PRIVACY POLICY OF THE GOTOTOP, LTD
Updated and Effective as of November 2, 2020
1. General Thank you for choosing to be part of our community at Gototop, LTD ("we", "us", or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at
habio.app@support-team.app. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we may collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Apps and our services.
In this notice, «Services» refers to our Games, Websites, and any related services or properties we control; «Gamesor App» refers to games, applications, and other products produced by us on any and all platforms; «Websites»refers to websites and other online properties we control, including
www.habio.app; «your data» is used when referring to personal data that relates to you as an identified or identifiable individual; «anonymous data» does not include data where the identity has been removed; «User, consumer» is any third party that accesses the App and is not either employed by Gototop, LTD or otherwise providing services to Gototop, LTD.
Please read this Policy carefully and do not hesitate to contact us if you have any questions at habio.app@support-team.app. By using the Services, you agree to the collection and use of information in accordance with this policy.
This Privacy Policy may be updated from time to time so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.
Where applicable, if you do not provide us the relevant Personal Data, you may not be able to use our Services completely. You should not use the Services if you do not agree with this Policy, our Terms of Use and any other agreement that governs your use of the Services. 2. Personal Data we may collect or use Within the present privacy policy of the Gototop, LTD under personal data the information relating to an identified or identifiable User.
We may collect, use, receive, transfer and share the following kinds of Personal Data about you (cases of collection are indicated).
User-provided information - When you register for the Services as a user, we may collect the following Personal Data from you directly: your name (or nickname), registration data (login/name/e-mail address and password, zip code/postal code) (collectively, "Registration Information").
- When you use the Services, we may collect the following information: information about your habits (this information you may independently send to us by using our App "Habio)".
- When you download an App, we receive whatever information the applicable App Marketplace shares with us. In certain cases, we may require certain Registration Information, and in other cases we may simply ask that you voluntarily provide such Registration Information.
- When you contact us (for example, to inquire about our Services), we collect whatever personal data you provide us, such as name, telephone number and email address, as well as the question or issue you raised (collectively, "Contact Information").
- When you upload any Content via the Service. The Service may allow you to post or upload Content to the cloud. In such cases, we will collect that Content. An example of this might be the profile photo for your Service account, place of residence etc.
When you use the App, some information about your device and your user behaviour may be processed automatically. This information is generally non-personal, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our App and giving our users the best experience. Otherwise we may not be able to provide you with all the requested services and features of the App. Examples of such information:
- «App usage data» – we may collect anonymous app launches data, the sessions frequency and duration, passing levels, making purchases, failures and other events while using the Services. Such statistics contribute to the Services improvement, hereby making it more interesting and fun. The events are collected while using one or more of such services including such as AppsFlyer, Facebook Analytics, Google Analytics.
- «Technical Data» such as IP Address, your device's operating system, browser type, language, location, hardware type and reference site address, mobile network information, device storage information.
- «Identity Data» such as your unique device ID (persistent/non-persistent), IDFA (Identifier for advertisers).
We do not and will not process any special categories of Personal Data.
We may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases we may use anonymous information without further notice to you since such information is not considered as Personal Data and cannot be connected with you.
Processing information through automatic data processing technologies we use starts automatically when you start using the App.
3. How we use Personal Data
Purpose of User's personal data processing: fulfillment of the provisions of the Terms of Service concluded between the User and the Gototop, LTD, provision of the User's complete access to the services provided by the Gototop, LTD. We process Personal Data when needed to provide our Services and for our operational purposes as described in this Policy. We will not use the information we collect for any purpose other than those disclosed in this Policy. We will process your Personal Data based on the legal basis. For example, we may use the Personal Data in the following ways:
- Account setup and administration: We use Registration information and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
- Personalization: We use Personal Data to personalize your experience with our Services. Some of our Services will ask you to share your geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online. For example, we may ask for age verification if we reasonable doubts regarding your age.
- Making our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.
- Providing you with interest-based (behavioural) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
- To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
- Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information that is processed automatically to better understand user behaviour and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
- Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.
- Send you push notifications, related information, including confirmations and reminders (if you choose to allow that function)—only for users 18 years old or older and you can independently disable this anytime.
- We may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed.
We do not share personal information with other third parties, including people or companies, except when we have your permission and paragraph 4. We will not rent or sell or disclose your personally identifiable information to others. We will use and process you Personal Data only in such cases if you give us your consent or we have legal obligations.
4. Data Processing Our Services may collect non-personal data using integrated third-party services for achievements, leaderboards and cloud saves such as Apple iCloud and Gamecenter, Google Play services. Such data are stored in these third-party services. We do not store personal data on our servers. These services have their own privacy policies.
We share your Personal Data with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in the optimal way, such as serving you personalized, relevant advertisements within the Service.
Gototop, LTD hereby undertakes not to conduct any disclosure or transfer of the User's personal data to any third parties, except Processors, mentioned in this paragraph, without receipt of personal consent of the User.
Gototop, LTD uses the safety measures for ensuring the confidentiality of the User's personal information as well as for protection of the User's personal information from loss, theft, unauthorized access, misuse, amendment or destruction.
The following companies are the Processors of the Personal Data of the Services of Gototop, LTD (In case you want to learn more about the services and privacy options please consult their websites and privacy policies):
You should know that we don't process payments directly, payments processed via Apple App Store (Apple Inc.,
https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google LLC,
https://policies.google.com/privacy). We don't collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform.
The User hereby freely gives, specific, informed and unambiguous consent to the processing of the personal data relating to him or her and mentioned above for the purposes of personal data processing indicated hereto.
We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located outside Cyprus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Cyprus and process it there. This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
5. How Long We Keep Personal Information We will keep your Personal Information for the length of time required to provide you with the Service and for the reasons described in this privacy policy, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide. In all cases, Gototop, LTD does not retain such data for more than 13 months. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account. Data retention periods for other Processors are indicated by the links above.
6. Personal Data Protection The security of your information is fundamental to us. We have implemented industry standard security measures, which include the encryption to protect your personal information, including all information you input into your habit data or share in Services, and this information is not available to third parties.
7. User's Rights It's important to remember that the User has the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of the Gototop, LTD via its Support service, i.e. by sending an e-mail to the address habio.app@support-team.app with the topic «Consent withdrawal» or in the Settings menu of the application.
The User is also entitled to:
- request the access to and rectification or erasure of personal data processed by the Gototop, LTD;
- restrict the processing of personal data concerning the User;
- object to processing of personal data concerning the User;
- demand for realization of the right to data portability from the LTD «Gototop»;
- exercise the right to lodge a complaint with a relevant supervisory authority;
- update Personal Data provided to us;
- Right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on "Limit Ad Tracking". On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing "Opt out of Ads Personalization".
- The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.
Please be aware when your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the paragraph 4 of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options. Please note that you can opt-out of marketing tracking by emailing the developer account.
8. Our Policy Towards Children Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents' prior permission.
We consider a user to be a child if they are under the age of 18, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age.
If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.
9. Specific Provisions Applicable Under California Privacy Law This is additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 ("CCPA"). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.
California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months: