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PRIVACY POLICY

PRIVACY POLICY

Garvin SW and/or its affiliates (“Garvin SW,” “we,” or “us”) respects the privacy of everyone that uses our websites, games, and various related services. This privacy policy is designed to inform you about the type of information that we gather about you, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of that information.

Garvin SW is dedicated to transparency, data privacy, and security, and follows the strict regulations required by the CCPA (California Consumer Privacy Act), LGPD (Lei Geral de Proteção de Dados) and GDPR (General Data Protection Regulation), as detailed in this privacy policy.

This Privacy Policy applies to Garvin SW websites and related services, which we here collectively call the Service. We may periodically update this Privacy Policy by posting a new version. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

1. What kind of data do we collect from you?

1-1. Data you provide us

  • Contact information (such as name, email address, etc.)
  • User name and password
  • Profile information (such as profile photo)
  • Your messages to the Service (such as chat logs and support tickets)
  • Other data you choose to give us (such as data to identify a lost account)

1-2. Data we collect automatically

  • Data about your account and game progress
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
  • Data about your device, such as device name and OS, browser type and language
  • Data we collect with cookies and similar technologies
  • General location data
  • Precise geo-location data (GPS, with your consent)
  • Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

1-3. Data we collect from 3rd parties

  • Data we receive if you link a third-party tool with the Service (such as Facebook, Google etc.)
  • Demographic data (such as to determine the coarse location of your IP address)
  • Data to fight fraud (such as refund abuse in games or click fraud in advertising)
  • Data from platforms that the games run on (such as to verify payment)
  • Data for advertising and analytics purposes, so we can provide you a better Service

2. Why do we collect your data?

2-1. To make the Service work

To perform the contract, we process data necessary to:

  • Create accounts and allow you to play our games and use our Service
  • Operate the Service
  • Verify and confirm payments
  • Provide and deliver products and services you request
  • Send you Service-related communications

2-2. To make the Service more suitable for our players

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to:

  • Update and develop player profiles
  • Develop and improve the Service and player experience
  • Manage our relationship with you
  • Provide social features as part of the Service
  • Customize your Service experience
  • Respond to your comments and questions and provide player support
  • Provide you Garvin SW offers in the Service as well as in other websites and services, and by email
  • Send you related information, such as updates, security alerts, and support messages
  • Enable you to communicate with other players

2-3. To show personalized advertisements

To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to:

  • Track the content you access in connection with the Service and your online behavior
  • Deliver, target and improve our advertising and the Service

(For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.)

2-4. To keep the Service safe and fair

Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the Garvin SW Terms of Service. In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

  • Analyze and monitor use of the Service
  • Moderate chats either automatically or manually
  • Take action against fraudulent or misbehaving players

2-5. To analyze, profile, and segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

3. Who do we share your data with?

Apart from Garvin SW, your data can be accessed by others in the following situations:

3-1. Other Players and Users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

3-2. Partners Working for Garvin SW

Garvin SW has partners to perform services for us. These partners process your data only at and according to Garvin SW´s instructions to provide the Service, such as hosting, player support, analytics and fraud prevention.

  • Other companies and public authorities: In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
  • Advertising and Social Media partners: The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
  • Business Transfer: In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personally identifiable information, generally is one of the transferred business assets. In the event that Garvin SW undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy. We will not sell or rent your information to any third party outside of these circumstances.

4. Privacy Policies of Third-Party Sites

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties.

Some parts of our Services are provided by a third-party Service Providers, who may collect and record information about your use of our Services. Additionally, other companies that place advertisements on our Websites, Games and/or Applications may collect information about you when you view or click on their advertising through the use of cookies. We cannot control the activities of such third parties and cannot guarantee that they will adhere to the privacy and security practices same or similar to ours. You should contact them directly if you have any questions about their use of the information that they collect.

5. Cookies and Tracking Technologies

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly. By accessing our Websites or using our Services you consent to our use of cookies in accordance with this Privacy Policy.

We use cookies and similar technologies to facilitate and customize your use of our Services. A cookie is a small data file, which we store on your computer or mobile device that can later be retrieved to identify you to us. We may use cookies and similar technologies, among other things, to:

  1. Allow us to recognize you and your device.
  2. Allow our Services to interact with a third-party social network or platform.
  3. Allow our payment processors to process your payment instructions.
  4. Provide you with more customized Services.
  5. Obtain data which will allow us to understand how people are using our Services so that we can improve them.

6. How do we protect your data?

Security Safeguards: The security of your personal information is important to us. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. Although we take appropriate measures to safeguard against unauthorized disclosure or access of your information, no security measure is perfect. Thus, we cannot guarantee the security of your information. You hereby agree to use our Services at your own risk. We do not assume any responsibility for the unauthorized use or access of your information under our control.

7. Data Storage and Retention

Your personal information may be transferred to, and stored at, a destination outside of your country or jurisdiction, including but not limited to our data center in United States of America. It may also be processed by personnel of our affiliates and third-party service provider who may operate outside of your country or jurisdiction. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.

By using our Services, you consent to your personal information being transferred to recipients in other countries and being stored and processed in the servers located in other countries.

We retain your data for as long as your account is active or as needed to provide you the Service. We may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

8. Your Rights and Options

  • Marketing Preferences: You have the right to ask us not to use your personal information for marketing purposes. To change your marketing preferences, or to unsubscribe, please contact us at Customer Center in our Services.
  • Cookie Preferences: You have choices with respect to cookies. By modifying your browser preferences, you can choose to accept all cookies, to be notified when a cookie is set, or to reject all cookies.
  • Social Media Settings: You can make changes to what data a third-party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third-party provider.
  • Accessing and Deleting Data: If you request, we will provide you a copy of your personal data in an electronic format. You may request to delete your account by logging in to the account that you wish to delete and going to the Customer Support menu to submit your request. We may ask you for certain personal information to confirm your identity before processing your request. Please note that we may not be able to delete your information in some cases (e.g., shared social data, aggregate form data, or data necessary to comply with legal obligations).
  • Your Other Rights: You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

9. International Transfer

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.

10. California Privacy Rights

California residents have the right to receive (a) information identifying any third party company to whom Garvin SW may have disclosed (within the previous calendar year) his/her personal information for that company’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, please send a request email to zninh.ngo@gmail.com.

10-1. "Do not sell my personal information"

California residents have the right to request information identifying any third party to whom Garvin SW may have disclosed user's personal information for that third party’s direct marketing purposes within the past year. If you are a California resident and to request such information, you may contact us at zninh.ngo@gmail.com. We are only required to respond to one request per user each year.

10-2. Privacy Rights for California Minors

California residents under the age of 18 have the right to request removal of any content or information that they have publicly posted within our services. Your request should include a detailed description of the specific content or information to be removed. Please be aware that the removal of your information or content doesn't guarantee complete or comprehensive removal, and copies may remain on our servers.

11. EU Data Protection Rights

The personal information of users in the EU domain is only collected to the minimum required to execute the game and provide service contracts. Other information is collected with the consent of the information subject. You have the right to oppose the way of personal information processing provided by Garvin SW, or to request a transfer to wherever you want, if technically possible. Residents of EU Member States may contact zinh.ngo@gmail.com for any unreasonable treatment that exceeds the time limit required by law, and you can request judicial relief to the authorities.

For information collected under this Privacy Policy, the data controller is Garvin SW. Our Data Protection Officer can be contacted at: zninh.ngo@gmail.com.

12. Contact Us

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly.

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