Privacy Policy

Last updated: May 13, 2022

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 Guul APP

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Guul Games OÜ, Harju maakond, Kesklinna linnaosa, 3. korrus, Viru väljak 2, Tallinn 10111 Estonia.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Estonia

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Application or the Website or both. This policy is applicable to Our

Products (web platform, mobile applications, API based clients) and to Our public Site www.guul.games

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.

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).

Website refers to Guul, accessible from www.guul.games

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.

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:(i) Name: first name and last name, (ii) Contact information including email address and telephone numbers, (iii) User names (accounts alias) and passwords according to the product specifications to allow users to login and use the product, (iv) Job title or description, (v) Company or organization name, (vi) Company address, including country.

Billing and Payment Information

When you subscribe to our services we would collect your billing information like Credit Card number, Debit card number, billing address and other such information to facilitate transactions between you and us.

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.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

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 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.
  • 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.

For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the Controller of Personal Information, whereas you are "Data Subject". As a Data Controller we will process your Personal information as per this privacy policy and the principles of GDPR.

Further, If you are an EEA or Switzerland-based customer, then We are also responsible for compliance with the applicable data protection law as We are the "Controllers". As the controller, it shall be our responsibility to inform You about the processing, and, where required, obtain necessary consent or authorization for any Personal Information that is collected as part of the Personal Information through Your use of the Service(s). We will take all steps reasonably necessary to ensure that the Personal Information is treated securely and in accordance with this Policy. We also ensure to keep our Data practices in accordance with the GDPR principles and guidelines.

Privacy Rights

You are entitled to certain rights with regards to your Personal Information. Further, If you are an individual and resident of the EEA or Switzerland, You are classified as a "Data Subject" as per the GDPR. As a resident of EEA or Switzerland, you also have certain specific rights with respect to your Personal Information as mentioned below. To ensure best practices, we afford these rights to all our Users, or to all persons to whom this policy is applicable, even if they are not a resident of the European Union.

We make it our utmost priority to inform you and safeguard your rights with regards to your Personal Information and Data. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. In case of any query you can write to us at support@guul.games.

As a User:

  • You can request access to your Personal Information. This entitles you to receive a copy of your Personal Information that we hold. You can also check if we are lawfully processing your Personal Information as per this Policy and applicable Laws.
  • You have a right to request rectification of any of your Personal Information that we hold. This enables you to correct any incorrect or inaccurate Personal Information that we may possess of yours.
  • You have a right to erasure or deletion of all your Personal Information. This enables you to ask us to delete any Personal information of yours that we possess.
  • If any automated processing of your Personal Information is based on your consent or a contract with you, you have a right to transfer or receive a copy of your Personal Information in a usable and portable format;
  • If the processing of your Personal Information is based on your consent, you can withdraw consent at any time for future processing. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
  • You can object to, or obtain a restriction of, the processing of your Personal Information under certain circumstances. such as when we are relying on legitimate interests to process your Personal information, or where there is any particular or unique situation which makes you object to such processing of Personal Information.
  • You also have a right to request restriction for the processing of any Personal Information that we possess. This enables you to ask us to suspend the processing of any of your Personal information.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
  • If we have collected and processed your Personal Information with your consent, then you have a right to withdraw your consent at any time, by writing to us.
  • You have a right to Opt-out of any kind of marketing or advertising from Us. This allows you to stop Us from sending you any kind of marketing communication about our products and services.
  • You have a right to data portability which allows you to instruct us to transfer your personal Data directly to you as per your request and instructions.
  • For residents of France, you can send us specific instructions regarding the use of your Personal Information after your death.

We will not charge any fees from you for exercising your rights. However, we may charge a fee for administrative purposes if we find your request to be excessive, alternatively we can also reject your excessive requests.

California-Resident Specific Rights

If you are resident of California and is a 'consumer' as defined under the California Consumer Privacy Act of 2018 ("CCPA") and We are a 'business' as defined under CCPA, then the following provisions applies to you:

Subject to the provisions of the CCPA, you have the right to request in the manner provided herein, for the following:

Right to request for information about the:

  • Categories of Personal Information We have collected about you.
  • Specific pieces of Personal Information We have collected about you.
  • Categories of sources from which the Personal Information is collected.
  • Business or commercial purpose for collecting Personal Information.
  • Categories of third parties with whom the business shares Personal Information.

Right to request for deletion of any Personal Information collected about you by Us:

If you seek to exercise the foregoing rights to access or delete Personal Information which constitutes 'personal information' as defined in CCPA, please contact us at details provided under the Contact Information clause in this Policy. We respond to all requests we receive from you wishing to exercise your data protection rights within a reasonable timeframe in accordance with applicable data protection laws. By writing to us, you agree to receive communication from us seeking information from you in order to verify you to be the consumer from whom we have collected the Personal Information from and such other information as reasonably required to enable us to honour your request.

The details and list of the mode of collection, processing and sharing of Personal Information by Us is highlighted in the present Policy. We suggest you read it carefully and then proceed.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Slack

Their Privacy Policy can be viewed at https://slack.com/trust/privacy/privacy-policy

Microsoft Teams

Their Privacy Policy can be viewed at https://learn.microsoft.com/en-us/microsoftteams/security-compliance-overview

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: hello@guul.games

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