PRIVACY POLICY

Date of Last Update: 22th of June 2021

By downloading, installing, accessing or using our mobile game namely, DogemonGo (the “Game” ), you (hereinafter referred to as “you”, “your” or “User” ) consent to the information collection, disclosure and use practices as described in this Privacy Policy. The Game is developed and owned by FROZEN Ltd., a company registered in Belize, having its registered address at Belize City, Belize (hereinafter referred to as “we,” “us” or “our”). This Privacy Policy also sets out how we may collect, use and disclose information in relation to Users of the Game.

• 1. Information We Collect
  • 1.1 The Licensor hereby grants the Licensee a revocable, non-exclusive, non-transferable and limited license to use the Game in machine-readable form on any mobile device subject to the limitations and restrictions set forth in this Agreement.
  • 1.2 For downloading, installing, accessing or using the Game, you may be asked to submit the following types of personal data:
  • 1.2.1 Personal Data: This may include personal information relating to an identified or identifiable natural person, such as first name, last name, age, gender, e-mail address and such other information, data and materials as we may deem necessary for you to use the Game. We utilize third party companies who use customer data to connect with processing services for us. When you contact us through any of the communication modes as mentioned below, your e-mail address may be added to our mailing list from which you can unsubscribe at any time using the unsubscribe link in each e-mail or by contacting us at [email protected].
  • 1.2.2 Communication Data: This may include data relating to any communication that you send to us whether that be through the consultation/contact form on the Game, through e-mail or any other mode of communication that you use to contact us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of potential legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend potential legal claims.
  • 1.2.3 Technical Data: This may include data about your use of the Game and online services such as your IP address, your login data, details about your browser, length of visit to pages on the Game, page views and navigation paths, details about the number of times you use the Game, time zone settings and other technology on the devices you use to access the Game. The source of this data is from our analytics tracking system. We process this data to analyse your use of the Game and other online services, to administer and protect our business and the Game, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer the Game and our business and to grow our business and to decide our marketing strategy.
  • 1.2.4 Marketing Data: This may include data about your preferences in receiving marketing material from us and our third parties and your communication preferences. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our services, to develop them, to grow our business and to decide our marketing strategy.
  • 1.3 We may use Personal Data, Communication Data, Technical Data and Marketing Data (collectively the “Data”) as follows:
  • 1.3.1 If you post at the Game’s discussion forum (if any), we may ask you to provide your name and e-mail address.
  • 1.3.2 If you want to enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we will need your Personal Data as per the rules of the specific contest.
  • 1.3.3 If you choose to participate in a customer survey, if any, conducted by us or by one of our business partners, we may ask for your Personal Data as may be required by a particular survey.
  • 1.3.4 If you report a problem or submit a customer review, we will ask you to provide your Personal Data. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.
  • 1.3.5 If you decide to use the Game, we will collect Personal Data for the purposes of assessing your use of the same.
• 2. Name and Address of the Data Controller
  • 2.1 Data Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union (“EU”) and other provisions related to data protection is: E-mail: [email protected]
• 3. Consent and its Withdrawal
  • 3.1 When you download, install, access or use the Game, you provide us with your consent to use your Data as per this Privacy Policy. In order for you to use the Game, it is necessary for us to collect all relevant and necessary Data from you. In addition, by filling the forms available on the Game, you give us your express consent and permission to use your Data.
  • 3.2 We will process the Data only after taking written instructions/consent from you mostly in electronic form in the form of clickable button or a checkbox.
  • 3.3 If you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected].
• 4. Promotional Emails
  • 4.1 You agree that we may from time to time send e-mail messages to you which offer products and services, promotions, subscriptions or registration-based services or other material. If you wish to discontinue receiving such email, you may opt-out by writing us through email at [email protected]. Your preferences will then be updated.
• 5. How We Use and Process the Data
  • 5.1 The Data collected by us from you may be used to provide you our services and better understand your needs in relation thereto, to correspond with you and reply to any of your questions relating to our services.
  • 5.2 We will not rent or sell your Data to others. We may store the Data in locations outside our direct control (for instance, on servers or databases co-located with hosting providers).
  • 5.3 If you provide any Data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes:
  • 5.3.1 verifying your identity;
  • 5.3.2 sending you a welcome e-mail;
  • 5.3.3 providing you with customer service and responding to your queries, feedback or disputes;
  • 5.3.4 conducting marketing analysis, sending surveys or newsletters, contacting you about the Game, activities, special events or offers from us or our partners and for other marketing, information, product development and promotional purposes;
  • 5.3.5 making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us;
  • 5.3.6 sending you notices (for example, in the form of e-mails, mailings and the like) regarding products or services you are receiving and for billing and collection purposes;
  • 5.3.7 provide and maintain the Game;
  • 5.3.8 notifying you about changes to the Game;
  • 5.3.9 sending you information we think you may find useful or that you have requested from us;
  • 5.3.10 enhancing and improve the Game such as through personalized features and content;
  • 5.3.11 analysing the use of the Game and the people visiting to improve our content and the Game;
  • 5.3.12 investigating, preventing or taking action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law;
  • 5.4 We shall ensure that:
  • 5.4.1The Data collected and processed for and on our behalf by any party is collected and processed in accordance with applicable data privacy laws;
  • 5.4.2You are always made fully aware of the reasons for the collection of Data and are given details of the purpose(s) for which the Data will be used;
  • 5.4.3The Data is only collected to the extent that is necessary to fulfil the purpose(s) for which it is required;
  • 5.4.4No Data is held for any longer than necessary in light of the purpose(s) for which it is required.
  • 5.4.5Whenever cookies or similar technologies are used online by us, they shall be used strictly in accordance with applicable laws;
  • 5.4.6You will be informed if any Data submitted by you online cannot be fully deleted at your request under normal circumstances and how to request deletion of any other copies of that Data, where it is within your right to do so;
  • 5.4.7Appropriate technical and organizational measures are taken to protect the Data;
  • 5.4.8Data is transferred securely, whether it is transmitted electronically or in hard copy;
  • 5.4.9You can fully exercise your rights with ease and without hindrance.
• 6. Disclosure of Data
  • 6.1 We shall not be able to keep your Data private in response to legal process, i.e. a court order or a subpoena or a law enforcement agency’s request. If, in our view, it is deemed appropriate to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use or as otherwise required by law, we may be compelled to disclose the Data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your Data to new platform.
  • 6.2 We may disclose the Data in the good faith belief that such action is necessary to:
  • 6.2.1 Comply with a legal obligation;
  • 6.2.2 protect and defend our rights or property;
  • 6.2.3 prevent or investigate possible wrongdoing;
  • 6.2.4 protect the personal safety of users of the Game or the public;
  • 6.2.5 protect against legal liability.
  • 6.3 When necessary, we may also disclose and transfer your Data to our professional advisors, law enforcement agencies, insurers, government and regulatory and other organizations.
• 7. Data Storage
  • 7.1 Your Data is stored and processed at our servers at Amazon, Heroku and Google Firebase.
  • 7.2 We may transfer your Data to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  • 7.3 We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place including the security of your Data.
  • 7.4 We will only retain your Data preferably for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any record retention or reporting requirements under applicable laws. When deciding what the correct time is to keep the Data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
• 8. How We Protect Your Information
  • 8.1 We store all the Data submitted by you through the Game at a secured database.
  • 8.2 We are concerned with protecting your privacy and Data, but we cannot ensure or warrant the security of any Data you transmit or guarantee that your Data may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards.
  • 8.3 No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Data, we cannot guarantee its absolute security. If you have any questions about security of the Game, you can contact us at [email protected].
  • 8.4 Any Data supplied by you will be retained by us and will be accessible by our employees, any service providers engaged by us and third parties.
• 9. Compliance with the GDPR
  • 9.1 We will make all reasonable efforts to ensure that the Game complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 of the EU regarding the collection, use and retention of Data from the Users based in European Union’s Member States. We will also make all reasonable efforts to adhere to the GDPR requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
  • 9.2 We strictly observe Article 14 ruling of the GDPR, making explicitly known to the user which Personal Data we have gathered pertaining to him / her and what has been the source as well as the “purpose” and “scope” of our Personal Data processing activities.
  • 9.3 Per Article 14 of the GDPR, if either the user provides no feedback or he/she declines to approach / contact, we shall erase the Personal Data that we have gathered until one (1) month after collection date.
  • 9.4 To prevent further contact within the same scope, the user’s name and e-mail address will be ‘blacklisted’ in our records that is accessible to our relevant internal departments only.
  • 9.5 Personal Data pertaining to any User that is identified as being under eighteen (18) years of age (therefore not bearing full legal capacity as an adult) will be automatically excluded from our records. This also comprehends the unlikely event of a user who is under eighteen (18) years of age but has been identified as an adult by error / mistake/ his / her own conduct.
  • 9.6 Upon the collection of Personal Data pertaining to Users, we will identify the User by asking further information, if required.
  • 9.7 The Rights of Users: Users based in EU may exercise following rights regarding their Data:
  • (i) Right of confirmation: Users shall have the right to obtain confirmation from us as to whether or not your Personal Data is being processed.
  • (ii)Right of Access: Users shall have the right to obtain free information from us about their Personal Data as well as its copy at any time. The EU directives and regulations also grant you access to the following information:
  • the purpose of the processing;
  • the categories of Personal Data concerned;
  • the recipients or types of recipients to whom your Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • the envisaged period for which your Personal Data will be stored, or, if that is not possible, the criteria used to determine that period;
  • the right to request from us rectification or erasure of Personal Data or restriction of processing of your Personal Data or to object to such processing;
  • the right to lodge a complaint with a supervisory authority;
  • where your Personal Data is not collected, any available information as to its source;
  • the existence of automated decision-making, including profiling, referred to in Articles 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for you.
  • (iii) Right to rectification: Users shall have the right to obtain from us without undue delay the rectification of their inaccurate Personal Data. Taking into account the purposes of the processing, Users shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
  • (iv) Right to be forgotten: Users shall have the right to require us to erase their Personal Data without delay which we will be obliged to do so where one of the following grounds applies as long as the processing is not necessary:
  • The Personal Data is no longer required.
  • You choose to withdraw your consent as per sub-article (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR
  • As per Article 21(1) of the GDPR, you raise any objection against the processing of your Data and when there is no overriding ground for such processing or you raise objection pursuant to Article 21(2) of the GDPR.
  • The Personal Data has been unlawfully processed.
  • The Personal Data must be erased for compliance with a legal obligation in EU or a Member State law to which we are subject.
  • The Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
  • Where we have made Personal Data public and are obliged pursuant to Article 17(1) to erase such Personal Data, we, while taking account of available technology and the cost of implementation, shall take reasonable steps including technical measures to inform other controllers processing the Personal Data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.
  • (v)Right of restriction of processing: User shall have the right to obtain from us restriction of processing where one of the following applies:
  • The accuracy of the Personal Data is contested by the User for a period enabling us to verify the accuracy of the Personal Data.
  • The processing is unlawful and the User opposes the erasure of the Personal Data and requests instead the restriction of their use.
  • We no longer need the Personal Data for the processing but we are required by the User for the establishment, exercise or defence of legal claims.
  • Pursuant to Article 21(1) of the GDPR you exercise your right to object to processing when the verification process is pending.
  • If any of the above conditions is fulfilled and you want to restrict processing of your Personal Data stored by us, you may contact us at [email protected].
  • (iv) Right to data portability: Users shall have the right to receive their Personal Data, which was provided to us, in a structured, commonly used and machine-readable format. Users shall also have the right to transmit such data to another data controller if such processing is based on consent retrieved as per point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means as long as the processing is not necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in us.
  • (iv) Right to object: Users shall have the right to object on grounds relating to their particular situation at any time to processing of their Personal Data, which is based on point (e) or (f) of Article 6(1) of the GDPR.
  • The Personal data will no longer be processed in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing.
  • If a User’s Personal Data is processed for direct marketing purposes, that User shall have the right to object at any time to processing of his / her Personal Data for such marketing. This applies to profile to the extent that it is related to such direct marketing. If a User objects to us to the processing for direct marketing purposes, we will no longer process the Personal Data for these purposes.
  • A User shall have the right, on grounds relating to his / her particular situation, to object to the processing of his / her Personal Data for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • 9.8 Right to withdraw data protection consent: Users shall have the right to withdraw their consent to the processing of their Personal Data at any time. Users may initiate a request with us at [email protected] to exercise any of the above-mentioned rights. We shall review your request and, in our discretion, honour your request, if deemed necessary by us, within a reasonable time. Personal Data pertaining to a former Users shall be erased from our records once all applicable legal timelines have expired being that if those are dilated in time (meaning over 1 year after service termination), the Personal Data shall be securely segregated from live Data.
• 10. Compliance with CalOPPA
  • 10.1 We comply with the California Online Privacy Protection Act (“CalOPPA”) which requires any person or company in the United States (and conceivably the world) that requires websites collecting ‘Personally identifiable information’ from California based users to upload a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. Under CalOPPA, we agree to the following:
  • You can visit our site anonymously.
  • Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
  • 10.2 We endeavour to fulfil requirements of the CalOPPA under this Privacy Policy in line with our policy for user data collection, storage, and disclosure as outlined for GDPR compliance.
• 11. Compliance of California Privacy Act 2018
  • 11.1 This Privacy Policy is also applicable on California residents and explains how we collect, use and share your Personal Information and how you may exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”).
  • 11.2 Your rights under the CCPA:
  • 11.2.1 Under the CCPA, Users have the right to access their Personal Data during the past twelve (12) months and information about our data practices. Users also have the right to request that we delete their Personal Data.
  • 11.2.2To request manual access or deletion of your Personal Data, please contact us at [email protected].
  • 11.2.3Please note that for making manual requests you will need to verify your identity by providing us with all the information as we may require from you for this purpose.
  • 11.2.4You have the right to be free from any discrimination for exercising your rights to access or delete your Personal Information.
  • 11.3 If you have additional questions about this or how to exercise your rights under the CCPA, please contact us at [email protected]
• 12. Third-Party Service Providers
  • 12.1 Third party companies and individuals may be employed to facilitate operational and voice communication services ("Third Party Service Providers") in relation to providing the Game Services on our behalf, to perform Game services-related services or to assist us in analysing how the Game service is used.
  • 12.2 These third parties have access to your Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
  • 12.3 Following are third-party service providers that the Company uses that work over SSL.
• 13. Changes to this Privacy Statement
  • 13.1 This Privacy Policy may be modified from time to time and any such change shall be reflected on the Game with the updated version of the Privacy Policy and Users agree to be bound to any changes to the updated version of Privacy Policy when they use the Game.
  • 13.2 Users acknowledge and agree that it is your responsibility to review the Game and this Privacy Policy periodically and to be aware of any modifications. We will post updates to this Privacy Policy here.
  • 13.3 We reserve the right to correct any errors, inaccuracies or omissions and to change or update the information at any time, without prior notice in case there is any information on the Game that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability and various other information.
• 14. Contact US
  • 14.1 If you have questions about our Privacy Policy, please contact us via email: [email protected].