Last Updated: 25.09.2022
Samfinaco Limited develops and publishes social games for the web and mobile devices. This Privacy Notice (this “Notice”) describes the ways Samfinaco Limited (“Studio,” “us”, “our” or “we”) collects, stores, uses, discloses or otherwise processes personal information of our users (“users” or “you”) in connection with their use of our products or services, including our product offerings such as our website available at https://belka-games.com and Studio game(s) provided on a mobile platform or any other Studio product or service that posts or links to this Notice (each a “Service,” collectively, the “Services”). Additionally, this Notice describes the rights and choices concerning your information that may apply to you.
This Privacy Notice covers the following topics:
- Personal information we collect and how we collect it
- How we use your information
- Sharing of your information
- Online advertising
- Security of your information
- Data retention
- Children’s privacy
- Third-party websites and services
- Transfer of personal information outside your country
- Managing your information
- Specific provisions for EEA, UK and Swiss individuals
- Specific provisions for California Consumers
- Changes to this Notice
- Contact information
If you have questions regarding this Notice or our collection and use of personal information, please contact us as described in the Section “Contact Us”.
- PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile). At times, we may collect personal information about you from other sources and third parties, including other players.
A. Information We Collect Automatically or From You Directly
We may offer you the option to complete a user profile that is visible to other Studio users (“Account”). If you create an Account, you may provide us your name, a username, e-mail address, a password and other information that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect, we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. Your username associated with your Account will be public and will be shown to other users. In addition, your username will allow others to access information on your user profile that is considered public or that you have designated as public in your user profile settings.
Address Book Information
We may also offer you the ability to choose to import your contacts or manually enter e-mail addresses so that you can locate your contacts on Studio and invite your contacts to join you in the Services. This information is typically collected through the use of third-party mobile device software development kits. If you choose to import your contacts or manually enter e-mail addresses, we will store those contacts for purposes of helping you and your contacts make connections through our Services. You are responsible for ensuring your sharing of this information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information.
Technical and Usage Information
Information Collected by or Provided to Customer Support
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game-play or activity on the Services, and your username or ID number. We will also store the correspondence and information within the correspondence that you choose to share with us.
We may collect information about your interests and communication preferences that you choose to provide, such as when subscribing to news or alerts.
Surveys, User Research Projects, Competitions and Promotional Events
If you choose to participate in, or fill out any forms relating to, Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, we will collect your contact information (such as your name, email, and phone number, address and postal code) to enable you to participate in the activity and to allow us to communicate with you, as well as any other information that we request that you provide for purposes of the activities, including audio or video recordings, photos, and/or screen captures. In connection with Studio surveys and user research projects, we may also collect your age, gender, opinions, responses to certain research questions, prompts, or surveys, and other personal information, consistent with the purposes of the Studio survey or user research project.
On occasion, we may also collect your shipping and billing information to send you certain rewards or incentives, such as if you are a participant in a Studio survey or user research project, a competition winner, or if you purchase our products or services. In addition, if you are a part of our event or promotion partner, we may also collect your personal information including your name, company email, and company address.
Please note that your participation in any Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, is completely voluntary.
B. Information We Collect From Other Sources
We may collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers, such as digital advertising companies; and (iii) social networking sites. We may combine this information with the information we collect from an individual directly.
C. Sensitive or Special Categories of Information
We typically do not request or seek to elicit sensitive or special categories of information, but you may choose to provide this information to us in connection with certain of the interactions described above, including when you ask for assistance from our Customer Support team. The meaning of sensitive or special categories of information varies by jurisdiction and it could include, for example, health, genetic or biometric data, or precise location information.
- HOW WE USE YOUR INFORMATION
We use information collected through our Service for purposes described in this Notice or disclosed to you in connection with our Service. For example, we may use your information for:
- Create your Service accounts and allow access to our Services;
- Identify and suggest connections with other Studio users;
- Operate our Services;
- Improve our Services;
- Understand you and your preferences to enhance your experience and enjoyment using our Services;
- Respond to your comments and questions and provide customer service;
- Provide and deliver products and services you request;
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- Conduct and administer surveys, user research projects, competitions and promotional events that you participate in;
- Enable you to communicate with other users; and
- Fulfill any other purpose for which you provide personal information.
Marketing and Advertising
- Deliver and target advertising and marketing and promotional information to you; and
- Communicate with you (including via email and push notifications) about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners.
Research and Development
- Create aggregate or anonymous information derived from the personal information we handle, which we may use and disclose for research, development and other lawful business purposes;
- Link or combine personal information with other information we get from third parties to help understand your preferences and provide you better services; and
- Analyze information to choose to provide to us in connection with Studio surveys and user research projects to gain insights into how users engage with our Services, to improve our Services, to consider developing new products or services, and other lawful purposes.
Compliance and Protection
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by investigating, bringing, making or defending legal claims);
- Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- Enforce the terms and conditions that govern the Services; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
We may occasionally send you push notifications through our Service to send you game updates, high scores and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
- SHARING OF YOUR INFORMATION
We may share information we collect for the following purposes:
- Service Providers. With service providers that perform services on our behalf or enhance our Services, including hosting services, customer service, analytics services and to assist us in our marketing efforts;
- Payment Processors. With third-party payment processors that process payments you make;
- Advertising Partners. Advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts, including as described in the Online Advertising section below;
- Affiliates. With our parent company, subsidiaries and other affiliates;
- Professional Advisors. With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;
- Authorities and others. With law enforcement and public authorities, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above;
- Business Transferees. With acquirers and other relevant participants (and their advisors) in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Studio or our affiliates (including, in connection with a bankruptcy or similar proceedings); and
- Your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.
- ONLINE ADVERTISING
To the extent we display advertising in our Services, with your consent as may be required by applicable law, we may share or we may allow online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time to enable them to play or display ads on our Services, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies, software integrations, or similar tracking technologies, which recognize the device you are using. We and our third-party partners use this information to try to make the advertisements you see online more relevant and tailored to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such information includes the following:
- Device make, model and operating system;
- Device properties related to screen size & orientation, audio volume and battery;
- Operating system;
- Name and properties of mobile application through which the user interacts with the Services;
- Country, time zone and locale settings (country and preferred language);
- Network connection type and speed;
- IP Address;
- City- and/or country-level geolocation data;
- Internet browser user-agent used to access the Services; and
- Advertising ID (IDFA on iOS devices and GAID on Android devices).
A list of these advertising partners and their privacy policies is available at link. The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to review those privacy policies to learn more about their data collection and use practices.
Social Media Widgets
Our Service may include social media features, such as the Facebook button, Google, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. Your interactions with those features are governed by the privacy notices of those companies.
We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-parties who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.
Google Analytics and Advertising
We utilize certain forms of display advertising and other advanced features through Google Analytics, including, but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager Integration, Google Ads, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. To learn how you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.
Opting-Out of Interest-Based Advertising
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:
You may also limit data collection by third parties by visiting your mobile device settings and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”) or by exercising other privacy options in your device’s settings.
Please note that electing to opt-out will not stop advertising from appearing in your browser or applications or reduce the number of ads that you receive. You will still receive ads, but those ads may be less relevant to your interests. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to apply your opt-out choices to that particular browser or device.
Do Not Track
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- SECURITY OF YOUR INFORMATION
We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.
However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.
- DATA RETENTION
We store data on servers in the U.S. and EU or any other country in which the Studio or its affiliates, subsidiaries, agents or contractors or service providers maintain facilities. We retain your personal information for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When we no longer require your personal information, we will look to delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
- CHILDREN’S PRIVACY
The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please contact us at email@example.com.
- THIRD-PARTY WEBSITES AND SERVICES
The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party. Please note that the Studio is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.
- TRANSFER OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Economic Area, United Kingdom or Switzerland, your personal information may be processed outside of those regions, including in the United States.
- MANAGING YOUR INFORMATION
Subject to certain exemptions, you can manage information we receive about you.
If you would like us to delete your information, you may send an e-mail to firstname.lastname@example.org and place “Delete My Account” in the subject line. If you proceed with the deletion of your account, you will no longer have access to the game account or services associated with your account. Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games, if applicable, and deleting the game from your mobile device. Please note that if you ask us to delete your account, all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future. Please note that your information, for example records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.
If you wish to review, change or correct the information we have about you, you may send an e-mail to email@example.com making this request.
For all of the above requests, we will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems.
- SPECIFIC PROVISIONS FOR EEA, UK AND SWISS INDIVIDUALS
These additional provisions apply to individuals who are located in European Economic Area (“EEA”), United Kingdom (“UK”) and Switzerland.
Samfinaco Limited having its registered address at 1100 Page Mill Road, Palo Alto, CA 94304, is the “data controller” responsible for the processing of personal data in connection with our Services. This means that we determine and are responsible for how your personal information is used.
Your Rights With Respect to Your Personal Information
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Accessing and Correcting Your Personal Information. At any time, you may request to access the personal data that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide us with the necessary information to correct it.
- Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.
- Transferring Your Personal Data (Otherwise Known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.
- Right to Object to Processing. You have the right to object to our processing of your personal data, under certain conditions.
- Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data based on that consent. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
If you wish to exercise any of your rights detailed above, please contact us at firstname.lastname@example.org or write to us at the address set forth in the “Contact Us” section. If you make a request, we will typically look to respond within one month, although a longer period may be permitted.
Right to Make a Complaint. In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavor to deal with your request. This is without prejudice to your right to make a complaint with an EU data protection supervisory. If you are based in the European Union, information about how to contact your local data protection authority is available at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html), respectively.
Lawful Basis for Processing
With respect to each of the purposes for which we use your personal information (see Sections 2, 3 and 4 above), the lawful basis that we may rely upon will vary based on the nature of, and reason for, particular use to which we are putting your personal information. However, typically we will use your personal information:
- Where we need to do so to perform a contract we are about to enter into with you or have entered into with you – for example, this will be relevant where we use your personal information to provide you with the Services, to operate the Services and to create and maintain your Account.
- Where it is necessary for our legitimate interests, and/or those of a third party, and your interests and fundamental rights do not override those interests – for example, this will be relevant where we share your personal information in the context of an actual or prospective corporate event, in these cases we and any relevant third parties have a legitimate interest in enabling those parties to investigate and, where relevant, to continue to operate, all or relevant part(s) of our operations.
- Where we need to comply with a legal or regulatory obligation – for example, this will be relevant where we are legally obliged to provide your personal information to authorities to comply with lawful governmental or regulatory requests.
- Where we have your specific consent to carry out the processing for the purpose in question – for example, this will be relevant where we use your personal information to show you targeted online advertising.
For questions about the lawful basis we rely on for data processing, please contact us at firstname.lastname@example.org. Visit the “Contact Us” section below for contact information.
Marketing and Advertising
From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email or push notifications. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
Where we rely on consent to send you marketing communications, we will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences in the settings page of the App or Service.
Data Transfers and Processing Outside Europe
If you are located in the EEA, UK or Switzerland, your personal information may be processed outside of those regions, including in the United States. In the event of such a transfer, we typically try to ensure a degree of protection similar to that applied in your home country is afforded to it by employing one of the following mechanisms:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the relevant authorities (e.g., by the European Commission, UK Government and/or Swiss Federal Council).
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by those relevant authorities (e.g., the United States).
- However, in these cases, we may look to use specific appropriate safeguards approved by the relevant authorities, which are designed to give personal information the same protection it has in the EEA, UK or Switzerland – for example, standard-form contracts approved by relevant authorities for this purpose.
In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to recipients in such countries despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
If you want further information on the specific mechanism(s) used by us when transferring your personal information, please contact us at email@example.com. Visit the “Contact Us” section below for contact information.
- SPECIFIC PROVISIONS FOR CALIFORNIA CONSUMERS
These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.
Your California Privacy Rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties to whom we disclose Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Correct. You can request that we correct any information on your account that is not accurate, complete, or updated by providing us with the necessary information to correct it.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. You can opt-out of any sale of your Personal Information.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
Right to Opt Out of Information Sales
We do not “sell” information about our users as most people would commonly understand that term. However, consistent with common practice among companies that operate online, we do “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research. To learn more about how third parties collect information automatically on our Site and the choices you may have in relation to those activities, please see our Online Advertising section, above.
How to Exercise Your Rights
To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales, or any other right you may have under applicable law, please submit a request by emailing firstname.lastname@example.org or by writing to us at the physical address in the “Contacts” section below, with the subject line “California Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete). We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
Category of Personal Information Collected
Source(s) of Personal Information
Business Purpose(s) for Collection
Categories of Third Parties to Whom We Disclose the PI for a Business Purpose
Identifiers, such as name, user name, email address and other contact information, IP address, and online identifiers (like advertising IDs and cookies)
Additional California Customer Records, such as address book information
Characteristics of Protected Classifications, such as age or gender
Commercial Information, such as purchase history, in-app purchases, or other purchasing or consuming histories or tendencies
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement
Geolocation Data, such as city or county-level geolocation information
Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
* Pursuant to the CPRA and as further described above, this information is “shared” with advertising partners for interest-based advertising.
- CHANGES TO THIS NOTICE
We may update this Notice to reflect changes to our data and information privacy practices. If we make any material changes, we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Notice for the latest information on our privacy practices. Please note that if we need to adapt the Notice to legal requirements, the new privacy Notice will become effective immediately or as required.
- CONTACT US
Our Data Protection Officer
You may contact us at email@example.com or at the address below for further information.
1100 Page Mill Road, Palo Alto, CA 94304