PRIVACYPOLICY
1 GENERAL
1.1 This privacy policy (the "Privacy Policy") is an integrated part of Sozap’s terms of service (the “Terms”) and always applies, unless otherwise agreed in writing, between SOZAP AB (publ),corp.ID.no. 556980-2241, (“Sozap”) and each user (the ”User”) of Sozap’s games and related services, which include Sozap’s applications for mobile devices, websites branded with Sozap-owned trademarks, products and services made available through social networking services, and related products and services (collectively the "Services"), for Sozap’s processing of the User’s Personal Data (as defined below).
1.2 Sozap is the data controller, as defined in Art. 4 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)(the “GDPR”), for the processing of the User's Personal Data which is registered with Sozap via the Services or which Sozap collects directly from the User or any third party.
1.3 This Privacy Policy serves to assure the User that Sozap, in its capacity of data controller, processes the User's Personal Data in accordance with applicable privacy laws and regulations. Below follows a description of how Sozap processes the User's Personal Data. Information is also given regarding the User’s rights, and how the User can get in contact with Sozap in case the User has any questions or wants to exercise its rights.
1.4 By registering, installing or otherwise using the Services, or in any other way soliciting Sozap, the User agrees to Sozap’s processing of the User's Personal Data as outlined in this Privacy Policy. If the User does not provide the required information or explicit consent when needed, the User may not be able to access the Services or part of the Services.
2 CHANGES TO THE PRIVACY POLICY
2.1 Sozap reserves the right to modify the terms of this Privacy Policy at any time. If Sozap makes material changes to the Privacy Policy, the User will be notified of such changes through the Services or by notices on applicable web sites. Sozap may also send an email to the email address registered with the User’s user account.
2.2 The User should periodically check this Privacy Policy for updates. By continuing to access or use the Services after Sozap has posted an updated Privacy Policy and made reasonable efforts to notify the User, the User agrees to be bound by the modified Privacy Policy. If the User does not agree with the modified Privacy Policy, the User’s only recourse is to stop using the Services.
3 PERSONAL DATA AND DATA COLLECTION
3.1 In this Privacy Policy, “Personal Data” refers to any information that can be attributed to an identified or identifiable living individual. Different pieces of information, which in combination can be used to identify a particular living individual, also constitute Personal Data.
3.2 Personal Data may be automatically collected or generated when the User visits, interacts with or uses the Services. The automatic collection or generation of Personal Data may be performed either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies as further described in Sozap’s cookie policy. Automatically collected or generated Personal Data may consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, game statistics, game preferences, unique advertising ID, data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on the Services, in-App or game activity; diagnostic data (i.e. crash data and game performance data).
3.3 Personal Data may be received directly from the User, e.g. when setting up an account with the Services, contacting Sozap (through social media, e-mail, in-game chat or any other channel, including any support services), posting on public forums or groups, participating in competition, contest, tournaments and other promotions, placing any purchases in the Services, interacting with other users in-game.
3.4 Personal Data may be received from social media and other channels once the User connects the Services to its account with Meta, Google, Apple or similar services. Sozap will receive access to the Users public profile information which may include name, e-mail address(es), gender, profile picture or similar photo, location, time zone, friend information.
3.5 Personal Data may be collected in connection with in-game purchases processed by Sozap or by the relevant platform provider (e.g. Apple, Google or Meta). Such Personal Data may consist of both financial data, such as credit card numbers or bank account information, and non-financial data related to the purchase, such as the User’s name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for accounting purposes.
4 HOW AND WHEN SOZAP COLLECTS PERSONAL DATA
4.1 SOZAP collects personal data provided by the data subject when creating an account.
4.2 Sozap may collect personal data by matching the data subject’s email address towards SOZAP’s partners CRM systems.
4.3 SOZAP may gather user generated data when a data subject uses Sozap’s services. This includes both applications and websites that utilize any Sozap services.
5 CATEGORIES OF DATA THAT SOZAP PROCESSES
SOZAP processes the following categories of personal data:
a) Email addresses,
b) First names,
c) Surnames,
d) Transaction Ids,
e) IP Addresses,
f) Geo location data,
g) Device types,
h) Device models,
i) Operating systems,
j) Operating system versions,
k) Application interaction data,
l) Cookie data,
m) Personal choices provided forcommunication, and
n) Push notification tokens.
6 CATEGORIES OF DATA SUBJECTS WHOSE DATA SOZAP PROCESSES
6.1 SOZAP processes the personal data of the following categories of data subjects:
a) Users of SOZAP’s services,
b) Employees of SOZAP, and
c) Contact persons for SOZAPcustomers and partners.
7 SENSITIVEPERSONAL DATA AND PERSONAL DATA RELATING TO MINORS
7.1 Sensitive Personal Data refers to data which reveals a User’s ethnic origin, political opinions, religious beliefs or membership of the trade union, as well as Personal Data relating to health or sex life. Sozap does not knowingly process any sensitive Personal Data regarding the User and has employed measures to restrict the Users possibility to upload sensitive Personal Data. If Sozap learns that sensitive Personal Data is processed within the Services, Sozap will make all efforts to promptly delete any such Personal Data.
7.2 Sozap does not knowingly collect Personal Data from underage Users without parental consent. If Sozap learns that a minor is using the Services, Sozap may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with regard to such minor.
8 OBJECTIVES AND LEGAL BASIS FOR SOZAP’S PROCESSING OF PERSONAL DATA
8.1 SOZAP processes personal data in the following instances:
a) When a user creates a user account for Sozap's services:
b) When a user uses or makes purchases within Sozap's services:
c) When providing customer service:
d) When performing legal obligations
e) Processing for marketing and promotions
f) Service development and analytics:
g) Processing for security purposes:
9 SHARING OF PERSONAL DATA TO THIRD PARTIES
9.1 SOZAP currently shares personal data with the following data processors:
10 SHARING OF PERSONAL DATA TO THIRD PARTIES
10.1 Without the User's explicit permission, Sozap will not share the User's Personal Data with any third party in any other way than what follows from this Privacy Policy, unless Sozap is obliged to do so following the applicable regulations or unless the Personal Data is shared in connection with an ongoing legal-, administrative- or recovery procedure in which the User and Sozap are both parties.
10.2 Sozap currently shares the User’s information (in some cases, Personal Data) with third parties, that is, parties other than Sozap, in the following circumstances:
a) Service providers and third party integration partners (“Personal Data Assistants”).
Sozap may provide the User’s information (including Personal Data) to third party companies as necessary to perform Services on Sozap’s behalf, including payment processing, data analysis, e-mail delivery, hosting services, and customer service. Sozap requires all Personal Data Assistants to (i) protect the User's Personal Data in accordance with this Privacy Policy and (ii) not use or disclose the User's Personal Data for any purpose other than to provide the agreed upon services to Sozap and enabling Sozap to offer access of the Services to the User. The Personal Data Assistants are listed in Appendix A.
b) Advertisers
Sozap uses the User’s information to show the User customized advertising on the Services and on third-party websites and services. Sozap allows third parties such as advertising networks and advertising service providers to use the User’s information to display advertisements on the Services and elsewhere online across different websites and services tailored to the User’s interests. The User can prevent the sharing of the User’s information by opting out of having the User’s information shared with third parties in the Services. However, opting out of information sharing may affect the User’s ability to use the Services.
c) Friends and other Users of the Services
The Services support various forms of interaction between Users. While using the Services, friends and other players will be able to see the User’s user profile, which may include the User’s username, game play statistics, and other information voluntarily provided by the User. Other Users may also be able to view the User’s user ID or profile with the application or social media platform used by the User to access the Services, and to send the User game- or friend requests through such application’s or social media platform’s established communication channels.
d) Business Transfers
Sozap may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if Sozap (or substantially all of Sozap’s assets) are acquired, or if Sozap goes out of business or enter bankruptcy, Personal Data would be one of the assets transferred to potentially be acquired by a third party.
e) Compliance
Sozap may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or incompliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur without notice to the User should such disclosure interfere with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
11 STORING OF PERSONAL DATA
11.1 The User's Personal Data is stored in Sozap's own database but may also be stored locally on devices that the User uses to access the Services. The database is stored on external servers provided by Sozap's Personal Data assistant located in the US. Sozap and the Personal Data assistant have entered into a data processing agreement with the standard contractual clauses approved by the European Commission for data transfers between EU and non-EU countries and the User expressly agrees to the Personal Data being stored on AWS servers in accordance with this Privacy Policy and applicable regulations.
11.2 The User's Personal Data will not be stored for any longer than necessary, with regards to the purpose of the processing and considering Sozap’s eventual legal obligations regarding to accounting regulations etc. If certain Registration Data is not provided, Sozap’s legal obligations cannot be fulfilled and Sozap can therefore be forced to deny the User access to the Services.
11.3 Sozap regularly deletes all Personal Data which is no longer needed with regards to the purpose of the processing, in accordance with the relevant laws and regulations in force at any time.
12 TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
12.1 Sozap does not transfer Personal Data to third countries (i.e. countries outside the EU/EEA) other than what has been expressly stated in this Privacy Policy.
12.2 Should Sozap need to do so in the future, Sozap will only transfer Personal Data if the third country has an adequate level of protection according to applicable privacy laws and regulations or if Sozap otherwise can ensure the secure processing of Personal Data in accordance with applicable regulations.
13 THE RIGHT TO REQUEST INFORMATION
13.1 The User has a right to request and obtain, free of charge, information regarding what Personal Data (if any) that is being processed by Sozap, a so-called register extract. The User also has the right to have any incorrect Personal Data corrected. If the User wishes to know if Sozap processes any Personal Data about the User, he or she can send a written and signed request to Sozap using the contact information below. In the request, the User needs to indicate specifically what kind of information the User is interested in receiving (unless the User is interested in receiving information about all Personal Data). That way, Sozap can provide the User with information that is relevant. If the User repeatedly sends requests for an extract from the register, Sozap may charge a fee or, in some cases, in accordance with statutory law, refuse to comply with the request.
13.2 The extract from the register will be sent to the User within 30 days from the time Sozap received the request. If the extract is extensive and Sozap needs more time or if Sozap for some reason cannot comply with the User’s request, Sozap will without undue delay notify the User thereof.
14 THE RIGHT TO RECTIFICATION
14.1 In order to fulfill its obligations to always have accurate and relevant Personal Data, Sozap systematically works with its registers and updates Personal Data where necessary. If the User notices that the Personal Data Sozap processes is incorrect or if Sozap lacks important Personal Data, the User has the right to have their Personal Data corrected. Sozap normally performs simple data corrections without consideration, but in some cases Sozap may need to consider the User's request. Sozap will not approve the User's request if it is impossible or requires an unreasonable amount of work. Upon a request by the User, Sozap will inform the User about whom the correction has been submitted to.
14.2 In the event that the User's Personal Data is changed at the User's request, Sozap will inform any subcontractors and partners that processes the Personal Data about the change.
15 THE RIGHT TO ERASURE
15.1 The User has the right to request that Sozap erases the User's Personal Data when:
a) they are nolonger needed for the purposes for which they have been collected and for whichthey are being processed;
b) Sozap processes Personal Data under the User's consent and the User withdraws said consent;
c) Sozap processes Personal Data for direct marketing and the User opposes the continued processing for this purpose;
d) Sozap processes Personal Data on the legal basis of a balance of interests and there are no legitimate interests that weigh heavier than the User's interest;
e) Sozap does not process Personal Data in accordance with applicable rules;
f) It is required that Personal Data is erased in order to fulfill a legal obligation; or
g) there is another relevant legal basis for the Users request to erase the Personal Data.
15.2 Sozap has the right to refrain from erasing the User's Personal Data if Sozap needs to retain these in order to fulfill a legal obligation or to be able to make legal claims against the User or in defense against legal claims from the User.
15.3 When Sozap receives the User’s request regarding erasure, Sozap will conduct an assessment in order to evaluate if there are reasons to erase the User’s Personal Data. The User will then be informed about Sozap’s assessment. If the User’s Personal Data are erased at the User’s request, Sozap will inform all Personal Data Assistants to which Personal Data has been transferred that the Personal Data has been erased.
16 THE RIGHT TO RESTRICTION OF PROCESSING
16.1 The User has the right to request the restriction of Sozap’s processing of the User's Personal Data when:
a) the User has disputed the accuracy of the Personal Data, during the time Sozap has the opportunity to check whether the Personal Data are correct;
b) the processing is illegal, and the User opposes that the Personal Data is deleted and instead requests a limitation of its processing;
c) Sozap no longer needs the Personal Data for the purposes of the processing, but the User needs the Personal Data to be able to determine, enforce or defend legal claims; or
d) the User has objected to processing when awaiting information of the legitimacy of whether Sozap’s interests weigh heavier in relation to the interests of the User.
16.2 Restriction of processing implies that the Personal Data will be marked, so that they in the future may only be processed for certain limited purposes.
17 DELETION OF PERSONAL DATA
17.1 The Personal Data will not be retained for any longer than is necessary with regard to the purposes of the processing, and Sozap will otherwise delete Personal Data in the manner that follows from applicable legislation, where an examination is made on a case-by-case basis when different types of Personal Data should be culled.
17.2 If the User requests that the User’s Personal Data shall be deleted, Sozap will delete or de-identify the Personal Data no later than 30 days from the reception of the request. This is provided that the Personal Data is not required to be saved in the future in order for Sozap to fulfill its legal obligations or to be able to exercise its legal claims.
18 THE RIGHT TO WITHDRAW CONSENT AND OBJECT TOPROCESSING
18.1 The User has the right to object to Sozap's processing of the User's Personal Data which Sozap conducts with the support of so-called balancing of interests according to law. If the User wishes to exercise this right, the User needs to specify in writing which processing the User objects to. In the event of such an objection, Sozap may only continue to process the User’s Personal Data if Sozap can show that there are compelling and entitling reasons for why the Personal Data must be processed, and provided such reasons weigh heavier than the User's interests.
18.2 If the User's Personal Data is processed for direct marketing, the User always has the right to object to the processing at any time.
19 THE RIGHT TO DATA PORTABILITY
19.1 If the User has provided its Personal Data to Sozap, the User may, in some cases, be entitled to extract his or her Personal Data in order to, for example, move them to another company.
19.2 In order for the User to be able to use his or her right to so called data portability, the User's request must relate to Personal Data that the User himself/herself has provided to Sozap and which Sozap processes with the consent of the User or to fulfill an agreement with the User.
19.3 The right to data portability does not apply when Sozap's processing of the User's Personal Data is based on a balance of interests or a legal obligation for Sozap.
19.4 The right to data portability does not apply when data portability is technically difficult to implement.
20 THE RIGHT TO COMPLAIN
20.1 In the event that the User has complaints or objections in connection with Sozap's Processing of the User's Personal Data, Sozap kindly asks the User to initially contact Sozap, so that Sozap can help the User in the best way possible.
20.2 However, the User always has the right to submit his or her complaints directly to the relevant data protection authority.
21 SECURITY
21.1 Sozap undertakes all appropriate technical and organizational security measures, that are required in accordance with applicable regulatory frameworks governing the processing of Personal Data, to ensure a high level of security appropriate to the risks and to protect the Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to processed Personal Data.
21.2 Sozap encrypts the User’s transmissions of sensitive information (such as Personal Data or payment information for purchasing virtual currency) using Secure Socket Layer (SSL) technology.
22 LINKS TO OTHER WEBSITES
Sozap is not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained therein. Please remember that when the User uses a link to go from the Services to another website, Sozap’s Privacy Policy does not apply to third-party websites or services. The User’s browsing and interaction on any third-party website or service, including those that have a link or advertisement on Sozap’s website, are subject to that third party’s own rules and policies. Sozap encourages the User to familiarize itself with the privacy statements of all websites that the User visits and interacts with.
23 CONTACT INFORMATION
23.1 If the User wishes to exercise his or her rights under these Terms, a request shall be made in written form and sent to Sozap by email to contact@sozap.com or via mail to:
SOZAP AB (publ)
Brunnsgatan3 B
611 32, Sweden
23.2 When contacting Sozap the User must be able to identify itself though the email address registered with Sozap and by copy of valid identification.
23.3 If the User has any questions about this policy or Sozap's Personal Data processing, the User may preferably contact Sozap through the Services for expedient answers, otherwise the User may send any inquiries to contact@sozap.com.
