PRIVACY POLICY

This Privacy Policy explains what personal data is collected when you use Sphinx - Live Trivia Game mobile application (the "Application", "Service"), how such personal data will be used, shared, and how you can control it.

If you disagree with the practices described in this Privacy Policy, you should take the necessary steps to delete your account following the setting in Application, if registered, and remove Application from your device.

BY USING THE SERVICE, YOU HEREBY WARRANT AND REPRESENT THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, (II) YOU ARE OF LEGAL AGE AS ESTABLISHED BY YOUR RESPECTIVE STATE OR COUNTRY OF RESIDENCE. Under no circumstance persons under the age of 17 may use the Service.

For this Privacy Policy "GDPR" shall mean the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Unless otherwise specified, all references made within this Privacy Policy to the European Union (EU) include all current member states to the European Union and the European Economic Area.

Atom Operations Limited, 116 Main Street, P.O. Box 3324, Road Town, Tortola, British Virgin Islands, is the Data Controller of the personal information we hold about you.

1. TERMS AND DEFINITIONS

    1. "Application" means Sphinx - Live Trivia Game, a trivia game application, that is also the means by which the Personal Data of the User is collected and processed.
    2. "Data Controller" (or "Owner") means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Application. The Data Controller, unless otherwise specified, is the Owner of the Application.
    3. "Data Processor" means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
    4. "Data Subject" means the natural person to whom the Personal Data refers.
    5. "Personal Data" (or "Data") means any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.
    6. "Usage Data" means information collected automatically through the Application (or third-party services employed in the Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
    7. "User" means the individual using the Application who, unless otherwise specified, coincides with the Data Subject.
    8. "Service" means the service provided by the Application as described in it and in the relative terms (if available).

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

    1. We collect personal information that you voluntarily submit directly to us when you use our Service. This is information when you register an account and user profile, fill in a form on our Service, create or edit your user profile on the Service, correspond with us by phone, SMS, e-mail or otherwise, respond to trivia questions, post comments using the chat function on our Service (if available), or use some other features of our Service. We may also collect your personal information from third parties, such as social networks, if you allow us so.
    2. We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
    3. The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.
    4. We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service. The table at Annex 2  sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
    5. We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
    6. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.
    7. We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

3. RECIPIENTS OF PERSONAL INFORMATION

    1. We may share your personal information with the following parties (as required in accordance with the uses set out in Annexes 1 and 2):
    2. The updated list of these parties may be requested from the Owner at any time.

4. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

    1. In accordance with applicable privacy laws, you have the following rights in respect of your personal information that we hold:
    2. If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal information you have submitted to us by logging into your account on the app.
    3. You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .

5. DATA TRANSFER OUTSIDE THE EU. DATA SECURITY

    1. The Owner may transfer Personal Data to Data Processors around the world in accordance with this privacy policy. Personal Data collected by the Owner will be transferred to the United States, Israel and Ukraine for the purposes as described in this privacy policy. These data transfers are necessary to provide the Service to the User.
    2. The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below:
    3. Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable laws and this privacy policy.

6. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

    1. The Application may send push notifications to the specific User.
    2. Legal action. The User's Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of the Application or the related Service. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
    3. System logs and maintenance. For operation and maintenance purposes, the Application and any third-party services may collect files that record interaction with the Application (system logs) use other Personal Data (such as the IP address) for this purpose.
    4. How "Do Not Track" requests are handled. The Application does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
    5. Changes to this privacy policy. The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within the Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. If a User objects to any of the changes to the policy, the User must cease using the Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.

7. CONTACTING US

Please contact us at support@sphinxtrivia.com if you have any questions, comments and requests regarding this Privacy Policy.

  

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

Category of personal information

How we may use it

Legal basis for the processing

Contact information such as your name, phone number, address and e-mail address.

We may use this information for account authentication.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We may use this information to communicate with you, including sending service-related communications, such as notifying you when you have won a quiz.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to deal with enquiries and complaints made by or about you relating to the Service.

The processing is necessary for our legitimate interests, namely administering the Service, and for communicating with you effectively to respond to your queries or complaints.

Profile information, such as your username, profile picture and other users you have invited to use our Service.

We use this information to operate, maintain and provide to you the features and functionality of the Service.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to promote our Service, such as inviting new users to our Service or tagging you in comments on our social media pages.

The processing is necessary for our legitimate interests, namely promoting our Service.

Chat, comments and opinions.  When you contact us directly, e.g. by email, phone, or when you participate in a chat on our Service (if available), we will record your comments and opinions.

We use this information to operate, maintain and provide to you the features and functionality of the Service.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to address your questions, issues and concerns.

The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We use this information to develop new products and features available through our Service or otherwise improve our Service.

The processing is necessary for our legitimate interests, namely developing and improving our Service.

Information  about your use of our Service , such as the number of games you have participated in on our Service, your replies to the trivia questions on our Service and the number of your wins, your balance of virtual goods purchased within the Service

We use this information to operate, maintain and provide to you the features and functionality of the Service.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to develop new products and features available through our Service or otherwise improve our Service.

The processing is necessary for our legitimate interests, namely developing and improving our Service or certain features of our Service.

Address book contacts . Where you give us permission to do so, we may collect the phone numbers and names of the contacts on your device.

We use this information to connect you with people in your address book that are using our Service and to allow you to invite other people in your address book to our Service.

We will only process this information to the extent you have given us consent to do so.

Information received from third parties, such as social networks. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.

We use this information to allow you to log in to the Service.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

We use this information to tailor how the Service is presented to you.

The processing is necessary for our legitimate interests, namely tailoring our Service to the user.

We use this information to promote our Service, such as tagging you in comments on our social media pages.

The processing is necessary for our legitimate interests, namely promoting our Service.

Precise location information . When you use certain functionalities of the Service, we may ask you to provide your precise location.

We use this information to provide you certain functionalities of the Service, such as the ability to interact with people using our Service near you.

We will only process this information to the extent you have given us consent to do so.

Approximate location information . Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.

We use information you provide to us about your location to inform and plan our marketing strategy.

The processing is necessary for our legitimate interest, namely informing our direct marketing strategy.

All personal information set out above.

We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve our Service and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to administer and improve the Service.

 

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information

How we use it

Legal basis for the processing

Information about how you access and use the Service . For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service.

We use information about how you use and connect to our Service to present our Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Service to the user.

We use this information to determine products and services that may be of interest to you for marketing purposes

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.

Log files and information about your device . We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

We use information about how you use and connect to our Service to present our Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Service to the user.

We use this information to determine products and services that may be of interest to you for marketing purposes

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.

Last updated: July 20, 2018