PRIVACY POLICY
1. INTRODUCTION
1.1 Welcome to the Studio Dois
website run by Studio Dois Private Limited and its
affiliates and related corporations (individually and collectively, "Studio
Dois", "we", "us" or
"our"). Studio Dois takes its
responsibilities under applicable privacy laws and regulations ("Privacy
Laws") seriously and is committed to respecting the privacy rights and
concerns of all users of our Studio Dois games
(“Games”) and website (the "Site") (we refer to the Games, Site and
the services we provide collectively as the "Services"). We recognize
the importance of the personal data you have entrusted to us and believe that
it is our responsibility to properly manage, protect and process your personal
data. This policy (“Privacy Policy”) is designed to assist you in understanding
how we collect, use, disclose and/or process the personal data you have
provided to us and/or possess about you, whether now or in the future, as well
as to assist you in making an informed decision before providing us with any of
your personal data. This Privacy Policy is also designed to assist our
users who live in the European Union (the “EU”) to understand their applicable
data privacy rights that exist under the EU's General Data Protection
Regulation when they use the Services.
1.2 "Personal Data" or "personal
data" means data, whether true or not, about an individual who can be
identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common
examples of personal data could include name, identification number and contact
information.
1.3 By using the Services, registering for an
account with us or visiting our Site, you acknowledge and agree that you accept
the practices, requirements, and/or policies outlined in this Privacy Policy,
and you hereby consent to us collecting, using, disclosing and/or processing
your personal data as described herein.
1.4 IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR
PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR
SERVICES OR ACCESS OUR GAMES OR SITE. If we change our Privacy Policy, we will
post those changes or the amended Privacy Policy on the Site. We reserve the
right to amend this Privacy Policy at any time.
2. WHEN WILL STUDIO DOIS COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about
you:
• when you register and/or use our Services, Games
or Site, or open an account with us;
• when you submit any form, including, but not limited
to, application forms or other forms relating to any of our products and
services, whether online or by way of a physical form;
• when you enter into any agreement or provide other
documentation or information in respect of your interactions with us, or when
you use our products and services;
• when you interact with us, such as via telephone
calls (which may be recorded), letters, fax, face-to-face meetings, social
media platforms and emails;
• when you use our electronic services,
or interact with us via our Games or Site or use our Services. This
includes, without limitation, through cookies which we may deploy when you
interact with our Games or Site;
• when you carry out transactions through our Games
or Site;
• when you provide us with feedback or complaints;
• when you register for a contest, for games or game
specific events;
• during your gameplay; and
• when you submit your personal data to us for any
reason.
The above does not purport to be exhaustive and sets out
some common instances of when personal data about you may be collected.
3. WHAT PERSONAL DATA WILL STUDIO DOIS COLLECT?
3.1 The personal data that Studio Dois may collect includes but is not limited to:
• name;
• email address;
• date of birth;
• billing address;
• bank account and payment information;
• telephone number;
• gender;
• information sent by or associated with the
device(s) used to access our Services;
• any other information about the user when the user
signs up to use our Services, and when the user uses the Services, as well as
information related to how the user uses our Services; and
• aggregate data on content the user engages with.
3.2 You agree not to submit any information to us
which is inaccurate or misleading, and you agree to inform us of any inacuracies or changes to such information. We reserve the
right at our sole discretion to require further documentation to verify the
information provided by you.
3.3 If you sign up to be a user of our Services
using your social media account (“Social Media Account”), link your account to
your Social Media Account or use any Studio Dois
social media features, we may access information about you which you have
voluntarily provided to your Social Media Account provider in accordance with
such provider's policies, and we will manage and use such personal data in
accordance with this Policy at all times.
3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at
any time by notifying our Data Protection Officer in writing. Further
information on opting out can be found in the section below entitled "How
can you withdraw consent, remove, request access to or modify information you
have provided to us?". Note, however, that opting out or withdrawing your
consent for us to collect, use or process your personal data may affect your
use of the Services. For example, opting out of the collection of location
information will cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 As with most websites and mobile applications, your
device sends information which may include data about you that gets logged by a
web server when you use our Services. This typically includes without
limitation your device’s Internet Protocol (IP) address, computer/mobile device
operating system and browser type, type of mobile device, the characteristics
of the mobile device, the unique device identifier (UDID) or mobile equipment
identifier (MEID) for your mobile device, the address of a referring web site
(if any), the pages you visit on our website and mobile applications and the
times of visit, and sometimes a "cookie" (which can be disabled using
your browser preferences) to help the site remember your last visit. If you are
logged in, this information is associated with your personal account. The
information is also included in anonymous statistics to allow us to understand
how visitors use our Games and Site.
4.2 Our mobile applications may collect precise
information about the location of your mobile device using technologies such as
GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for
one or more purposes including, without limitation, location-based services
that you request or to deliver relevant content to you based on your location
or to allow you to share your location to other Users as part of the services
under our mobile applications. For most mobile devices, you are
able to withdraw your permission for us to acquire this information on
your location through your device settings. If you have questions about how to
disable your mobile device's location services, please contact your mobile
device service provider or the device manufacturer.
5. COOKIES
5.1 We may from time to time implement
"cookies" or other features to allow us or third parties to collect
or share information that will help us improve our Site, Games and the Services
we offer, or help us offer new services and features. “Cookies” are identifiers
we transfer to your computer or mobile device that allow us to recognize your
computer or device and tell us how and when the Services or website are used or
visited, by how many people and to track activity within our Site and Games. We
may link cookie information to personal data. Cookies also link to information
regarding what items you have selected for purchase pages you have viewed, or
games you have played. This information is used to keep track of your shopping
cart, for example. Cookies are also used to deliver content specific to your
interest and to monitor usage of the Services.
5.2 You may refuse the use of cookies by selecting
the appropriate settings on your browser. However, please note that if you do
this you may not be able to use the full functionality of our Site, Games or
the Services.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
6.1 We may collect, use, disclose and/or process
your personal data for one or more of the following purposes:
(a) to consider and/or process your
application/transaction with us or your transactions or communications with
third parties via the Services;
(b) to manage, operate, provide and/or administer
your use of and/or access to our Services, Site and Games (including, without
limitation, your preferences), as well as your relationship and user account
with us;
(c) to respond to, process, deal with or complete a
transaction and/or to fulfil your requests for certain products and services
and notify you of service issues and unusual account actions;
(d) to enforce our Terms of Service or any
applicable end user license agreements;
(e) to protect personal safety and the rights,
property or safety of others;
(f) for identification and/or verification;
(g) to maintain and administer any software updates
and/or other updates and support that may be required from time to time to
ensure the smooth running of our Services;
(h) to deal with or facilitate customer service,
carry out your instructions, deal with or respond to any enquiries given by (or
purported to be given by) you or on your behalf;
(i) to contact you or
communicate with you via voice call, text message and/or fax message, email
and/or postal mail or otherwise for the purposes of administering and/or
managing your relationship with us or your use of our Services, such as but not
limited to communicating administrative information to you relating to our
Services. You acknowledge and agree that such communication by us could be by
way of the mailing of correspondence, documents or notices to you, which could
involve disclosure of certain personal data about you to bring about delivery
of the same as well as on the external cover of envelopes/mail packages;
(j) to inform you when another user has sent you a
private message or posted a comment for you on the Games or Site;
(k) to conduct research, analysis and development
activities (including, but not limited to, data analytics, surveys, product and
service development and/or profiling), to analyse how
you use our Services, to improve our Services or products and/or to enhance
your customer experience;
(l) to allow for advertising and other audits and
surveys to, among other things, validate the size and composition of our target
audience, and understand their experience with Studio Dois’s
Services;
(m) for marketing and, in this regard, to send you
by various modes of communication marketing and promotional information and
materials relating to products and/or services (including, without limitation,
products and/or services of third parties whom Studio Dois
may collaborate or tie up with) that Studio Dois (and/or
its affiliates or related corporations) may be selling, marketing or promoting,
whether such products or services exist now or are created in the future. You
can unsubscribe from receiving marketing information at any time by using the
unsubscribe function within the electronic marketing material. We may use your
contact information to send newsletters from us and from our related companies;
(n) to respond to legal processes or to comply with
or as required by any applicable law, governmental or regulatory requirements
of any relevant jurisdiction, including, without limitation, meeting the
requirements to make disclosure under the requirements of any law binding on Studio
Dois or on its related corporations or affiliates;
(o) to produce statistics and research for internal
and statutory reporting and/or record-keeping requirements;
(p) to carry out due diligence or other screening
activities (including, without limitation, background checks) in accordance
with legal or regulatory obligations or our risk management procedures that may
be required by law or that may have been put in place by us;
(q) to audit our Services or Studio Dois's business;
(r) to prevent or investigate any fraud, unlawful
activity, omission or misconduct, whether relating to your use of our Services
or any other matter arising from your relationship with us, and whether or not
there is any suspicion of the aforementioned;
(s) to store, host, back up (whether for disaster
recovery or otherwise) of your personal data, whether within or outside of your
jurisdiction;
(t) to deal with and/or facilitate a business asset
transaction or a potential business asset transaction, where such transaction
involves Studio Dois as a participant or involves
only a related corporation or affiliate of Studio Dois
as a participant or involves Studio Dois and/or any
one or more of Studio Dois's related corporations or
affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A
“business asset transaction” refers to the purchase, sale, lease, merger,
amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation
or of any of the business or assets of an organisation;
and/or
(u) any other purposes which we notify you of at the
time of obtaining your consent.
(collectively, the “Purposes”).
6.2 As the purposes for which we will/may collect,
use, disclose or process your personal data depend on the circumstances at
hand, such purpose may not appear above. However, we will notify you of such
other purpose at the time of obtaining your consent, unless processing of the
applicable data without your consent is permitted by the Privacy Laws.
7. HOW DOES STUDIO DOIS PROTECT CUSTOMER INFORMATION?
7.1 We implement a variety of security measures to
ensure the security of your personal data on our systems. User personal data is
contained behind secured networks and is only accessible by a limited number of
employees who have special access rights to such systems. We will retain
personal data in accordance with the Privacy Laws and/or other applicable laws.
That is, we will destroy or anonymize your personal data when we have
reasonably determined that (i) the purpose for which
that personal data was collected is no longer being served by the retention of
such personal data; (ii) retention is no longer necessary for any legal or
business purposes; and (iii) no other legitimate interest warrant further
retention of such personal data. If you cease using our Services, or your
permission to use the Site, Games and/or the Services is terminated, we may
continue storing, using and/or disclosing your personal data in accordance with
this Privacy Policy and our obligations under the Privacy Laws. Subject to
applicable law, we may securely dispose of your personal data without prior
notice to you.
8. DOES STUDIO DOIS DISCLOSE THE INFORMATION IT COLLECTS FROM ITS
VISITORS TO OUTSIDE PARTIES?
8.1 In conducting our business, we will/may need to
disclose your personal data to our third party service providers, agents and/or
our affiliates or related corporations, and/or other third parties, whether
sited in Singapore or outside of Singapore, for one or more of the above-stated
Purposes. Such third party service providers, agents and/or
affiliates or related corporations and/or other third parties would be
processing your personal data either on our behalf or otherwise, for one or
more of the above-stated Purposes. Such third parties include, without
limitation:
• our subsidiaries, affiliates and related corporations;
• contractors, agents, service providers and other
third parties we use to support our business. These include but are not limited
to those which provide administrative or other services to us such as mailing
houses, telecommunication companies, information technology companies and data centres;
• a buyer or other successor in the event of a
merger, divestiture, restructuring, reorganization, dissolution or other sale
or transfer of some or all of Studio Dois’s assets,
whether as a going concern or as part of bankruptcy, liquidation or similar
proceeding, in which personal data held by Studio Dois
about our users is among the assets transferred; or to a counterparty in a
business asset transaction that Studio Dois or any of
its affiliates or related corporations is involved in; and
• third parties to whom disclosure by us is for one
or more of the Purposes and such third parties would in turn be collecting and
processing your personal data for one or more of the Purposes.
8.2 This may require, among other things, disclosing
your gaming history and/or disclosing records showing which games were viewed
by which IP addresses. We will also share statistical and demographic
information about our users and their use of the Services with suppliers of
advertisements and programming. This would not include anything that could be
used to identify you specifically or to discover individual information about
you.
8.3 Additionally, you may elect to export your user
activity feeds as RSS feeds which may be subscribed to by other users, which
may include information regarding your game play, installation of games,
connections with other users and other information about your account activity
which is published as a feed on the Site or Games.
8.4 For the avoidance of doubt, in the event that
Privacy Laws or other applicable laws permit an organisation
such as us to collect, use or disclose your personal data without your consent,
such permission granted by the laws shall continue to apply.
8.5 Third parties may unlawfully intercept
or access personal data transmitted to or contained on the site, technologies
may malfunction or not work as anticipated, or someone might access, abuse or
misuse information through no fault of ours. We will nevertheless deploy
reasonable security arrangements to protect your personal data as required by
the Privacy Laws; however there can inevitably be no guarantee of absolute
security such as but not limited to when unauthorised
disclosure arises from malicious and sophisticated hacking by malcontents
through no fault of ours.
9. INFORMATION ON CHILDREN
9.1 The Services are not intended for children under
the age of 10. We do not knowingly collect or maintain any personal data or
non-personally-identifiable information from anyone
under the age of 10 nor is any part of our Site, Games or other Services
directed to children under the age of 10. We will close any accounts used
exclusively by such children and will remove and/or delete any personal data we
believe was submitted by any child under the age of 10.
10. INFORMATION COLLECTED BY THIRD PARTIES
10.1 Our Site and Games use Google Analytics, a web
analytics service provided by Google, Inc. ("Google"). Google
Analytics uses cookies, which are text files placed on your device, to help the
website analyse how users use our Services. The
information generated by the cookie about your use of the Services or device
(including your IP address) will be transmitted to and stored by Google on
servers in the United States. Google will use this information for the purpose
of evaluating your use of our Services, compiling reports on website activity
for website operators and providing other services relating to website activity
and Internet usage. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process the
information on Google's behalf. Google will not associate your IP address with
any other data held by Google.
10.2 We, and third parties, may from time to time
make software applications downloads available for your use on or through the
Services. These applications may separately access, and allow a third party to
view, your identifiable information, such as your name, your User ID, your device’s
IP Address or other information such as what game you are playing during any
given session, and any cookies that you may previously have installed or that
were installed for you by a third party software application or website.
Additionally, these applications may ask you to provide additional information
directly to third parties. Third party products or services provided through
these applications are not owned or controlled by Studio Dois.
You are encouraged to read the terms and other policies published by such third
parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY
SITES
11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL
DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do
implement a variety of security measures to maintain the safety of your
personal data that is in our possession or under our control. Your personal
data is contained behind secured networks and is only accessible by a limited
number of persons who have special access rights to such systems,
and are required to keep the personal data confidential. When you place
orders or access your personal data, we offer the use of a secure server. All
personal data or sensitive information you supply is encrypted into our databases
to be only accessed as stated above.
11.2 In an attempt to provide you with increased
value, we may choose various third party websites to
link to, and frame within, the Site or Games. We may also participate in
co-branding and other relationships to offer e-commerce and other services and
features to our visitors. These linked sites have separate and independent
privacy policies as well as security arrangements. Even if the third party is
affiliated with us, we have no control over these linked sites, each of which
has separate privacy and data collection practices independent of us. Data
collected by our co-brand partners or third party web
sites (even if offered on or through our Site or Games) may not be received by
us.
11.3 We therefore have no responsibility or
liability for the content, security arrangements (or lack thereof) and
activities of these linked sites. These linked sites are only for your
convenience and you therefore access them at your own risk. Nonetheless, we
seek to protect the integrity of our Site and Games and the links placed upon
each of them and therefore welcome any feedback about these linked sites
(including, without limitation, if a specific link does not work).
12. WILL STUDIO DOIS TRANSFER YOUR INFORMATION OVERSEAS?
12.1 Your personal data and/or information may be
transferred to, stored or processed outside of your country. In most cases,
your personal data will be processed in Singapore, where our servers are located and our central database is operated. Studio Dois will only transfer your information overseas in
accordance with Privacy Laws. More information about the transfer out of
the EU, of personal data and/or information relating to users who are located in the EU, can be found in the section titled
"Additional Provisions for EU Users Only".
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT
INFORMATION YOU HAVE PROVIDED TO US?
Withdrawing Consent
13.1 You may withdraw your consent for the
collection, use and/or disclosure of your personal data in our possession or
under our control by sending an email to our Personal Data Protection Officer
at smallegg.dyy@gmail.com.
13.2 However, your withdrawal of consent may mean
that we will not be able to continue providing the Services to you, and we may
need to terminate your existing relationship and/or the contract you have with
us.
Requesting Access to, or Correction of Personal Data
13.3 If you have an account with us, you may
personally access and/or correct your personal data currently in our possession
or control through the Account Settings page or tab on the Site or Games. If
you do not have an account with us, you may request to access and/or correct
your personal data currently in our possession or control by submitting a
written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of
your request so as to be able to deal with your request. Hence, please submit
your written request by sending an email to our Personal Data Protection
Officer at smallegg.dyy@gmail.com.
13.4 We may charge you a reasonable fee for the
handling and processing of your requests to access your personal data. If we so
choose to charge, we will provide you with a written estimate of the fee we
will be charging. Please note that we are not required to respond to or deal
with your access request unless you have agreed to pay the fee.
13.5 We reserve the right to refuse to correct your
personal data in accordance with the provisions as set out in Privacy Laws,
where they require and/or entitle an organisation to
refuse to correct personal data in stated circumstances.
14. ADDITIONAL PROVISIONS FOR EU USERS ONLY
14.1 The provisions in this Section only apply if
you are a user who is located in the European Union
(“EU”). These provisions take precedence over any inconsistent provisions
in the remainder of this Privacy Policy.
14.2 Portability
You have the right to obtain from us the Personal Data
that you have previously provided to us, and which we process on the basis of
your consent in a structured, commonly used and machine-readable format and a
right to request that we transfer such Personal Data to another party. If
you wish for us to transfer the Personal Data to another party, please ensure
you detail that party and note that we can only do so where it is technically
feasible. We are not responsible for the security of the Personal Data or its
processing once received by the third party. We also may not provide you with
certain Personal Data if providing it would interfere with another’s rights
(e.g. where providing the Personal Data we hold about you would reveal
information about another person).
14.3 Erasure
You may request that we erase the Personal Data we hold
about you in the following circumstances:
(a) you believe that it is no longer necessary for
us to hold the Personal Data we hold about you;
(b) we are processing the Personal Data we hold
about you on the basis of your consent, and you wish to withdraw your consent
and there is no other ground under which we can process the Personal Data;
(c) we are processing the Personal Data we hold
about you on the basis of our legitimate interest and
you object to such processing. Please provide us with detail as to your
reasoning so that we can assess whether there is an overriding interest for us
to process and retain such Personal Data;
(d) you no longer wish us to use the Personal Data
we hold about you in order to send you promotions, special offers, marketing
and lucky draws; or
(e) you believe the Personal Data we hold about you
is being unlawfully processed by us.
Please provide as much detail as possible on your reasons
for the request to assist us in determining whether you have a valid basis for
erasure. However, we may retain the Personal Data if there are valid grounds
under law for us to do so (e.g., for the defence of
legal claims or freedom of expression) but we will let you know if that is the
case. Please note that after deleting the Personal Data, we may not be
able to provide the same level of servicing to you as we will not be aware of
your preferences.
14.4 Retention of Personal Data
We retain your Personal Data as long as
needed to provide services or products to you, or as required or permitted by
applicable laws, such as tax and accounting laws. If you make a request for
erasure of your Personal Data 3 and we determine that there is a valid basis
for your request, we will endeavour to erase the
Personal Data within 30 days of your request, or inform you if it will take
longer.
14.5 Objection against Profiling and Targeted
Marketing
At any time you have the right to object to our
processing of Personal Data about you in order to send you promotions, special
offers and marketing messages, including where we build profiles for such
purposes and we will stop processing the Personal Data for that purpose. Please
provide as much detail as possible on your reasons for the request to assist us
in determining whether you have a valid basis for objection. However, we may
retain the Personal Data if there are valid grounds under law for us to do so.
14.6 Restriction of Processing to Storage Only
You have a right to request that we restrict the
processing of the Personal Data we hold about you to storage purposes only,
where:
(a) you believe the Personal Data is not accurate,
for the period it takes for us to verify whether the Personal Data is accurate;
(b) we wish to erase the Personal Data
but you want us to just store it instead;
(c) we wish to erase the Personal Data as it is no
longer necessary for our purposes but you require it
to be stored for the establishment, exercise or defence
of legal claims; or
(d) you have objected to us processing Personal Data
we hold about you on the basis of our legitimate interest and you wish us to
stop processing the Personal Data whilst we determine whether there is an
overriding interest in us processing and retaining such Personal Data.
14.7 Transfer of Personal Data outside the EU
Your Personal Data may be transferred outside of the
EU. We take appropriate steps to ensure that recipients of your Personal Data
are bound to duties of confidentiality and we implement measures such as
appropriate contractual clauses to ensure that the recipients of such transfer
protect and treat your Personal Data in accordance with all applicable personal
data protection laws.
14.8 Information on Children
The Services are not intended for children under the age
of 16 who are located in the EU. We do not knowingly
collect or maintain any personal data or non-personally-identifiable
information from anyone under the age of 16 who is located in the EU, nor is
any part of our Site, Games or other Services directed to children under the
age of 16 who are located in the EU. We will close any accounts used
exclusively by such children and will remove and/or delete any personal data we
believe was submitted by any child under the age of 16 who is
located in the EU.
15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
15.1 If you have any questions, concerns or
complaints about our privacy practices, please contact us at smallegg.dyy@gmail.com.
Last modified: 22 May 2020