Privacy Policy


Your privacy is important to us. I Baram Games’s policy (referred in this document as “We”, “Company”, and “Baram Games”), to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our applications users and visitors of

https://baramgames.com (the “website”).


This Policy explains:

  • what is personal data;
  • what type of personal data We collect;
  • means and reasons to collect it;
  • subjects that we may share your personal data with;
  • ways of contacting us in regards to your personal data.

 

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

This policy is effective as of 28 April 2022.

Last updated: 04 May 2022


Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.


Statement regarding protection of your personal data

As a Company, we take data privacy seriously and do our utmost to protect any personal information we receive. We only process data on legal grounds that allow such processing, and always in strict compliance with applicable law and regulations permitting any such processing.


This Privacy Policy governs all our applications and services that are available for use on mobile devices, personal computers, or any other platforms including the website. This includes anything related to how we process and protect your personal data. Therefore, by using any of our applications and/or services you agree with this Policy.

As the data controller, we are responsible for your information. If you do not want us to collect and process this information in accordance with our Privacy Policy, then unfortunately you are not permitted to use our applications or services.

When we identify what data is collected and how that data will be processed, the Company becomes a “data controller” under various European legislations, including GDPR (General Data Protection Regulation) in Europe, 2018 Data Protection Act in the UK, and under Ukrainian Personal Data Law of 2010. We may also be a “data operator” following 1998 COPPA (Children’s Online Privacy Protection Rule).


We only process personal information under at least one of the following legitimate reasons, including but not limited to: 

• you have agreed to the processing of your data; 

• Processing is necessary to carry out an agreement with you (including any offer and acceptance), for example when you use our applications / services.

• such processing is required by the laws of the countries in which we offer our services or make our applications/services available; 

• the processing is for the legitimate interests of the company as a controller or a required third party, unless interests relating to the fundamental rights and freedoms of the data subject requiring data protection prevail over the interests set out above.

Moreover, please be advised, that that we do not ask for any sensitive personal information from our users/visitors.


Our Privacy Policy may be updated from time to time to comply with applicable law. Please visit this Policy periodically to see if any changes have been made. If you use our applications or services after update to this Policy, you consent to these changes. If you do not agree to the updates, you are required to stop using our applications / services (for example, by uninstalling the applications from your devices).


Also, in order to delete any personal information We may hold about you, feel free to delete or reinstall an app on your device.

The ways we collect and process your personal data

(A) The applications and/or services used by you may collect and process the following information about you:

  • geolocation (GPS location, country / state / region);
  • device information we collect includes the device name and model, operating system, browser type and language settings.
  • the device’s ID and the android advertisement ID (if authorised)
  • the progress of the game and activities, such as remembering the language selected by the user and the level of difficulty at a certain stage of use, are important.
  • the data collected by cookies and similar technologies.


(B) The following is some information that you may be asked to provide to us or our partners (third parties) while using our applications, services, and website:

  • your age;
  • name;
  • contact details (email / phone number);
  • pictures / photos;
  • your social media accounts;
  • payment details;
  • job related information (CV).

 

(C) We may also process other personal information that you submit to us voluntarily. However, if data processing for that information is not required for using our applications and/or services, or is not legally required, we will delete it.


Processing of children’s data

We consider users/customers who are under 13 years of age to be children, unless different age limits apply in their respective country (in certain jurisdictions, these are individuals under 16).


By default we neither collect nor process children’s personal data. However, as the demographic of our application includes children, among its users there are likely to be parents who might purchase services for their kids (such as buying a pro plan or in-app characters), you should be aware that it is possible your child’s information will be collected when using these services on behalf of your child.


The parents or guardians who order the services for children must agree to these terms and conditions of use of the application, as well as this policy. They are also responsible for ensuring the accuracy of the data and providing any necessary service to their child.


By continuing to use our applications or services, you confirm that you understand that personal data may be collected and processed in accordance with this Policy. If you are ordering our services for a child, you confirm that you have the consent of the child’s parent or guardian to do so.


When ordering a service or downloading an application for further use, the person who takes the relevant action is representing the legitimate interests of the child and is personally responsible for the child’s actions with this service and/or application in future.


Children must not share their real name, location, phone number or email address, or any other personal information, without the consent of their parents or other legal guardian.


We don’t encourage children to join a game by using our apps by offering a reward, and we don’t recommend other children’s activities that reveal more personal information about the child than is actually necessary to use the app.


We do not share any of our users’ personal data with any third parties. 

For more information about what third parties may get information about users and for what purposes, please see the relevant sections of this Policy below.

Purposes of personal data processing

We provide services and make applications accessible in most of the world. The information we collect about users / customers is mainly used to ensure the appropriate quality of our services, in particular, enhancing your gaming experience or improving functions and capabilities of our applications in future. We may analyse user data collected from application use to adapt tasks based on what a user needs so that they are more efficient with their time spent using an app made by this company.


Other reasons for using your personal information may include:


  • To provide you with the full range of our services;
  • Control age restrictions that comply with the laws of your country of residence;
  • Purchase a PRO plan or certain in-game characters; 
  • Customize the user experience for offers
  • Personalize the content;
  • Troubleshoot and troubleshoot;
  • Provide advice to users;
  • Use for administrative, analytical and statistical purposes;
  • Ensure and promote communication between users;
  • Provide promotional and marketing information, including special offer joint promotional offers from the Company and our partners;
  • Advertising, direct marketing and efficiency evaluation;
  • Manage and unsubscribe from subscriptions;
  • Protect against malicious actions of users and in relation to other aspects of the Company’s security;
  • Protect legitimate interests;
  • Comply with other legal requirements, including timely response to requests from stakeholders and supervisor/law enforcement agencies
  • Selection of candidates for work and employment in the company.


We rely on ads to generate revenue for the development, distribution, and technical support of our apps—most of which are free. For example, you may see third-party advertising while using our application.


Your specific consent is required to send promotional and marketing communications, which you may withdraw at any time by contacting the data protection officer.

Only provide the personal information necessary to fulfill the selected service. If you choose to disclose additional information, we will take measures to ensure it is processed securely.

In-app purchases

Some of our applications have in-app purchasing function (PRO plan or specific gaming characters).


Please note that all in-app purchases are processed by an external payment processor that may collect information directly from you. In particular, the payment processor may request the payer’s address and bank or credit card details in accordance with its own privacy policy (please review it before submitting such data to any external processor).

External payment processors do not share the information provided by you, and we do not have credit card details. However, we receive a summary about all purchases made, including the transaction amount, which is necessary to give access to your purchase in the application.

Some of our apps have an in-app purchase feature (by plan or specific game characters). Please be aware that all in-app purchases are processed by a third party payment processor, who may collect information directly from you.. 

Before sending your address and bank or credit card details to an external provider, please check the payment processor’s privacy policy.

Third party processors keep all of the information you provide to them confidential. They will never share your credit card information with anyone. However, we will receive a summary of all purchases made, including the transaction amount required for access in request if applicable.

Where is your personal data stored

In order to provide high level of personal information security Company uses cloud services of Google LLC (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4).

When your personal data might be disclosed

We may and sometimes might need to share personal information with third parties in certain cases to ensure that you use our applications or other services. This is because we use the services of other companies that automatically have limited access to certain information about you, for purposes such as administration, optimization, marketing support, sales and payment processing. 


The Company may also share information it receives with our counterparts whose services are used to improve the user experience and for the purposes described herein, depending on the vendor.


If you use social media features while using our applications, such as “liking” something on Facebook, this will enable data sharing between us and the relevant social platform.

Some of the service providers We use include:

  • Google Cloud (Google LLC): server infrastructure, big data;
  • Google Marketing Platform (Google LLC): analytic tools, marketing tools;
  • Google Firebase (Google LLC): analytic tools, consolidated bug and failure reports, push notification tool, remote configuration tool;
  • Unity (Unity Technologies): analytical tools, remote configuration tool.


The privacy policies of these service providers do not allow for the collection of information about specific users through our application. They implement and adhere to their own privacy policies, which are compliant with applicable regulations, including the GDPR

To learn more about how our counterparts process data, please read their respective privacy policies.


We may also share users’ data with third parties, such as governmental agencies, if we believe this information is necessary for the following purposes:

  • when required by a legitimate governmental agency (e.g. in court proceedings);
  • when it reveals, investigates and/or prevents fraud by users or any third parties;
  • when it safeguards the rights, property and/or security of the Company to the extent permitted by law.


Technical, administrative, and other data protection measures.

We have put in place a number of security measures to protect your personal data from unauthorized access, use or disclosure, and against accidental or unlawful loss, destruction or damage.


We at the company take data minimization seriously- only processing the information related to users, customers and clients that we need to in order to perform certain functions and for specific purposes. Your personal information is always kept safe and sound beyond the scope of necessary processing (such as when you send us your CV).

.

We have designed our website and applications to provide services in a way that would ensure the best possible privacy. 


When we share data with our partners, we always use the most safe and secure data communication channels.


The Company complies with the GDPR by taking measures to protect data disclosure to countries outside the European Economic Area or Switzerland, based on approved standard terms and conditions from the European Commission, or any other applicable provisions according to Article 46 of the GDPR.


However, the security of your data cannot be guaranteed in the case of unauthorized access to your devices that are outside of your control. The Company will not be liable for this.

How long is the of data processing / storage kept

We will only keep your data for as long as it is needed to achieve the purpose for which it is collected and processed, or to comply with regulatory requirements.


We identify the relevant storage period by identifying the nature and category of the personal data, the purposes of processing, and whether we can hit those purposes otherwise.


The Company will usually only process personal data for a maximum of three years after it was received. However, this may be extended if the user/customer is still using our application or other services.


However, other countries’ regulations may have additional requirements. The required data storage period may vary depending on the user’s location and the laws of the country that require proof of this period.


For example, if the country where our application or service user resides has a limitation of action provision that defines the time period during which they can file their claim or complaint against us, and we need proof of legal relations with them to comply with this rule, then we may process their personal data during this limitation. 


We need to consider any periods of time when we might have to keep your personal data so that we can comply with our legal commitments to you or supervisory authorities. 


We may gradually reduce the amount of personal data we use over time, or even make it anonymous so that it is no longer linked to you specifically. In this case, we can use this information without further notice, as it no longer contains any personal data.

Cookies and other tracking technologies 

Cookies are small text files that are placed on your device such as computer or mobile device by websites that you visit. The website will, for a certain period of time, remember your preferences and actions, so that you will not have to set them up again. Our cookies do not identify a specific user and only identify the device that is being used.


Cookies and other tracking technologies on our website and in our applications may be used in various ways, such as website operation, traffic tracking, or for advertising. In particular, we use cookies and other tracking technologies to improve the quality and efficiency of our services.


To learn more about what are cookies, how they work, how to manage or delete them, please visit www.allaboutcookies.org


Please note that setting of certain browsers allow prohibiting cookies and other tracking technologies. Please be aware that switching some cookies off will result into loss of functionality of our website or application, and, accordingly, you will not be able to use all of their options, and some features / services might not be working correctly.

Specific rights of subjects of the personal information

Rights of personal data subjects under the Ukrainian legislation


Please be advised of your rights under Ukrainian law with respect to the protection and processing of your personal data:

  • You should be aware of where your personal data is coming from, why it is being collected, and where it is being stored. You have the right to know who is responsible for managing your data, or to have your authorized representative receive this information on your behalf, unless the law says otherwise;
  • Understanding what personal data is accessed by third parties; 
  • Being able to see and change your personal data.
  • You will receive a response within 30 days as to whether your personal data is being processed, unless otherwise required by law. You will also receive the contents of such personal data.
  • Submit an objection to the processing of personal data on grounds that are substantiated.
  • If you believe your personal data is being processed illegally or inaccurately, you may submit a request to the data owner or manager for modification or deletion of that data.
  • The safeguarding of your personal data from any illegal processing and from accidental loss, destruction or damage caused by willfully hiding, failing to disclose, and protecting against disclosure of information that is inaccurate or is harmful to an individual’s reputation and business standing.
  • You can file complaints about the processing of your personal data to the relevant administrative agency for personal data protection in Ukraine, the Secretariat of the Verkhovna Rada Commissioner for Human Rights, or to court.
  • Take legal action in the event of any violation of data protection regulations; 
  • Provide statements of data processing limitations when agreeing to such processing;
  • Revoke you data processing consent;
  • Be aware of how automatic data processing works; 
  • Prevent automated decision-making that could have legal consequences..

 

GDPR and rights of personal data subjects

To begin the process of demanding information from us, you will be asked for your identification and to submit your requirements. This will allow us to review your inquiry and determine whether or not we can provide you with the information you are asking to gain access to. The list of data that we must provide to you is contained in Article 13 and Article 14 of the GD.


We do our best to process requests quickly, but please understand that preparing a response to a personal data request can be complex and may take up to a month or longer. If we need more time, we will let you know.

The GDPR has provided individuals with extra rights to safeguard their personal data.


The right to be informed

The company has provided facts about the personal data we process to anyone who requests it. If you require assistance with what personal data we process, you can contact our company s data protection officer.


The right to rectification

If you discover that any of the personal information that our company process is incorrect or obsolete, please contact us at the correspondence address provided.


On occasions, it is not possible to change your personal data. For example, if your personal data has already been used in an agreement or if it is written down in a document that has been submitted to a state agency or otherwise according to applicable law.


The right to data portability

You may be able to get your personal data from us in a format that can be read by computers, if this is something you need or have requested. If we agree to this, it means that you have the right to limit how we use your data. 


The right to restrict processing

You may request that we restrict our processing of your data to only those activities necessary for storage purposes. This means that we will terminate any other data processing activities, under certain circumstances


Withdrawal of data processing consent and the right to erasure

If you revoke your consent for us to process your personal data for marketing mailings, we will no longer process your data for that purpose.


You may also exercise your right to erasure. In cases referred to in Article 14 of the GDPR, the Company will delete the personal data being processed, other that the data that we are obliged to keep under applicable law.


If you are a parent of a child under 13 who has disclosed information to us without your consent, please notify us immediately and we will remove this information.

Rights in relation to automated decision making and profiling

The data subject has the right to not be subject to a decision that is based only on automated processing which produces legal effects that concern or significantly affect the data subject. We don’t use personal information for the purposes of marketing or creating targeted advertisement.

Complaints

The European Supervisory Authority for Data Protection may receive complaints from our users who reside in the EU. You may submit requests related to data protection and processing to the European Supervisory Authority for Data Protection.

Our data protection officer (DPO) is your go-to person for any questions or comments about your data protection and processing. To get in touch with our DPO, please fill out the Contact Form at: https://baramgames.com/contact-us



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