Privacy Policy
==============
Last updated: March 31, 2023
This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy.
Interpretation and Definitions
==============================
Interpretation
--------------
The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.
Definitions
-----------
For the purposes of this Privacy Policy:
* Account means a unique account created for You to access our Service or
parts of our Service.
* Affiliate means an entity that controls, is controlled by or is under
common control with a party, where "control" means ownership of 50% or
more of the shares, equity interest or other securities entitled to vote
for election of directors or other managing authority.
* Application means the software program provided by the Company downloaded
by You on any electronic device, named "Trivia Tackle"
* Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Ibex Smart Communications FZ-LLC, 2110, Shatha Tower,
Dubai Media City.
For the purpose of the GDPR, the Company is the Data Controller.
* Country refers to: United Arab Emirates
* Data Controller , for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or
jointly with others determines the purposes and means of the processing of
Personal Data.
* Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
* Do Not Track (DNT) is a concept that has been promoted by US regulatory
authorities, in particular the U.S. Federal Trade Commission (FTC), for
the Internet industry to develop and implement a mechanism for allowing
internet users to control the tracking of their online activities across
websites.
* Personal Data is any information that relates to an identified or
identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to
You such as a name, an identification number, location data, online
identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity.
* Service refers to the Application.
* Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used. For
the purpose of the GDPR, Service Providers are considered Data Processors.
* Third-party Social Media Service refers to any website or any social
network website through which a User can log in or create an account to
use the Service.
* Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).
* You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as
the Data Subject or as the User as you are the individual using the
Service.
Collecting and Using Your Personal Data
=======================================
Types of Data Collected
-----------------------
Personal Data
~~~~~~~~~~~~~
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:
* Email address
* First name and last name
* Usage Data
Usage Data
~~~~~~~~~~
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The Company allows You to create an account and log in to use the Service
through the following Third-party Social Media Services:
* Google
* Apple
* Google Play
* Facebook
If You decide to register through or otherwise grant us access to a Third-
Party Social Media Service, We may collect Personal data that is already
associated with Your Third-Party Social Media Service's account, such as Your
name, Your email address, Your activities or Your contact list associated with
that account.
You may also have the option of sharing additional information with the
Company through Your Third-Party Social Media Service's account. If You choose
to provide such information and Personal Data, during registration or
otherwise, You are giving the Company permission to use, share, and store it
in a manner consistent with this Privacy Policy.
Information Collected while Using the Application
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
While using Our Application, in order to provide features of Our Application,
We may collect, with Your prior permission:
* Information regarding your location
* Pictures and other information from your Device's camera and photo library
We use this information to provide features of Our Service, to improve and
customize Our Service. The information may be uploaded to the Company's
servers and/or a Service Provider's server or it may be simply stored on Your
device.
You can enable or disable access to this information at any time, through Your
Device settings.
Use of Your Personal Data
-------------------------
The Company may use Personal Data for the following purposes:
* To provide and maintain our Service , including to monitor the usage of
our Service.
* To manage Your Account: to manage Your registration as a user of the
Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered
user.
* For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.
* To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile
application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted
services, including the security updates, when necessary or reasonable for
their implementation.
* To provide You with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless You have opted
not to receive such information.
* To manage Your requests: To attend and manage Your requests to Us.
* For business transfers: We may use Your information to evaluate or conduct
a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Our assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about our Service users is among the assets
transferred.
* For other purposes : We may use Your information for other purposes, such
as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service,
products, services, marketing and your experience.
We may share Your personal information in the following situations:
* With Service Providers: We may share Your personal information with
Service Providers to monitor and analyze the use of our Service, to show
advertisements to You to help support and maintain Our Service, for
payment processing, to contact You.
* For business transfers: We may share or transfer Your personal information
in connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of Our business to
another company.
* With Affiliates: We may share Your information with Our affiliates, in
which case we will require those affiliates to honor this Privacy Policy.
Affiliates include Our parent company and any other subsidiaries, joint
venture partners or other companies that We control or that are under
common control with Us.
* With business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
* With other users: when You share personal information or otherwise
interact in the public areas with other users, such information may be
viewed by all users and may be publicly distributed outside. If You
interact with other users or register through a Third-Party Social Media
Service, Your contacts on the Third-Party Social Media Service may see
Your name, profile, pictures and description of Your activity. Similarly,
other users will be able to view descriptions of Your activity,
communicate with You and view Your profile.
* With Your consent : We may disclose Your personal information for any
other purpose with Your consent.
Retention of Your Personal Data
-------------------------------
The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
periods.
Transfer of Your Personal Data
------------------------------
Your information, including Personal Data, is processed at the Company's
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.
The Company 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 Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.
Disclosure of Your Personal Data
--------------------------------
Business Transactions
~~~~~~~~~~~~~~~~~~~~~
If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
~~~~~~~~~~~~~~~
Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
Other legal requirements
~~~~~~~~~~~~~~~~~~~~~~~~
The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
* Comply with a legal obligation
* Protect and defend the rights or property of the Company
* Prevent or investigate possible wrongdoing in connection with the Service
* Protect the personal safety of Users of the Service or the public
* Protect against legal liability
Security of Your Personal Data
------------------------------
The security of Your Personal Data is important to Us, but remember that 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 Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
============================================================
The Service Providers We use may have access to Your Personal Data. These
third-party vendors collect, store, use, process and transfer information
about Your activity on Our Service in accordance with their Privacy Policies.
Analytics
---------
We may use third-party Service providers to monitor and analyze the use of our
Service.
* Firebase
Firebase is an analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device
settings, such as your device advertising settings or by following the
instructions provided by Google in their Privacy Policy:
<https://policies.google.com/privacy>
We also encourage you to review the Google's policy for safeguarding your
data: <https://support.google.com/analytics/answer/6004245>
For more information on what type of information Firebase collects, please
visit the How Google uses data when you use our partners' sites or apps
webpage: <https://policies.google.com/technologies/partner-sites>
Advertising
-----------
We may use Service Providers to show advertisements to You to help support and
maintain Our Service.
* AdMob by Google
AdMob by Google is provided by Google Inc.
You can opt-out from the AdMob by Google service by following the
instructions described by Google:
<https://support.google.com/ads/answer/2662922?hl=en>
For more information on how Google uses the collected information, please
visit the "How Google uses data when you use our partners' sites or app"
page: <https://policies.google.com/technologies/partner-sites> or visit
the Privacy Policy of Google: <https://policies.google.com/privacy>
* AppLovin
AppLovin is provided by the AppLovin Corporation.
If you'd like to opt-out from AppLovin service, please visit the AppLovin
Opt-out page: <https://www.applovin.com/optout>
If you'd like to learn more about AppLovin, please visit the Privacy
Policy page of AppLovin: <https://www.applovin.com/privacy>
Email Marketing
---------------
We may use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You.
You may opt-out of receiving any, or all, of these communications from Us by
following the unsubscribe link or instructions provided in any email We send
or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
* Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket
Science Group LLC.
For more information on the privacy practices of Mailchimp, please visit
their Privacy policy: <https://mailchimp.com/legal/privacy/>
Payments
--------
We may provide paid products and/or services within the Service. In that case,
we may use third-party services for payment processing (e.g. payment
processors).
We will not store or collect Your payment card details. That information is
provided directly to Our third-party payment processors whose use of Your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.
* Apple Store In-App Payments
Their Privacy Policy can be viewed at
<https://www.apple.com/legal/privacy/en-ww/>
* Google Play In-App Payments
Their Privacy Policy can be viewed at
<https://www.google.com/policies/privacy/>
GDPR Privacy
============
Legal Basis for Processing Personal Data under GDPR
---------------------------------------------------
We may process Personal Data under the following conditions:
* Consent: You have given Your consent for processing Personal Data for one
or more specific purposes.
* Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual
obligations thereof.
* Legal obligations: Processing Personal Data is necessary for compliance
with a legal obligation to which the Company is subject.
* Vital interests: Processing Personal Data is necessary in order to protect
Your vital interests or of another natural person.
* Public interests: Processing Personal Data is related to a task that is
carried out in the public interest or in the exercise of official
authority vested in the Company.
* Legitimate interests: Processing Personal Data is necessary for the
purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.
Your Rights under the GDPR
--------------------------
The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the
EU, to:
* Request access to Your Personal Data. The right to access, update or
delete the information We have on You. Whenever made possible, you can
access, update or request deletion of Your Personal Data directly within
Your account settings section. If you are unable to perform these actions
yourself, please contact Us to assist You. This also enables You to
receive a copy of the Personal Data We hold about You.
* Request correction of the Personal Data that We hold about You. You have
the right to have any incomplete or inaccurate information We hold about
You corrected.
* Object to processing of Your Personal Data. This right exists where We are
relying on a legitimate interest as the legal basis for Our processing and
there is something about Your particular situation, which makes You want
to object to our processing of Your Personal Data on this ground. You also
have the right to object where We are processing Your Personal Data for
direct marketing purposes.
* Request erasure of Your Personal Data. You have the right to ask Us to
delete or remove Personal Data when there is no good reason for Us to
continue processing it.
* Request the transfer of Your Personal Data. We will provide to You, or to
a third-party You have chosen, Your Personal Data in a structured,
commonly used, machine-readable format. Please note that this right only
applies to automated information which You initially provided consent for
Us to use or where We used the information to perform a contract with You.
* Withdraw Your consent. You have the right to withdraw Your consent on
using your Personal Data. If You withdraw Your consent, We may not be able
to provide You with access to certain specific functionalities of the
Service.
Exercising of Your GDPR Data Protection Rights
----------------------------------------------
You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You are in
the European Economic Area (EEA), please contact Your local data protection
authority in the EEA.
"Do Not Track" Policy as Required by California Online Privacy Protection Act
(CalOPPA)
========================================================================
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities.
If You are visiting such websites, You can set Your preferences in Your web
browser to inform websites that You do not want to be tracked. You can enable
or disable DNT by visiting the preferences or settings page of Your web
browser.
Children's Privacy
==================
Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification
of parental consent, We take steps to remove that information from Our
servers.
If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent's
consent before We collect and use that information.
Links to Other Websites
=======================
Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party's
site. We strongly advise You to review the Privacy Policy of every site You
visit.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Changes to this Privacy Policy
==============================
We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the "Last updated" date at the top
of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.
Contact Us
==========
If you have any questions about this Privacy Policy, You can contact us:
* By email: privacy@ibexsolutions.net