Privacy Notice

Version: 2.2

Last modified: 11 January 2024

We respect your privacy and take all necessary efforts to protect your Personal Data. Understanding the significance of Personal Data protection in a digital age, we adopted this Privacy Notice to make the processing of information about you fair, lawful, and transparent.

This Privacy Notice applies to the processing of your Personal Data when you use our website https://www.burny.games/ (“Website”), play our games available on the official app stores or other platforms (“Games”) including any mobile or device-specific version of the Website and/or Games, use any related products and services that we provide, including our official pages on social networking services. The Website, Games, and any other of our products and services shall collectively be referred to as Services.

We encourage you to take your time and read this Privacy Notice meticulously because it provides you with the following information:

Our contact details
Categories and sources of your Personal Data
When we share your Personal Data with others
How we commit international data transfers
Your data protection rights
Rights of California residents
Children
How to complain
How we secure your Personal Data
How we store your Personal Data
Cookies
What happens when you visit other websites
Modifications to this Privacy Notice
Definitions and legal references

You can find the vocabulary of the definitions and legal references at the end of this Privacy Notice.

Any references to “you” and “your” include all individuals whose Personal Data we collect, hold, and process as a Data Controller while providing Services, including, in the case of legal entities, their representatives, employees, officers, agents, directors, and shareholders.

OUR CONTACT DETAILS

Name: Burny Games LTD. Any references in this document to “we”, “us” or “our” are references to Burny Games LTD only.

Registration number: НЕ401925

Address: Louki Akrita, 21-23, BELLAPAIS COURT, 7th floor, Flat/Office 46, 1100, Nicosia, Cyprus

E-mail: legal@burny.games

Burny Games LTD is a Data Controller within the meaning of the GDPR. It means that Burny Games LTD determines why and how the processing of your Personal Data should take place.

CATEGORIES AND SOURCES OF YOUR PERSONAL DATA

Personal Data you give us personally

1. Registration Data. When you use our Services, you may provide us with your name, age, email address, nickname, or other information that you decide to share with us.

2. Communication Data. If you correspond with us by email or other forms of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry. Communication Data may include any information you choose to share with us.

3. Payment Data. When you make any purchases on our Services, we collect your payment details such as payment methods, currency, the amount of your payment, etc.

4. User-generated content. If you make any comments or publish any content (e.g., text, image, video, audio) on our Services, we may process Personal Data from such content.

Personal Data that we additionally collect

1. Activity Data. When you use our Services, we may collect information about your activity, such as pages visited, time spent, features used, clicks, preferences, etc. We also analyze your activity through the Games, your engagement with the Games, conversion, assessment, and report on the Games performance. We may analyze your engagement by tracking your clicks on ads on Services, your interaction with our ads on other resources, and the installation of Games.

2. Gaming Data. When you play our Game, we collect information about your gaming activity including your registration time, login time, game performance and progress, time stamps of actions, history of games, time spent, your preferences, in-game purchases, gaming patterns, interactions with other players (if applicable).

3. Device and Connection Data: We collect information about your device, including device model and properties, protocol (IP) address, the region or general location where your computer or device is accessing the internet, device language, browser type, operating system, carrier, mobile device identifiers (such as device ID and advertising ID (like IDFA - Apple Advertising ID, or AAID - Android Advertising ID).

Personal Data we get from third parties

In some cases, we may receive your Personal Data from third parties that collect such information through our Services according to their privacy policies/notices and arrangements with us. For example, providers of analytics, marketing, fraud prevention services, etc. For further information on third parties integrated into the Services, please go to ‘Analytics and other service providers’.

Personal Data we get when you connect the Services through third parties

If you log in to the Games using an account at social networking services (“SNS”) (for example, Facebook Login) or decide to connect our Games to your Apple or Google account, we will collect some Personal Data (as permitted by you) from your account with third parties to set up your profile on the Games.

Personal Data we collect from publicly available sources

We may collect and process information about you from publicly available sources (e.g., SNS, search engines, chats, blogs, etc.), e.g., when you post comments or content related to our Services, somehow else mention us on the Internet to respond to your comments and resolve any issues encountered.

What happens if you don’t give us your Personal Data

You are under no obligation to provide us with your Personal Data. However, some Personal Data is necessary so that we can supply you with the Services. For example, if you do not provide us with Registration Data, we will be unable to set up your account in the Game and allow you to play.

HOW WE USE YOUR PERSONAL DATA

We use your Personal Data for the following purposes:

1. Providing Services

This includes using Personal Data in order to:

Provide access to the Website and Games;
Verify your age;
Create your account and allow you to play our Games;
Manage your account in the Game and customize your experience in the Game (e.g., using your language in the Game and communication);
Provide you with our products or services;
Verify and confirm payments (if any).

We rely on the fulfillment of a contract and legitimate interests (for example, processing of payments) as the lawful basis for the processing of your Personal Data.

2. Customer support

We process Personal Data to support you, including to:

Communicate with you, send messages concerning your account (e.g., security alerts) or support messages;
Answer any of your questions, or comments, and resolve any issues related to our Services;
Improve our support processes.

We rely on a legitimate interest basis (for example, to resolve issues) for collecting, storing, and processing this information.

3. Safety and security

We use Personal Data to help maintain the safety, security, and integrity of our Services This includes:

Ensuring confidentiality, integrity, and availability of the Services;
Preventing unauthorized access to our information systems;
Detecting any suspicious activity on our Services;
Taking action against fraudulent and misbehaving players.

We have a legitimate interest in maintaining Personal Data for safety and security purposes.

4. Marketing our Services

We may use some Personal Data we collect to market our Services, in particular to:

Advertise our Games and other Services to you;
Assess the effectiveness of our advertisement campaigns;

Notify you of news and updates related to our Services.

We send you our direct marketing communications only if we obtain your consent. You can opt out of marketing communications and personalized advertisements at any time by contacting us at legal@burny.games, changing the privacy settings of your device or through the functionality of our Games.

You will receive push notifications from us only when you enable that type of communication in your device settings.

We rely on our legitimate interest to evaluate the efficacy and level up our advertising campaigns or show you contextual ads.

5. Improvement of our Services

We may use Personal Data we collect for testing, research, analysis, development, and improving user experience on our Services, in particular to:

Analyze the performance of our Games and players’ satisfaction with them;
Perform market analysis/research.

We have a legitimate interest in understanding how you use our Services and enhancing our Services to keep you engaged.

6. Distribution of personalized ads in our Services using third-party ad networks

Our Services include features from third-party ad networks and their partners (e.g., software development kits or SDKs, application programming interface or API, cookies) enabling them to receive some Personal Data from our Services for a customized in-game ads experience. This practice is commonly referred to as “interest-based advertising”, “online behavioral advertising”, or “targeted advertising”.

Where required with your consent, we may share such types of Personal Data with ad networks and their partners:

IP address, mobile device identifiers (such as device ID and advertising ID), device model and properties, the region or general location where your computer or device is accessing the internet, device language, browser type, operating system, carrier; and
Other information regarding the delivery of ads and your interaction with them.

Ad networks and their partners use this information to deliver relevant ads and optimize the ad content to make sure you don’t see the same ad multiple times and make ads tailored to your interests and preferences.

Most ad serving companies collect and use Personal Data pursuant to their own privacy policies/notices and may combine information collected in the context of delivering an offer or ads to you via our Services with other information they have independently collected over time and/or across different websites/apps. A list of ad companies that operate their own networks on our Services, links to their privacy statements, and opt-out options (if available) can be found at ‘Advertising/Monetization networks and their partners’.

If you reside in the EEA or UK, we need your specific and informed consent to share your personal data to deliver personalized in-game ads to you.

You can opt out of receiving personalized ads from third parties in Games at any time by changing our privacy preferences in Games, contacting us at legal@burny.games, or adjusting your Privacy Settings of your devices (detailed information for Android users can be found here, and information for iOS users can be found here).

Please be aware that opting out of receiving targeted advertising does not imply that you will no longer receive any advertising. Instead, you may encounter contextual advertising that is less tailored to your interests, preferences, and needs.

WHEN WE SHARE YOUR PERSONAL DATA WITH OTHERS

1. Service providers and business partners:

Hosting providers: To store and transfer our content and data.
Payment service providers: To process payment transactions.
Analytics providers: To measure, process, and analyze the performance of the Services and effectiveness of marketing campaigns, tailor our marketing activities, and improve Services and user experience.
Marketing partners: To send, manage, and optimize messages to you (push notifications, email, SMS, etc.), deliver mobile ads, and ensure Games monetization.
IT and security services: To protect the Services, build and maintain our technical infrastructure.
Consultants, lawyers, accountants, and other professional service providers: To receive professional advice.
Third-party ad and monetization networks: To deliver personalized in-game ads and monetize our Games.

2. Other disclosures

In addition to the disclosures for the purposes identified above, we may disclose your Personal Data to third parties:

To comply with legal obligations and respond to requests from government agencies;
To address disputes and claims, or to establish, exercise, and protect our rights.

As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, Personal Data may be one of the transferred business assets. In any case, guarantees provided by this Privacy Notice will remain in full force.

HOW WE СOMMIT INTERNATIONAL DATA TRANSFERS

As a multinational business, we engage service providers from different countries, including countries outside the EEA and UK. We take measures to provide an appropriate level of data privacy protection:

Adequacy: We may transfer Personal Data to a third country when such a third country has received a finding of “adequacy” from the relevant regulator(s);
Appropriate safeguards: We are providing appropriate safeguards by entering binding, standard data protection clauses, including international data transfer agreement (IDTA), the international data transfer addendum (UK Addendum) (where applicable) adopted by the relevant regulator(s) and enforceable by data subjects in the UK and/or EEA;
Derogations: Depending on the circumstance, we also collect and transfer Personal Data based on certain derogations such as explicit consent of the data subject, performance of a contract involving the data subject, important public interest reasons, establishment, exercise, or defense of legal claims.

If you want further information on the specific mechanism used by us when transferring your Personal Data outside of the EEA or UK, please contact us.

YOUR DATA PROTECTION RIGHTS

Under data protection legislation you have certain data protection rights. You can learn more about these rights below:

Right of access: You have the right to ask us for copies of your Personal Data;
Right to rectification: You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete;
Right to erasure (right to “be forgotten”): You have the right to have all of your Personal Data erased when you stop using the Services and close your account;
Right to restriction of the processing: You have the right to ask us to restrict the processing of your Personal Data in certain circumstances;
Right to object to the processing: You have the right to object to the processing of your Personal Data in certain circumstances;
Right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organization, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

You can also exercise your rights by contacting us at legal@burny.games.

RIGHTS OF CALIFORNIA RESIDENTS

As a California resident, under the California Consumer Privacy Act (“CCPA”) you have the rights listed below:

Right of Disclosure. You have a right to request disclosure of your Personal Data, and to receive additional details regarding the Personal Data the Company collects and its use purposes, including any third parties with which it shares Personal Data. You have a right to request a copy of your Personal Data that the Company has collected about you during the past 12 months in a readily usable format. You can exercise this right only twice in 12 months.
Right to deletion. You can ask us to delete the Personal Data that we have collected about you.
Right not to be subject to discrimination for the exercise of rights. You are entitled to exercise the rights described above free from discrimination. This means that we will not take any actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights.

Opt-out right for Personal Data Sales. You have a right to request to opt out of the sale of Personal Data to third parties.
Right to correct inaccurate Personal Data. You may ask us to correct inaccurate Personal Data that we have about you.
Right to limit the use and disclosure of sensitive Personal Data (if any). In our regular course of business, we do not process sensitive Personal Data (for example, social security number, financial account information, precise geolocation data, or genetic data). However, please be informed that you can ask us to only use your sensitive Personal Data for limited purposes, such as providing you with the Services you requested.

You are not required to pay any charge for exercising your rights.

You can also exercise your rights by contacting us at legal@burny.games.

CHILDREN

We do not intentionally or knowingly collect personal information from children under the age of 13 and our services are not targeted at children. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

HOW TO COMPLAIN

If you have questions, concerns, or complaints, please try to contact us at legal@burny.games.

In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you are unhappy with how we process your Personal Data.

If you believe that your rights have been violated, you can file a complaint with the Commissioner for Personal Data Protection of the Republic of Cyprus (the jurisdiction of our registration). Commissioner's website: http://www.dataprotection.gov.cy.

If you are within the EU, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of work. You can find the list of data protection authorities in the EEA at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

HOW WE SECURE YOUR PERSONAL DATA

To help protect the privacy of Personal Data, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees and vendors who need to know that information to provide Services to you and communicate with you at your request. Also, we train our employees and contractors about the importance of confidentiality and maintaining the privacy and security of your Personal Data.

HOW WE STORE YOUR PERSONAL DATA

We will not keep your Personal Data for longer than required. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, and what the law requires us to do.

When we no longer need to keep your Personal Data, we anonymize or delete it. In certain cases, we need to securely retain certain Personal Data to fulfill our legal and regulatory obligations.

COOKIES

Cookies are snippets of data that can be installed on your internet web browser when you visit the Website. You can manage your preferences regarding the use of cookies directly through your browser or through the cookie banner. However, blocking some types of cookies may impact your experience of the Services we are able to offer.

For additional details regarding the use of cookies on this Website, please refer to the Cookie Notice available here. If you require further information about the use of cookies or similar technologies on our Games, please visit the respective cookie settings within the Games.

WHAT HAPPENS WHEN YOU VISIT OTHER WEBSITES?

Our Services may contain links to the other websites (our business partner/advertisers/affiliates networks). Please note, that if you follow a link to any of these websites, it is advisable to keep in mind that these websites have their own privacy notices or privacy policies. This Privacy Notice does not cover how those organizations process Personal Data. Consequently, we do not accept any responsibility or liability for these policies.

MODIFICATIONS TO THIS PRIVACY NOTICE

We keep our Privacy Notice under regular review to make sure it is up to date and accurate. We recommend that you revisit and read this Privacy Notice regularly to ensure that you are up-to-date with the current terms.

DEFINITIONS AND LEGAL REFERENCES

Data Controller 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.

Data Processor means the natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Data Controller and according to its instructions.

The European Economic Area (EEA) consists of the member states of the European Union and three additional countries, namely Iceland, Liechtenstein, and Norway.

Personal Data means any information that directly, indirectly, or in connection with other information allows for the identification of a natural person.