隐私政策

With this Privacy Policy, we inform you regarding the personal data we collect in connection with your use of our games, and for which purpose the data is used. You can access this information at any time at https://www.ubeejoy.com/privacy.

1 DATA CONTROLLER AND CONTACT

The data controller within the meaning of data protection laws is:

UNIT 12 19/F TOWER B SOUTHMARK
11YIP HING STREET, WONG CHUK HANG
HONG KONG

If you have any questions or suggestions about data protection, you can send us an email to ubeejoycs@aobi.com.

2 SCOPE OF DATA PROTECTION

The scope of data protection is personal data. In accordance with Article 4(1) GDPR, personal data encompasses all information relating to an identified or identifiable natural person, which includes, for example, names or identification numbers.

3 COLLECTION AND USE OF YOUR DATA

3.1 FACEBOOK SHARE

You do not need to register in order to play our games. You can however voluntarily connect your game with your Facebook account in order to participate in the Facebook share.

If you connect your Facebook account with our game, the following data is shared with us:

·         Name

·         Date of birth (if indicated by Facebook)

·         Place of residence (if indicated by Facebook)

Please note: If you participate in the Facebook Share, your friends can also see that you play our game and you will also be displayed in the timeline. In addition, when your Facebook account is connected, a list of your friends who also participate in Facebook Share and who have connected their Facebook account with your game is shared.

You can cancel the connection with your Facebook account at any time by logging into Facebook and selecting the “Settings” option. The connection between Facebook and the app can be deleted under “Apps and Websites.”

We collect this data in order to provide our app to you and to be able to connect your account if desired, Article 6(1)(b) GDPR.

To the extent that we, as described above, process your data for the purposes of providing the functions of our app, you are contractually required to provide us with this data. Without this data, we are not able to provide these functions to you.

You are not required to provide the above voluntary information. Without this data, however, we are not able to provide these functions of our app to you.

3.2 SUPPORT REQUESTS

If you send support requests to us by email, we collect and process the data from your request in order to be able to provide a response. For this purpose, it may also be necessary for you to provide us with information about your end device so that we can process the request and resolve any technical problems that may exist.

We collect this data in order to provide our app to you and to be able to process your request, Article 6(1)(b) GDPR.

You are not required to provide the above voluntary information. In particular, you are free to send the request to us under a pseudonym, without giving your real name.

4 PERMISSIONS

Our app may use the following permissions:

5 PSEUDONYMOUS USER PROFILE

For the needs-oriented design and statistical analysis of app usage, we collect pseudonymous data about how our apps are used, and we evaluate this data statistically. Specifically, we use the following analytical services:

We collect this data on the basis of a legitimate interest in needs-oriented design, for statistical evaluation, efficient marketing of our app, and the fact that your legitimate interests do not prevail under Article 6(1)(f) GDPR.

6 ADVERTISING NETWORKS

We use the following advertising networks in order to be able to integrate advertising within our free-of-charge apps. These collect the data described below for the purpose of providing personalized advertising:

You can object to the use of personalized advertising by making the following settings depending on your device type: On iPhone or iPad, first open “Settings,” tap on “Privacy,” and open “Advertising.” Here you can enable “Limit Ad Tracking.” If you use devices with Android and Google Play Services, first open “Google Settings,” tap on “Advertising,” then open “Disable interest-related ads,” then tap on “OK.”

Use of the aforementioned advertising networks and the transmission of the data mentioned is based on our legitimate interest in recouping our investments for operation of our app through advertising and the fact that your justified interests are not overriding, Article 6(1)(f) GDPR.

7 CHANGES OF PURPOSE

Your personal data is only processed for purposes other than those described if a legal provision allows this or you have granted your consent to the changed purpose of data processing. In the event of further processing for purposes other than those for which the data was originally collected, we will notify you regarding those other purposes before further processing, and we will provide you with all other information relevant to this.

8 AUTOMATED INDIVIDUAL DECISIONS OR PROFILING MEASURES

We do not use automated processing for making decisions or profiling.

9 DISCLOSURE OF DATA

As a matter of principle, your personal data will not be disclosed to others without your explicit prior consent, except in the following circumstances:

·         If needed to investigate unlawful use of our services or to prosecute in a criminal offense, personal data can be forwarded to law enforcement agencies and, if appropriate, to any victims. However this only happens if there is concrete evidence highlighting unlawful behavior. Disclosure may likewise occur for the purpose of enforcing terms of use or other agreements. In addition, we are also required by law to disclose information to certain government agencies upon request, namely to law enforcement, to government agencies prosecuting misdemeanors punishable by fines, and to tax authorities.

Such data are disclosed by virtue of our legitimate interest in combating abuse, for prosecuting criminal offenses and for securing, asserting and enforcing claims, and because your rights and your interest in the protection of your personal data do not prevail pursuant to Article 6(1)(f) GDPR. If we are legally required to disclose data, the disclosure occurs on the basis of Article 6(1)(c) GDPR.

·         To provide our services, we outsource work to outside companies under contract and to service providers (“processors”). In such cases, personal data will be transferred to such processors to allow further processing to take place. These processors are carefully selected and regularly reviewed by us to ensure your privacy. Processors may only use data for the purposes specified by us. Moreover, processors are contractually bound to process your data only in accordance with this data protection policy and with EU data protection laws.

In order to ensure protection of your personal privacy rights within these data transfers, we employ the standard agreement clauses of the EU Commission in accordance with Article 46(2)(c) GDPR for the development of contractual relations with third countries. These are available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF, alternatively you can also request these documents from us by using the contact options specified below. Specifically, this relates to the following service providers:

·         adjust GmbH

·         As our business evolves, UBeeJoy may undergo organizational changes such as adoption of a new legal form or the establishment, purchase, or sale of subsidiaries and divisions or components of companies. Whenever such changes take place, customer information for each business unit is transferred together with the business unit. Each time personal information is disclosed to third parties as described above, we will ensure that the disclosure complies with this Privacy Policy and with applicable data protection laws.

Transfer of data to processors is based on Article 28(1) GDPR. Alternatively, transfer can be warranted on grounds of our legitimate interest in the economic and technical benefits of using specialized processors, and due to the fact that your rights and interests in protecting your personal data do not prevail under Article 6(1)(f) GDPR.

10 DELETION OF YOUR DATA

We will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs. As a rule, we store your personal data as long as you use the site or for the term of any applicable contract, unless the data must be kept longer for legal reasons, for criminal prosecution, or to secure, assert, or enforce legal claims.

If data must be kept for legal reasons, it is blocked. The data is then no longer available for further use.

11 YOUR RIGHTS AS A DATA SUBJECT

11.1 RIGHT TO INFORMATION

You are entitled at any time, upon request, to obtain information from us about your personal data within the scope of Article 15 GDPR. To request such information you may submit an application by mail or by email to the address given above.

11.2 RIGHT TO RECTIFICATION OF INACCURATE DATA

You have the right to demand that we correct forthwith any inaccurate personal data concerning you. For this purpose, please use the contact addresses listed above.

11.3 RIGHT TO DELETION

Under the conditions described in Article 17 GDPR, you have the right to demand the deletion of your personal data. In particular, you are entitled to demand deletion if the personal data is no longer needed for the purposes for which it was collected or otherwise processed, if it is no longer needed, if it was unlawfully processed, if an objection has been submitted or if deletion is mandatory under EU law or under the law of a Member State to which we are subject. For the period of data storage, please also see Section 10 of this Privacy Policy. To assert the aforesaid right, please use the contact addresses listed above.

11.4 RIGHT TO RESTRICTION OF PROCESSING

You have the right to demand that we restrict processing in accordance with Article 18 GDPR. This right applies especially if we are not in agreement with the user concerning the accuracy of any personal data. The right persists for the time required to verify its accuracy. In addition such right applies in the following cases: if the user is entitled to demand deletion but instead demands restricted processing; if the data is no longer required for the purposes we are pursuing, but the user needs them in order to assert, exercise or defend legal claims; and if an objection has been raised but its successful exercise is still disputed between us and the user. To assert the aforesaid right, please use the contact addresses listed above.

11.5 RIGHT TO DATA PORTABILITY

You have the right to demand from us whatever personal information you may have given us. Pursuant to Article 20 GDPR, at your request we must provide you with such information in a structured, commonly used and machine-readable format. To assert the aforesaid right, please use the contact addresses listed above.

11.6 RIGHT TO OBJECT

Pursuant to Article 21 GDPR, you have the right at any time to object to the processing of your personal data on grounds related to your particular situation, including grounds under Article 6(1)(e) or (f) GDPR. We will cease processing your personal information unless we can demonstrate compelling and legitimate grounds for processing that outweigh your interests, rights, and freedoms, or unless the processing is done for the purpose of enforcing, pursuing, or defending legal claims.

11.7 RIGHT TO APPEAL

You also have the right to contact us to appeal the data protection problems. ubeejoycs@aobi.com

12  CHANGES TO THIS PRIVACY POLICY

The current version of this Privacy Policy is always available at https://www.ubeejoy.com/privacy.

Last updated: 31. July 2018