Privacy Policy

Last updated: September  26, 2024

We at Megarama Games Ltd (the “Megarama”, “Company,” “We,” Us,” or “Our”) are committed to securing your Personal Data and your privacy.

This Privacy Policy has been created to inform you about how We manage, collect, store and use the information you provide in connection with any Megarama website, game or application (“Products”).

We believe that you have the right to know whether your Personal Data is being transferred to third parties, including being “sold” as defined in the CCPA, and we have set forth below in what circumstances we share your Personal data.

We will uphold the following principles:

It is important to Us that you have at all times all the information required for you to make educated decisions about the processing of Personal Data about you. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing.

In addition, if We find you are required to be provided with specific information, We will provide it to you in the appropriate time and place.

We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: [email protected]

The purposes for which We may process Personal Data about you include, inter alia, to provide you with Our Products as requested by you, to enhance the user experience in Our Products, to facilitate in-game purchases, to improve Our Products and services and provide you with technical support and respond to your enquiries, to protect Our rights and interests, to perform business and administrative activity that supports the provision of Our Products and services to Our users, and/or to uphold any legal and/or regulatory requirements.

In addition, We will process Personal Data about you in order to understand your personal needs and preferences.

We apply significant resources to allow you to exercise your rights as a data subject. Therefore, you may approach Us any time you wish to review Personal Data about you, have Us amend it, erase it, cease using it for specific purposes or in general, or transfer it to you or to a third party. We will fulfill your wishes in accordance with applicable law.

While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures aimed at ensuring the Personal Data about you is secured.

Our Complete Privacy Policy

1. The Scope

This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, processe it, etc.

In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

Our Products are intended for general audiences and are not directed at children under the age of 13. We do not knowingly collect or solicit information from anyone under the age of 13 or knowingly allow such persons to access our Products. If We learn that information about a child was collected, We will take reasonable steps to delete such information as soon as possible.

2.  When Do We Collect Personal Data About You?

We collect Personal Data about you whenever you use Our Products, use Our service channels, use the Website and/or contact Us. In some instances, you will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about you by examining and analyzing your use of Our Products and/or Our service channels.

3. No Obligation To Provide Personal Data To The Company And Its Implications

You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with the Products or services you requested Us to provide you, will prevent your use of the Website and the Products, and/or will cause the malfunctioning of Our Products and services.

 4. What Personal Data About You Do We Collect?

Personal Data We collect upon activation of your Product account (if activated) the following information you provide us:  name; emails; address; age; date of birth; if you use your Facebook account to setup your account – Your profile picture; or any other relevant information included in your application, social network or other online profile.

Personal Data We collect during your use of the Products: Your mobile device’s unique identifier (UDID); Your social network or third party service user identification number, if you share that with Us; certain technical information about your device, your IP address, your usage patterns on the Platform (including usage times and types of use you are making) and other data generated during your use of the Product and associated with your user ID.

Personal Data We collect when you perform in-app purchases: When you perform an in-app purchase We collect transaction identifiers for such. Your means of payment information is stored with the third-party payment service and not shared with Us.

Personal Data We receive from you: any Personal Data you provide to Us of your own free will when contacting Us. We may record and/or document in writing your calls.

Personal Data We collect upon each browse of the Website: interests, user behavior, device info, operating system info, and device ID.

5. The Purposes Of The Processing Of Personal Data And Their Legal Basis

We process your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

We will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which We may process Personal Data about you are as follows:

1. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. This refers to all the information required for us to operate our Products and grant you access thereto.
2. Processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party. By way of example, for the purpose of improving Our campaign management tool, or for the exercise or defense of legal claims.

At any time, you may approach Us by sending a notice to the email address [email protected], in order to receive information concerning the review performed by Us. This is so you can conclude that We may process the Personal Data about you on account of such processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party.

The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:

6. Transfer Of Personal Data To Third Parties

We may also share Personal Data about you with third parties that provide Us with the following services:

1. Storage and hosting providers, including cloud computing services;
2. IP address information;
3. Analysis of user experience;
4. Support;
5. Marketing;
6. CRM data management;
7. Digital signing;
8. Accounting and legal services; and
9. Research, analytical, technical, and diagnostic services.

We may also share Personal Data about you with its related entities and business partners, which provide it with resources that enable Us to enrich and improve the level of services and products it provides to its users.

We may share Personal Data about you with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims. In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, Us and/or any company within the group of companies of which We are a part, or in the event of any similar transaction (including the sale of Our assets and/or of any company within the group of companies of which We are a part), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of Us and/or any company within the group of companies of which We are a part.

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit. Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information: 

Your right to opt-out of allowing the “transfer” or “sale” of your Personal Data

You have the right to opt-out of this disclosure of your information, which may be considered a “sale” under California law, as well as opt out of sharing your personal information, via cookie management in the privacy preference centers of each platform listed above. That said, due to technical limitations and in the interest of the users, we do not necessarily know the identities of all visitors to our platforms at all times based on the settings they adopt. Your opt-out of cookies setting would only apply to the browser and device you are currently using as we do not make any attempts to link devices you use. If you clear cookies or if you use a new browser or device, your opt-out cookie may no longer be available. As a result, in those situations we may still ask that you authorize the “sale” of your personal information when you visit our platforms, by asking you to accept cookies, within 12 months after you opt-out the “sale” of your information.

When sharing data with third parties, we will, where applicable, include safeguards such as confidentiality, respect for the LGPD and other applicable standards, as well as transparency regarding data processing. The term “LGPD” refers to the Brazilian General Data Protection Law No. 13,709/2018. 

We will also comply with the provisions of the the Virginia Consumer Data Protection Act (Chapter 53, § 59.1) where applicable. 

7. Cookies and Third Party Services

We use certain third-party services, such as analytics companies or companies delivering advertisements in our Products, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.

A cookie (which is a small text file) is installed on the device via which you visit or access the Website. The cookies allow Us to collect information about you and your behavior, in order to improve your user experience, to remember your preferences and settings, and to customize and offer you products and services that may interest you. Cookies are also used to collect statistics and perform analytics.

 Some of the cookies We use are session cookies, which are downloaded temporarily to your device and last until you close your web browser, while others are persistent cookies, which last on your device after you cease browsing the Website and are used to help the Website remember you as a returning visitor when you return to the Website

 The cookies We use have been classified according to their functionality, as follows:

The Cookies incorporated in our Products are as follows:

You can change your browser settings to block and delete some or all cookies. For general information about cookies and how to disable them, please visit http://www.allaboutcookies.org

Please see below links to instructions on how to do this in respect of some of the most popular web browsers:

• Firefox
• Internet Explorer
• Google Chrome
• Safari

Please note, however, that if you do so, some or all of the Website’s features and functionalities might not perform as intended.

Please note that the content on this site or accessible through Products may link to third party sources, which may also use cookies, over which we have no control. Therefore, this policy does not apply to such third party sites.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

We shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us.

In order to ensure that Personal Data about you is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.

9. Transfers Of Personal Data To A Third Country Or An International Organization

Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, We shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.

If you are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:

1. The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“), including any transfer in accordance with the EU-US Privacy Shield Framework;
2. The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You may request that We provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: [email protected]

10. Protection Of Personal Data About You

We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.

We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties.

Any transfer of Personal Data via the internet cannot be fully secured. Therefore, We cannot ensure the protection of Personal Data about you when transferred via the internet to Us.

11. Links To Websites of Third Parties

The Product may provide links to websites and/or applications of third parties, including if you click on advertisements. We do not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.

Whenever you access such third parties’ websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you.

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify you of such amendments by publishing the updated Policy on the Website and the Platform. In addition, when We make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website and the Platform. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page in the Product.

Generally, you have the right to request that We provide you with confirm whether Personal Data about you is being collected by us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict you consent to certain processing of your Personal Information.

If you are an EEA resident please read this section below:

You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address: [email protected]

Right of access

You have the right to receive from Us confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from Us rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.

We shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, We may not fulfill your request or do so in a limited manner.

Right to rectification

You have the right to obtain from Us the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.

Right to erasure

You have the right to obtain from Us the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which We are subject.

This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which We are subject; or (b) for the establishment, exercise, or defense of legal claims.

Right of restriction of processing

You have the right to obtain from Us the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling Us to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) We no longer need the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by Us or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about you is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

Right to data portability

You have the right to receive the Personal Data about you, which you have provided to Us, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from Us to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

Right to withdraw consent

You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.

Your rights in respect of Personal Data about you as outlined in this section may be restricted by European Union or Member State law to which We are subject.

We shall provide you with the information requested according to your rights outlined in this section without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

The information requested according to your rights outlined in this section shall be provided free of charge, unless stated otherwise in this section. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

We may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section, if We have reasonable doubts concerning the identity of the natural person making the request.

If you reside in California, please read below with respect to the California Consumer Privacy Act (CCPA) rights you have:

In order to exercise your CCPA right, please contact us [email protected]

Our Data Protection Officer can be contacted at [email protected] should you have any questions.

Please note that we may need to receive personal information from you in order to verify your identity prior to allowing you to exercise your rights.