DBA DEVELOPMENTS (“DBA DEVELOPMENTS”) PROVIDES A FULL, BEST IN CLASS AND USER-FRIENDLY MOBILE GAMING EXPERIENCE, ALLOWING OUR USEERS TO PLAY THE MOST POPULAR SKILL BASED GAMES IN THEIR REAL-MONEY TOURNAMENT VERSION (THE “SERVICES”). ANY REFERENCE TO THE SERVICES HEREIN SHALL INCLUDE ANY AND ALL SERVICES, GAMES, WEBSITES, COMPETITIONS, TOURNEMENTS AND OTHER ACTIVITIES WHICH MAY BE OFFERED BY DBA DEVELOPMENTS FROM TIME TO TIME, THROUGH MOBILE, DESKTOP OR OTHERWISE. IN ADDITION, “SERVICES” SHALL ALSO INCLUDE ANY MOBILE APPLICATIONS OR OTHER SOFTWRE, UPDATES, UPGRADES, FIXES, PATCHES, APIS AND/OR ANY OTHER SOFTWARE WHICH DBA DEVELOPMENTS MAY MAKE AVAILABLE FROM TIME TO TIME (COLLECT AND/OR RECEIVEIVELY, “SOFTWARE”).
In this Privacy Policy, “DBA DEVELOPMENTS” refers to DBA DEVELOPMENTS and its affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership or related companies.
DBA DEVELOPMENTS takes its users privacy very seriously and is committed to protecting its users’ information in compliance with all applicable laws and regulations. This Privacy Policy has been created to inform you about how we collect and/or receive, store, use and share and/or disclose the information you provide in connection with the use of the Services and/or Software.
By accessing or using the Services and/or the Software, you are deemed to have accepted this Privacy Policy, including without limitations, to the collection and/or receipt, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not not agree to any provision in this Privacy Policy, please stop using the Services.
We may amend this Privacy Policy from time to time without providing to you any notice and you are encouraged to check this Privacy Policy frequently. You continued use of the Services indicates your consent to the most updated version of this Privacy Policy.
Please note that we will not share and/or disclose any of your PI or other identifiable (by itself or together with additional information) information protected under applicable privacy laws and regulations (including without limitations the GDPR (”GDPR”)) (“PI”) with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in”.
For the purposes of the GDPR DBA DEVELOPMENTS might be a data controller (i.e., the company that is responsible for, and controls the processing of your PI) for certain uses of your PI and a data processor for other uses, as applicable.
Your Personal and other Information and how we Collect and/or Receive it
We only collect and/or receive PI to the extent it is necessary in order to fulfil one or more of the Services’ functions and activities and/or to maintain and improve the Software. If you use the Services and/or the Software through any third-party platform (such as Facebook), we may receive certain PI about you from such third party platforms.
As an example only, we may collect and/or receive the following PI from you directly or from third parties: (i) your username(s) and password; (ii) your user ID number and other public data of your friends on social platforms, if access is done through any social platform, as applicable; (iii) your e-mail and other contact details which you have provided or which we have collected in accordance with this Privacy Policy; (iv) your location data; (v) Your Phone number you authenticate with; and (vi) your age and date of birth.
We may also collect and/or receive certain information about your activities on or through the connected third-party applications or through your use of the Services and other publicly available information.
We may also collect and/or receive information through your use of the Services such as if you participate in users’ forums and message boards, as shall be available from time to time, post comments to other users, send private messages or invitations to other users, chat with users or post information.
We may receive certain billing and payment information if and when you pay any amount to DBA DEVELOPMENTS or otherwise transfer funds through the Services. We will not store your financial information, however our payment processors may share and/or disclose non-financial information with us related to your purchases, like your name, billing address, etc.
Finally, we may use various tracking technologies to collect and/or receive certain technical information, including without limitations: (i) the type of the device you are using; (ii) the type of your operating system, version and platform type; (iii) your mobile device’s identifiers and other related information; (iv) your browser types, language, etc.; (v) referring/exit pages, URL, etc.; and (vi) pages viewed and other types of browsing information.
We may collect and/or receive the above information directly or through our third-party suppliers, subject to the applicable engagement terms with such third party suppliers and subject to applicable laws and regulations.
Transfer of Information Internationally
When you use the Services and/or the Software, your PI may be sent to other countries including without limitations out of the United States to other countries or into the United States from other countries. We may store PI about users on servers located in the United States and/or in other countries and we may change such storage from time to time. When we transfer your PI from one country to another country, we will take commercially reasonable steps to ensure that your PI is treated in the most secured and lawfulwy and in the manner and in accordance with the principles that are described in this Privacy Policy.
Please note that laws and regulations vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your PI is to be transferred to or to be stored, used or processed in, may be different from the privacy laws in the place where you are resident or in which your PI is currently located.
If you are a resident in a jurisdiction, where transfer of your PI to another jurisdiction requires your consent, then you hereby provide us your express and unambiguous consent to such transfer in order for us to be able to provide you with our Services and/or Software.
Use of Cookies
A cookie is a small data file that is stored on your computer or on your mobile device. The Services and/or Software may send cookies to a computer or a mobile device when you access the Information contained in a cookie may be linked to PI for purposes such as improving the quality of the Services and/or the Software, creating or improving recommendations to interests, and making the Services and/or Software easier to use for our users.
Third party advertisers on the Services and/or Software may also use, place or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies. You may disable the cookies at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting cookies from the websites you visit or limit the type of cookies you allow, however if you do not accept cookies you may not be able to use all or any of the features of the Services and/or the Software.
DBA DEVELOPMENTS and its third party service providers and/or partners may also employ other similar technologies including, without limitations: (i) web beacons, allowing us to know if a certain page was visited or whether a specific e-mail was opened; or (ii) pixels, allowing us or our advertising or other partners to advertise more efficiently by excluding our users from certain promotional messages, identifying the source of a new installation or delivering ads to our users on other websites.
How We Use and Share and/or disclose Your Information
We may collect and/or receive and store your information for the following reasons: (i) creating accounts and enable the Services and/or the Software; (ii) improve, optimize and personalize the Services and/or the Software; (iii) identify and suggest connections with other users; (iv) enable users to communicate with each other; (v) provide technical support to our users; (vi) protect the safety and rights of our users; (vii) protect our rights and enforce this Privacy Policy and our Terms of Use; (viii) prevent fraud or potentially illegal activities; (ix) manage and deliver contextual and behavioral advertising; (x) notify our users of new products or Services and/or the Software, updates or other offers; or (xi) comply with our legal obligations, resolve disputes and other related purposes.
We may record games, tournaments, contests, competitions and/or other events played through the Services at our discretion and use such recordings for our various business purposes in accordance with applicable laws and regulations, including this Privacy Policy.
Among others, we may broadcast, display, show and otherwise share and/or disclose live or recorded games, tournaments, contests, competitions and/or other events.
Third-Party Advertising
We do not actively share and/or disclose PI with third-party advertisers for their direct marketing purposes unless you provide us with your consent. When advertisers place ads in the Services, they may collect and/or receive or we may share and/or disclose certain performance data (e.g. number of clicks on advertisements), aggregated and/or de-identified information about users, certain technical information. We may use your email and other contact details you provided us with for approaching you with direct marketing offers, including new products or services by us or by our business partners. Without limiting from the generality of the above, we may use your phone number for sending you SMS messages from time to time with promo codes for various commercial and marketing purposes. You may opt out of such marketing services by replying accordingly to messages or by letting us know you prefer to opt out at: [email protected] .
The information collect and/or received as set forth above may be used in order to measure the effectiveness of ads, offer targeted advertising and/or perform web analytics.
Advertisers may collect and/or receive this information through the use of tracking technologies like cookies and web beacons (see above). If you do not want to receive tailored advertisements from third parties, please follow the instructions below.
Third-Party Services Providers
We may share and/or disclose information with third-party suppliers and partners to perform Services on our behalf, like processing payments, analyzing data, e-mail delivery, hosting Services, customer services and to help us in our marketing efforts. We require such third parties to maintain the confidentiality of the information we share and/or disclose with them and not to use your information for anything other than to provide Services on our behalf.
Other Cases in Which We May Share and/or disclose Your Information
We may also share and/or disclose your information: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any laws or regulations; (iii) where we believe that the Services is being used in committing a crime, including to report such criminal activity or to share and/or disclose information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions; (iv) when we believe that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) to protect the rights or property of DBA DEVELOPMENTS and other applicable third parties, including to enforce our Terms of Use.
Accessing and Managing Your Information
Under applicable data protection laws and regulations, including the GDPR, you have the right to:
access your personal data and receive a copy thereof, i.e. obtain information on whether we process your personal data and specific information about any such processing;
rectify (amend) your personal data, i.e. request to amend inaccurate personal data;
delete your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under applicable law apply);
restrict the processing of your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under applicable law apply);
complain to a supervising authority; and
withdraw your consent.
You may exercise any of your rights in relation to your personal data by written notice to us at: [email protected] .
How We Protect Your information
DBA DEVELOPMENTS has made reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access. While we take reasonable precautions against possible security breaches of our Services and/or Software, no website or Internet transmission is completely secure, and DBA DEVELOPMENTS cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
How Long We Keep Your IP
How long we retain your PI depends on why we collected and/or received it and how we use it. We will not retain your PI for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain all or part of your PI for a few years after you have decided to close your account if this is necessary to meet our legal obligations or to exercise legal rights.
CCPA
This part of this Privacy Policy contains disclosures and provisions required by the California Consumer Privacy Act of 2018 (the “CCPA”) and applies only to “PI” that is subject to the CCPA and only to California residents.
Collect and/or receiveion, Disclosure or Sale of PI
In the last 12 months, we collect and/or received the categories of PI about California residents as described in this Privacy Policy including in this CCPA Privacy Notice. Our use of such PI may qualify as a “Sale” under the CCPA, since the data we provide to third parties, including to our clients and partners might help us to generate valuable consideration. Even if our own use of PI does not constitute a “Sale” under the CCPA, our clients and partners may use our technology to buy or sell PI as defined by the CCPA. If you wish to opt out of the use of your PI for interest-based advertising purposes, you may do so by contacting us at: [email protected] .
Categories of PI We Collect and/or Receive
Personal and online identifiers (such as name, emails, unique online identifiers like cookies, mobile advertising IDs, etc.). Please note that we will not, however, sell any personal identifiers such as names and emails and they will be used only for our internal purposes as described in greater depth in other parts of this Privacy Policy.
Internet or other electronic network activity information (such as browsing history, interactions with a website or advertisement).
Geolocation information.
Inferences drawn from the above information about your predicted characteristics and preferences.
Other information about you that is linked to the PI above.
Such PI was Used or Shared as follows
Categories of Sources: We collect and/or receive this PI from the following categories of sources: users and business partners.
Why We Collect and/or receive, Use, and Share and/or disclose such information: We use and disclose the PI we collect and/or receive for our commercial and business purposes, as described in greater depth in other parts of this Privacy Policy. These commercial and business purposes include, without limitation: (i) Providing our Services and/or Software, (ii) Other business purposes as identified in the CCPA, which include: advertising or marketing Services, auditing related to our interactions with you, legal compliance, detecting and protecting against security incidents, fraud, and illegal activity, performing Services (for us or our Services providers) such as account servicing, processing orders and payments, and analytics, internal research for technological improvement, internal operations, activities to maintain and improve our Services and other certain one-time uses.
Recipients of California PI: To the extent our use of PI constitutes a “Sale” under the CCPA, we “sell” PI to our partners. We disclose (or might disclose) the categories of PI designated above to the following categories of third parties, for the above commercial and business purposes: Services providers (as defined by the CCPA), government entities (upon request and to the extent we are obligated to do so), Services providers such as fraud protection vendors and data analytics companies.
Your Rights Regarding PI
If you are a California resident, you may exercise the following rights, subject to certain exceptions as they shall be from time to time: (i) the right to know categories and specific PI we collect and/or receive, use, disclose, and sell about you over the past twelve (12) months, categories of sources from which we collect and/or received your PI, our purposes for collect and/or receiving or selling your PI, the categories of your PI that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have share and/or disclosed PI, (ii) the right to request that we delete the PI we have collect and/or received from you or maintain about you, (iii) the right to opt out of any “sale” of your PI and (iv) the right not to be discriminated against for exercising any of your rights under the CCPA.
To exercise any of the above rights, please contact us at: [email protected] .
Minors under 18
Without derogating from any of our statements above, we do not sell the PI of consumers that we know to be under 18 years of age. DBA DEVELOPMENTS is taking complying with applicable laws and regulations regarding minors very seriously, including without limitations, the United States’ Children’s Online Privacy Protection Act.
If you are a parent or guardian and you have discovered that your child has submitted PI to us, DBA DEVELOPMENTS will make reasonable efforts to delete the information from its database at your request. To request the deletion of your child’s information, please send an email to [email protected] .
Changes to this Privacy Policy
We may decide to change this Privacy Policy from time to time at our sole discretion.
If we decide to make material changes to this Privacy Policy, we will tell you and other users by placing a notice on our website or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. Otherwise, we might just relace this Privacy Policy by an updated version on our website.
For any questions, comments or concerns about this Privacy Policy or any other issue (including without limitations in order to exercise any of your rights with respect to the managing of your PI) please contact us at: [email protected]
