Privacy policy

Effective as of 01 March 2022
Last updated on 01 March 2022

Contents:

1.        Introduction

2.        Scope

3.        What is the personal information

4.        Personal information we collect

5.        Our use your information

6.        Disclosure of your information

7.        Your rights in regard to your personal information and abilities you exercise them

  1. Introduction

OWLab Limited, the company incorporated and existing under the laws of Republic of Cyprus with the registration number ΗΕ 410965, hereinabove referred to as “Gamla”, “We” or “Us”, provides interactive skill-based games. Gamla respects and values your privacy. This Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, and share your personal information, and to inform of you of how to exercise your privacy rights.

This Privacy Policy also sets out the rights of Users regarding their Personal information. We encourage you to read this Privacy Policy before using the Services. You will be deemed to have accepted this Privacy Policy if you use Our websites or register on the Platform/the Applications, or send us queries via the Website/ the Platform/the Applications or other means, such as by telephone or e-mail. If you do not accept this Privacy Policy, please refrain from using Our Services. The Privacy Policy is an integral part and governs together with the general Terms and Conditions (the "Terms"). In this sense, the terms that are not defined in the present will have the meanings that are granted in the Terms, so the User must read and understand these Terms in addition to the Privacy Policy. We expresse its maximum commitment to protecting the confidentiality of the Users and to adapting the services it provides to the Law, and in accordance with the applicable data protection regulations, we wish to keep you informed on the terms of using your Personal information and your rights in regard to latter.

  1. Scope

This Privacy Policy applies to personal information processed by us, including on our websites (https://gamla.io), games, gaming platform and applications and all other online or offline products, services, and offerings We may provide in the future. To make this Privacy Policy easier to read, our websites, games, gaming platform and mobile applications, and other offerings are collectively called the “Services.”

If you have questions regarding our Privacy Policy, please refer to “Contact Us” section.

  1. What is the personal information

We are responsible for the Privacy of your personal data We collect. Personal data will be understood to be any information that allows the User ("you", "your" or the "User/s") to be directly or indirectly identified, such as, for example, name, location, online identifier, e-mail, financial data, etc. (“Personal information").

  1. Personal information we collect

We collect Personal information from our customers (Users). The categories of personal information We collect depend on how you interact with Us, our Services, and the requirements of applicable law. We collect information that you provide to Us, information We obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information you provide to us directly

We may collect the following Personal information that you provide to Us:

  1. Account creation

To access certain parts of our Services, you may need to create a profile (your “Gamla Account”). When you create a Gamla Account for use with our applications and games, We may collect, but not limited to the name, surname, username, password, country location (or state either territory), date of birth and email address. You may also have the option to add a short description about yourself or a profile image. Your Username, country location, profile image, and description about yourself will be visible to other Users.

Date of Birth: to play cash games, you will need to provide your date of birth, which will be associated with your account.

  1. Payment Information

We may collect personal information and details associated with you if you make purchases and withdrawals via our Services. In addition to the details of the withdrawal and the account information described above, We may require first and last name, phone number, and physical address to facilitate withdrawals, and may also require you to provide your government-issued ID (e.g., your social security number or ITIN) for tax purposes if you make significant withdrawals via our Services. The third-party payment processing companies who process your transactions (which may include PayPal, Apple Pay, etc.) may directly collect your first and last name, date of birth, email address, physical address, credit and debit card information, government-issued identification, preferred currency, bank statements, Internet protocol (IP) address, phone number, and other personal or financial information as needed to verify your identity and confirm you are legally eligible to make withdrawals from your account. All withdrawals, purchases, and deposits are processed by our third-party service providers, and We do not directly collect or store any payment information ourselves.

  1. Accessing to the Services without creation of an account

You can also access some our Services as a guest, without creating an account. If you use our Services without creating or logging into an account, We will still collect the personal information described in “Information collected automatically or from others” below associated with your device identifiers and may also collect include your name and payment information (as described in the “Payment Information” section hereinabove), device information, and location. We may connect this information with your Gamla Account, if you have one, or if you create an account with Us at a later date.

  1. Biometric Information

In connection with our identity verification procedures, you may be required to take a selfie with your government-issued ID, which Our service providers may analyze to ensure your facial image matches the photo in your government-issued ID. If you consent to our collection of biometric information, you agree that We may collect your image, including your image on your government-issued ID. Your biometric information may be shared with Our service providers who may perform a scan of your facial geometry to provide identity verification services to Us. Where required by law, We will delete your biometric information within 3 years from your last interaction with Our Services. There can also be realized the procedure when you may be required to pass through the verification with your government-issued ID with Our verification service provider or such of Our payment services provider. In such a case you can only provide such a provider with the information requested based on their terms of service which you read and accept, and We don’t obtain your image, save as one you provided with registering your account, and any images of your documents thus We don’t procure any obligations in respect to your data provided by you to such provider.

  1. Information to combat fraud

In addition to the information described above, in some instances, We may also ask you to upload a video of yourself playing our games to ensure you are the one actually playing. We use this information to help us manage risk, prevent fraud, and enhance the security of Our Services.

  1. Your communications with Us

We may collect personal information, such as email address, phone number, or mailing address when you request information about Our Services, register for Our newsletter or loyalty program, request customer or technical support, or otherwise communicate with Us.

  1. Surveys

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

  1. Interactive features

We and others who use Our Services may collect personal information that you submit or make available through Our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Gamla also may collect, use, store, transmit and publicly display statistical data regarding your game play (e.g., scores, rankings, and achievements). Any information you provide using the public sharing features of the Services (referred to in this Policy as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution and discretion before revealing any information that may identify you in the real world to other Users.

  1. Sweepstakes, Tournaments, Competitions, or Contests

We may collect personal information you provide for any sweepstakes, tournaments, competitions, or contests that We offer (e.g., name, email address, date of birth). In some jurisdictions, We are required to publicly share information of sweepstakes and contest winners.

B. Information collected automatically or from others

We may collect personal information automatically when you use Our Services:

  1. Automatic Data Collection

We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser, operating system or device information, MAC address, WiFi routing information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of Our Services, such as pages that you visit before, during and after using Our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use Our Services. We may combine your information with information that other people provide when they use our Services.

  1. Telemetry

When you play Our games, We may collect statistics and other information about how you use the Services. This may include information about gameplay, game server usage, game device usage, system interactions, friends you connect with through Our Services, and other information associated with your Gamla Account. We might also record your gameplay, (including your button inputs), and replay it to you or other Users or use it to improve Our Services and prevent fraud. We may also use records of your in-game behavior and skill levels to match you with other players.

  1. Crash reports

We may collect usage details about when you launch Our games, when and how long you play each game, and detailed crash reports, which may contain information about the hardware or device you play Our games on.

  1. Location information

To participate in some of Our cash games or otherwise use certain features of the Services, We may collect precise geolocation data (e.g., GPS coordinates) from your mobile device or WiFi routing information, Internet service provider and approximate location derived from IP address of your device in case the precise geolocation data is not available.

  1. Cookies, pixel tags/web beacons, and other Technologies

We, as well as third parties that provide content, or other functionality on Our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of Our Services.

  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. For more information on the use and management of cookies, please refer to our Cookie Policy.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in Our Services that collects information about engagement on Our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to Our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of Our functionality;
  • Performance-Related. We may use Technologies to assess the performance of Our Services, including as part of our analytic practices to help us understand how individuals use Our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow Us to offer you enhanced functionality when accessing or using Our Services. This may include identifying you when you sign into Our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

  • Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
  • Social Media Platforms. Our Services may contain social media buttons, such as Facebook, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on Our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information collected from other sources

We may obtain information about you from other sources, including through third-party services and organizations.

  • Third-Party Websites, Applications, or Platforms. To access some of Our Services, you may have the option to link an account on a third-party website, application, or platform, such as Google, Facebook, and Apple (“Third-Party Platforms”) with the Services. Third-Party Platforms are not controlled by Us, and their collection and usage of personal information is subject to their respective privacy policies. We may obtain additional information about you from the Third-Party Platforms, depending on your privacy settings.
  • Referrals and Sharing Features. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only send content from Our Services with people with whom you have a direct relationship (e.g., relative, friend, neighbor, partner or colleague).

  1. Our use your information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide our services

We use your information to execute Our obligations and and provide you with Our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of Our Services;
  • Personalizing the Services for you, such as sending you birthday rewards or other benefits;
  • Answering requests for customer or technical support;
  • Communicating with you about your account, activities on Our Services, and policy changes;
  • Processing your financial information and other payment methods for products or Services purchased; and
  • Processing applications if you apply for a job We post on Our Services.

 

B. Administrative purposes

We use your information to analyse and improve Our Services in our legitimate interest, or to comply with Our legal obligations, such as:

  • Pursuing Our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Determining your eligibility to use Our Services, including under local law;
  • Measuring interest and engagement in Our Services;
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading, or enhancing Our Services;
  • Developing new products and Services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
  • Debugging to identify and repair errors with Our Services;
  • Auditing relating to interactions, transactions, and other compliance activities;
  • Telephone conversations may be recorded for security reasons, for legal requirements and to improve our services; Observe legal and regulatory obligations or respond to the requirements of public authorities;
  • Sharing information with third parties as needed to provide the Services and as describer herein and in the Terms;
  • Enforcing Our agreements and policies; and
  • Other uses as required to comply with Our legal obligations.

C. Marketing and advertising our products and services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law, such as:

  • Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services; and
  • Email campaigns, custom audiences advertising and “interest-based” or “personalized advertising.”

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact Us at any time as set forth in the “Contact Us” section.

D. Other purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
  • Automated Decision-Making. We may engage in automated decision making, including profiling, for example to determine your skill level, to match you with players of a similar skill level, and to determine if you are permitted to make withdrawals from your Gamla Account. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract We have with you, We have your consent, or We are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact Us as set forth in the “Contact Us” section.
  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access Our Services, or other analyses We create. If We create or receive personal data that has been de-identified or aggregated, We will not attempt to reidentify it, except to comply with applicable law.
  • Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps in order to prevent fraud. For example, We may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, Our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

This usage refer mainly to financial regulations, the prevention of money laundering and may entail a certain degree of automation in the creation of profiles, based on the User's registration and activity data; We might do it to protect our rights, as well as those of Our related parties.

In certain cases We may consider it necessary, always acting in good faith, to record and disclose data, in order to (i) protect, defend or enforce Our legal rights, as well as Our privacy, security and assets, (ii) protect the security, privacy and trust of both Users and the general public, and (iii) manage commercial risk; to improve the security, services and features of the the Website/ the Platform/the Applications.

Gamla carries out the data processing through partially or fully automated electronic means, protecting them with adequate security measures. However, activities capable of producing significant legal effects, such as profile-based decision-making, always involve human intervention, or else the final decision is in the hands of individuals. We apply the appropriate legal, administrative, organizational, technical, physical and personnel measures, both by design and by default, to prevent the loss, theft and unauthorized use, disclosure or modification of data. The Website/ the Platform/the Application may contain links to or from networks associated with third party websites or applications. If you access a link that directs you to any of these websites or applications, please note that these will apply their own general conditions and privacy policies. Gamla declines all responsibility related to their content. Check these general policies and conditions before accepting the sending of data to these platforms.

  1. Disclosure of your information

Your data can be processed by:

  • Service providers. Our external service providers that provide services contemplated in the Terms or ensure the correct functioning of the Website/ the Platform/the Application: payment services, marketing, companies that ensure Our cybersecurity, etc.
  • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom We jointly offer products or services.
  • Affiliates. We may share your personal information with Our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you, or to support and supplement the Services We provide.
  • Public authorities in the exercise of their legal powers. This category would include complaints to the competent authorities such as the Office of the Commissioner for Personal Data Protection. The above recipients can be located both within and outside the European Economic Area (EEA).

Third party access to User data is limited exclusively to the information that is necessary for the third party to perform the corresponding function on Our behalf or in accordance with the provisions of the law. The third parties in question are subject to the obligations of confidentiality and data protection provided for by law and which We consider necessary, as well as the relevant security measures Gamla will refrain from transferring User data to countries outside the EEA unless appropriate protective measures are in place there. In the event of data transfers to countries whose level of data protection is not considered adequate by the EC, We shall, in accordance with the regulations in force, have appropriate safeguards in place to protect the data.

  • Other Users/Website Visitors. As described above, our Services allow you to share your profile and/or User Content with other Users/publicly, including to those who do not use Our Services.

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

If Gamla disposes of part or all of its business or its assets, or is involved in a merger or business transfer process, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, it may reveal and transfer the User's data to the other party or parties.

  1. Your rights in regard to your personal information and abilities you exercise them

Anyone has the right to obtain information about whether Gamla is processing personal information concerning them. You have the right to access your personal information, as well as to request the rectification of inaccurate data or, where appropriate, to request its elimination when, among other reasons, the data are no longer necessary for the purposes for which they were collected. Under certain circumstances you may request the restriction of processing your data, in which case We will only keep your data for the exercise or defence of legal claims. Under certain circumstances and for reasons related to your particular situation, you may object to the processing of your data. We will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims you may obtain a copy of your personal data in a structured and commonly used electronic format and transfer your data, and other information that you have provided, from one electronic processing system to another if you wish to do so. To exercise these rights, We shall provide the corresponding forms that you must fill out and send by e-mail to Us. Similarly, we inform you that you can exercise your right to file a claim with the competent Data Protection control authority.

  1. Term of keeping your personal information

We keep the personal information We collect as described in this Privacy Policy for as long as you use Our Services, or as necessary to fulfil the purpose(s) for which it was collected, provide Our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce Our agreements, and comply with applicable laws.

Your public User Content shall be kept for as long as We deem necessary to do so, at the maximum extent permitted by the applicable law.