for example, the Authority of your place of residence.
You can submit all your claims, deletion requests and questions with respect to such rights to [email protected]. Your requests will be answered as soon as
possible and within thirty days at latest.
possible and within thirty days at latest.
There are other ways in which you can control the personal data that we collect about you. For instance, you
could disconnect your Facebook or other social network account from our games, or delete our games from your
mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the
settings in your phone.
could disconnect your Facebook or other social network account from our games, or delete our games from your
mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the
settings in your phone.
11. Children’s Privacy
Most of Boa Services and games are not intended for children under the age of 13 and Boa does 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 Boa Services.
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 Boa Services.
You must be over 13 years old to play our games and use our Services. We do not collect personal data from
anyone under 13 years old person knowingly and willfully. However if the Services are used by such person in
contradiction to this Privacy Policy, we may collect personal data from such person. If you believe that we
might have any information from or about a child under 13 years old, please contact us.
anyone under 13 years old person knowingly and willfully. However if the Services are used by such person in
contradiction to this Privacy Policy, we may collect personal data from such person. If you believe that we
might have any information from or about a child under 13 years old, please contact us.
12.Legal Bases (for European Economic Area users)
If you are an individual in the
European Economic Area (EEA), we collect and process personal data about you only where we have legal bases for
doing so under applicable EU laws. The legal bases which we rely upon are the following:
- Contractual Necessity: This covers data used by us in order to provide you with Services
that you have requested – and that we have agreed – to provide to you, such as our games, customer services,
chat functionality and third-party social network connectivity; - Legal Obligation: This covers data used by us to comply with a legal obligation, such as to
maintain records relating to tax or to respond to a valid legal request for certain data; - Legitimate Interests: This covers data used by us for purposes that are not harmful to your
privacy and can be reasonably expected within the context of your use of our Services, such as marketing,
advertising, analytics, research and optimization of our games and other Services; and - Consent: This is used as a legal basis in the following contexts: the collection of data
stored on your device by us and our advertising partners, including device information, ad identifiers, IP
address, country and region. You consent to this collection when you agree to install our game and you can
withdraw your consent to this by uninstalling our games.
In this Privacy Policy we have explained how you can opt out of certain types of processing that we
undertake and where any processing is based on your consent, you can withdraw that consent at any time in the
ways described in this Privacy Policy. Nonetheless, if you play our game we will still collect some personal
data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect
any personal data about you at all, you should cease playing our games and stop using our Services.
undertake and where any processing is based on your consent, you can withdraw that consent at any time in the
ways described in this Privacy Policy. Nonetheless, if you play our game we will still collect some personal
data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect
any personal data about you at all, you should cease playing our games and stop using our Services.
13. Data Retention
Boa retains the personal information collected as described in this Privacy Policy for as long as you use our
Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve
disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements
and comply with applicable laws.
Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve
disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements
and comply with applicable laws.
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.
business interests, such as to comply with our legal obligations, resolve disputes, and enforce our
agreements.
14. Security
The personal data that you provide to Boa is stored on servers that are located in secured facilities and
protected by protocols and procedures designed to ensure industry-standard security of such data such as
firewalls and data encryption. However, no server, computer or communications network or system or data
transmission over the internet can be guaranteed to be 100% secure. As a result, while Boa strives to protect
your personal data, Boa cannot ensure or warrant the security of any personal data you transmit to Boa or
through the Services.
protected by protocols and procedures designed to ensure industry-standard security of such data such as
firewalls and data encryption. However, no server, computer or communications network or system or data
transmission over the internet can be guaranteed to be 100% secure. As a result, while Boa strives to protect
your personal data, Boa cannot ensure or warrant the security of any personal data you transmit to Boa or
through the Services.
By using the Services or providing personal data to us, you agree that we may communicate with you
electronically regarding security privacy, and administrative issues related to your use of the Services. If we
learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the
Services or sending an e-mail to you.
electronically regarding security privacy, and administrative issues related to your use of the Services. If we
learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the
Services or sending an e-mail to you.
15. Changes to Our Privacy Policy and Practices
Revision to the Privacy Policy
We may revise this Privacy Policy at our sole discretion, so
review it periodically. If you continue to visit this Site and use the services made available to you after such
changes have been made, you hereby provide your consent to the changes.
We may revise this Privacy Policy at our sole discretion, so
review it periodically. If you continue to visit this Site and use the services made available to you after such
changes have been made, you hereby provide your consent to the changes.
Posting of Revised Privacy Policy
If there are any material changes to this Privacy Policy,
Boa will notify you by email or as otherwise required by applicable law. We will post adjustments to the
Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or
upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read
this Privacy Policy periodically.
If there are any material changes to this Privacy Policy,
Boa will notify you by email or as otherwise required by applicable law. We will post adjustments to the
Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or
upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read
this Privacy Policy periodically.
New Uses of Personal Information
Additionally, before we use personal information for
any new purpose not originally authorized by you, we will endeavor to provide information regarding the new
purpose and give you the opportunity to opt out. When consent of the individual for the processing of personal
information is otherwise required by law or contract, Boa will endeavor to comply with the law or
contract.
16. Contact Info of Data Controller
If you have any questions about the privacy
practices or this Privacy Policy, please contact Boa’s data protection officer by email at [email protected].
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