Privacy Policy

 

Welcome to EPRA GAMES!

 

We provide, hereafter, in a clear, simplified and accessible way, the practices related to the collection, form of use, storage, treatment, processing, sharing and transfer of personal data that occur as a result of accessing and using our game, owned by EPRA GAMES PRODUCTIONS LTDA. (“EPRA GAMES”), a limited liability company, registered with the CNPJ/MF (National Registry of Legal Entities) under No. 43.149.597/0001-43.

 

EPRA GAMES practices regarding data processing, as well as this Privacy Policy, are adequate to the requirements contained in Law No. 10.406/2002 (Brazilian Civil Code), Law No. 12.965/2014 (Brazilian Civil Rights Framework for the Internet), Law No. 13.709 /2018 (General Personal Data Protection Law) and in other applicable legislation.

 

Hereafter, YOU (“USER”) can see how your personal data is processed when it’s inserted into our game.

 

Personal data processing or processing is understood to mean any operation carried out with the information collected, including operations related to the production, reception, classification, use, access, transmission, distribution, archiving, storage, elimination, evaluation or control of information, modification , communication, transfer, broadcast or extraction by our game.

 

Please be advised that YOU may refuse to consent to this Policy, however in this case we will not be able to provide YOU our services in relation to the Game. Otherwise, by continuing to use the Platform’s features, YOU will be aware of and in accordance with our data protection practices in these terms.

 

1. How is your personal data collected and what types of personal data are collected?

 

All data collected or provided directly by the holder of personal data are treated as confidential, and we will only use them for the purposes described herein and/or authorized by you.

 

To learn more about the personal data collected and their respective purposes, see the table below.

 

Source	Type of Data Collected	Goal	Legal Grounds
Platform Acquisition	Registration Data and bank details: Name, email and/or cell phone, bank details (the latter exclusively  used by Google)	Sale: allow the sale on the Platform (Google Exclusive).   Marketing: Sending notification about EPRA GAMES games and communication about the Platform (The latter is Google’s responsibility).	Agreement
Use of Features	Registration data (name, email, phone), region and age	Statistics: Demographic inferences for targeted advertising campaigns.	Agreement

 

It is the USER’s responsibility to keep their personal information up to date. Whenever there is a change in the USER’s data, this fact must be promptly changed by the USER through the Game. EPRA GAMES is not responsible for the veracity of the data provided by the USER, who is solely responsible for the accuracy of the information.

 

2. With whom does EPRA GAMES share your personal data?

 

Sometimes we need to share your personal data with third parties who provide services on our behalf, mainly in the use of auxiliary services to the operation of the Game.

 

We describe below some situations in which we may share your personal data and, whenever possible, we will do so anonymously.

 

Partners and Suppliers: EPRA GAMES may share Personal Data it collects from the game with its partners and/or suppliers.

 

If YOU have any questions regarding who our suppliers and partners are, please contact our contact channel below.

 

Public Authorities. We will comply with the law. So, if a judge or authority with legal competence requires EPRA GAMES to share certain personal data for, for example, an investigation, we will share it. We are against any abuse of authority and, if EPRA GAMES understands that a certain order is abusive, we will always defend the privacy of the holders.

 

Rights protection. In addition, we reserve the right to share any personal data that we believe to be necessary to comply with a legal obligation, enforce our terms of use, or protect the rights of EPRA GAMES and our employees.

 

3. What are your rights as a personal data holder?

 

Personal data is yours and Brazilian law guarantees that YOU have a series of rights related to them. We are committed to fulfilling these rights and, in this section, we will explain how YOU can exercise them with EPRA GAMES. Brazilian law grants YOU the following rights:

 

Confirmation and Access	Allows YOU to verify whether EPRA GAMES processes your personal data and, if so, request a copy of the personal data we hold about YOU.
Adjustment	Allows YOU to request the adjustment of incomplete, inaccurate or outdated personal data.
Anonymization, blocking or deletion	Allows YOU to ask us to (a) anonymize your data so that it can no longer be related to YOU and therefore ceases to be personal data; (b) block your data, temporarily suspending your ability to process it; and (c) delete your data, in which case we will delete all your data without the possibility of reversal, except in cases as provided by law.
Portability	YOU have the right to request, upon express request, that EPRA GAMES provide YOU, or to a third party chosen by YOU, your personal data in a structured and interoperable format, for transfer to another provider, as long as it does not violate the intellectual property or company’s business secret.
Deletion	When we process your Personal Data on the basis of your consent, YOU may request the deletion of the data.
Information about sharing	YOU have the right to know the public and private entities with which EPRA GAMES makes shared use of data. In any case, if YOU have questions or want more details, YOU have the right to ask us for this information.
Information about the possibility of not agreeing	Allows YOU to have clear and complete information about the possibility and consequences of not providing consent. Your agreement, when necessary, must be free and informed. Therefore, whenever we ask for your agreement, YOU are free to deny it – although in such cases we may have to limit our deliveries to YOU.
Withdrawal of Agreement	YOU have the right to withdraw your agreement in relation to processing activities that are based on consent. However, this will not affect the legality of any processing carried out previously. If YOU withdraw your agreement, we may not be able to provide certain deliveries to YOU, but we will notify YOU when this happens.
Objection	The law authorizes the processing of personal data even without your consent. If YOU do not agree with this treatment, in some cases, YOU may object to it, requesting the interruption.

 

 

Whenever YOU exercise your rights, EPRA GAMES may request some additional information for the purpose of proving your identity, seeking to prevent fraud. We do this to ensure your security and privacy. Also, some requests may not be responded to immediately, but EPRA GAMES is committed to responding to all requests within a reasonable time and always in compliance with applicable legislation.

 

In some cases, WE may have legitimate reasons for failing to comply with a request to exercise rights. These situations include, for example, cases where a disclosure of specific information could violate the intellectual property rights or trade secrets of EPRA GAMES or third parties, as well as cases where requests for data deletion cannot be fulfilled due to the existence of EPRA GAMES’ obligation to retain data, whether to comply with legal or regulatory obligations or to enable EPRA GAMES or third parties to defend themselves in disputes of any kind.

 

 

4. How long will personal data be stored?

 

WE will keep the personal data of EPRA GAMES’ USERS only for as long as it is necessary to fulfill the purposes for which WE collected them, including for the purposes of complying with any legal, contractual, accountability or request from competent authorities.

 

All data collected will be deleted from our servers when the USER so requests or when they are no longer necessary or relevant for the Game, unless there is any other reason for their maintenance, such as a possible legal obligation to retain data, or the need to preservation of these to protect the rights of EPRA GAMES.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm arising from unauthorized use or disclosure of your personal data, the purpose of processing your data and whether we can achieve such purposes through other means, and applicable legal requirements.

 

5. Cookie Policy

 

EPRA GAMES will collect from the USER through access to the game, through cookies and other network technologies, some files or information that may be stored on your computer and/or mobile device.

 

By accessing the game, the USER authorizes the use of cookies in accordance with this Policy. If YOU do not agree that cookies are used in this way, YOU must adjust your browser settings to not allow their use. Disabling the cookies used may make accessing the game less functional, but should not prevent it from working properly.

 

Type of cookies used: The type of cookies that EPRA GAMES uses are Session Cookies. Session Cookies are temporary cookies that will remain in the cookie file in the app until the USER uninstalls it. The information obtained by these cookies is used to analyze gameplay patterns, allowing us to identify problems and provide a better USER experience.

 

6. How Information Security works at EPRA GAMES

 

EPRA GAMES takes all technical and organizational measures to protect Game USERS’ personal data against loss, unauthorized use or other abuse. Data will be stored in a secure operating environment that is not accessible to the public.

 

We strive to protect the privacy of the personal data we store, but unfortunately we cannot guarantee complete security. Unauthorized use of accounts, hardware or software failure and other factors can compromise the security of your personal data at any time, so please help us maintain a safe environment for everyone. In addition to adopting good security practices in relation to their personal data, if the USER identifies or becomes aware of something that compromises the security of personal data, contact the service channels below.

 

7. International Transfer

 

Some of our suppliers may have their servers located outside Brazil, so that, for example, for us to store your data, we need to transfer it to other countries. These transfers only involve companies that demonstrate compliance or are in the process of compliance with applicable data protection laws, and maintain a similar or more stringent level of compliance than provided for in applicable Brazilian legislation.

 

EPRA GAMES’ headquarters is in Brazil and the data we collect is governed by Brazilian law. By accessing our game, the USER agrees to the processing and transfer of such data to Brazil and eventually to other countries in which possible future companies of the same economic group as EPRA GAMES are headquartered. The personal data of Game USERS, when transferred to these countries, may be subject to local legislation and relevant rules.

 

8. How to talk to us

 

If YOU believe that your personal information has been used in a way that is incompatible with this Policy or with your choices as a data holder, or if YOU have other questions, comments or suggestions related to this Policy, YOU can contact our team through our game, in the CONTACT tab.

 

We have a person in charge (“DPO”) who is available at the following contact addresses:

Person in Charge: Tony Ribeiro Sá
Mailing Address: Rua Arthur de Azevedo Machado, 1459, International Trade Center – Costa Azul – Salvador – BA – CEP 41.770-790
Contact email: tony.ribeiro@sgnsistemas.com.br

 

9. Policies Update 

As we are always aiming at improving our game, this Policy may be updated in order to provide more security to the USER, convenience and increasingly improve their experience. That is why we recommend that the USER access our Policy periodically, so that they are aware of the changes. To make it easier, we indicate at the end of the document the date of the last update. If relevant changes are made that require new USER authorizations, we will publish this update and request a new consent.

 

Last update: March 25st, 2022.

 

Versions History: 1st Revision October 15th, 2021.