We, at OONA Trading Limited (“OONA”, “we” or “us”), are committed to respecting your privacy and the integrity and security of your personal data. OONA is a data controller under this Privacy Policy with registered address at Kyriakou Matsi 3 & Anexartisias, Roussos Limassol Tower, 4th floor, 3040, Limassol, Cyprus.
This Privacy Policy applies to https://oona-trading.com/, all other sites or online services that are owned or operated by OONA, all mobile games published by OONA, OONA games that can be played through third party platforms (collectively “Services”).
By downloading, accessing and/or using our Services, you acknowledge the collection and use of your information in accordance with this Privacy Policy, including our and our partners’ use of your data for the purposes as described below.
PLEASE READ THE FOLLOWING CAREFULLY AND MAKE SURE YOU FULLY UNDERSTAND THIS PRIVACY POLICY. IF YOU HAVE ANY CONCERNS ABOUT PROVIDING INFORMATION TO US OR IT BEING USED AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DISCONTINUE AND AVOID USING THE SERVICES.
1. DATA COLLECTED
1.1. We collect only the data that is necessary for the purposes described in this Privacy Policy — we don't gather any more information than we need. The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways:
1.1.1. Data provided by you
From time to time, you may voluntarily provide to us the following data:
- Contact information, such as name and email address.
- Your messages to the Services, such as chat logs and player support tickets.
- Other data you choose to provide us*.
*We do not require you to provide us with any personal data. However, if you voluntarily choose to provide us with any data (i.e. by putting your real name as a nickname, or when you contact us via the Services, etc.), we will process such data in accordance with this Privacy Policy. For example, if you decide to contact us with a request, we will process the content of your message, the date and time of your message, our response and any other personal data you provide in that context. If you decide to have a chat in the Services, we will process the details of your conversation.
1.1.2. Data collected by us automatically
We will automatically collect the following data of yours:
| Data Category | Data Elements |
|---|---|
| Device-level identifiers |
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| Approximate location data |
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| Device-related data |
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| Diagnostics and performance data |
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| Usage data |
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Note that we do not use such data to learn a person’s true identity or contact details, but mostly to provide our Services and understand how our users typically use and interact with our Services, so that we could maintain and improve them.
1.1.3. Data provided by third parties
We may receive information relating to you and your use of the Services from the following third-party providers:
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Analytics Providers. Our analytics providers may provide us with:
- Data about your use of the Services (such as in-app events, your interaction with the Services, software bugs and errors, etc.) so that we could improve the Services and detect and prevent fraud in it.
- Data about the performance of our advertising campaigns (e.g. we may be provided with information from which ad network and advertising campaign the install of the Services originated from, or data on fraud traffic such as refund abuse in games or click fraud in advertising).
- Data about your interaction with the in-app advertisements (including clicks, views, impressions).
- Other data mentioned in Clause 1.1.2 above.
- Marketing Partners. From time to time, we may receive non-personal information from our marketing partners concerning the performance of our marketing campaigns run outside the App (e.g. we may be provided with data about interaction with our advertisement (such as clicks, views, impressions, installs or other marketing campaign performance indicators), information from which ad network and advertising campaign the install of our Service originated from or data necessary to fight fraud (such as refund abuse in games or click fraud in advertising)).
- Advertising Partners. We receive information from third-party advertising partners, including user ID and information on your interactions with advertisements shown in our Services.
- Online Stores. If having purchases within the Services, we will run them via App Store or Google Play Store (“Online Stores”). Such being the case we will get limited data on your purchases from the Online Stores, which would typically include id of transaction, time and date of purchase, amount and currency of purchase, purchase history. We do not process or get access to your financial data, such as your credit card number or bank account data. Any post-purchase processes are controlled by the Online Stores. We encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Services.
- Log-in providers. If you choose to link a third-party account (such as Facebook, Google, or Apple) to the Services, we may receive some basic profile information from that provider to enable cross-device login and synchronize your progress across devices – such as your user ID, username, profile picture, email address, a list of friends who play the same game, and an authentication token (depending on your privacy settings with the relevant provider). We do not access or store your passwords for any third-party account. Please note that these third-party services are governed by their own privacy policies and terms of service. We encourage you to review them to understand how your data is handled.
1.2. We do not request or intend to collect any sensitive data (“special categories of information”), such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please do not share such information about yourself (or others) via the Services.
2. PURPOSES AND BASIS FOR PROCESSING
2.1. We will process your personal data for the following purposes and on the following basis:
| Purpose | Legal Basis |
|---|---|
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(a) Operating the Services:
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Performance of a contract which you enter into when you download or access the Services and accept our Terms |
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(b) Improving the Services and your experience:
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Our legitimate interest to improve and optimize the Services and enhance user experience |
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(c) Enforcing our Terms of Use:
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Our legitimate interest to keep the Services safe, to fight fraud, ensure security of the Services and protect our interests |
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(d) Complying with applicable law:
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Compliance with legal obligations to which we are subject |
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(e) Promoting the Services and measuring marketing performance:
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Our legitimate interest to advertise and promote the Services |
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(f) To display advertising in the Services using third-party advertising networks:
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For general advertising or when consent is not required we rely on our legitimate interest in monetizing our Services. For personalised advertising and tracking, we rely on your consent. |
2.2. We do not carry out any decision-making having legal effects for you based solely on automated processing, including profiling.
3. SHARING OF DATA
3.1. We may share your personal data with:
3.1.1. Our service providers and other partners, who perform the following functions / services:
| Cloud storage providers | we engage them for storage of Services data |
| Analytics services | we engage them for analytics, attribution and mobile measurement services which allow us to improve the Services through data analysis and know our audience |
| Marketing partners | we collaborate with them to advertise the Services, to measure and optimize our advertising campaigns, so we can reach audiences interested in the Services and expand our user base |
| Advertising partners | we may also share information (such as device identifiers, IP address and non-identifying data about your device) with advertising partners who distribute advertising in our Services or allow them to collect data directly from you through their mobile SDKs or similar technologies embedded in our Services. Our advertising partners may combine this information with data they have collected about you when you use their services or third-party websites and services. This helps them show you more relevant advertising in our Services and improve their ad targeting and measurement systems. We advise you to check their privacy policy for further details. |
| Other service providers | we may engage other service providers, e.g. assisting us with customer support, software maintenance, technical support, security issues, external auditors, etc. |
3.1.2. State authorities and institutions (upon their requests, when otherwise required under applicable law or on our initiative in order to combat the violations of the Terms);
3.1.3. Other users of the Services (to a very limited extent: only your nickname and game results by means of displaying them in the leaderboard);
3.1.4. Our affiliated companies;
3.1.5. Acquiring party or assignee in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our company or its assets;
3.1.6. Other third parties, providing such sharing is needed for the purposes of processing listed above or upon your consent for this.
3.2. You may find the current List of our service providers and other partners here.
3.3. We share your personal data with these third parties only for the purposes listed in Section 2 above, where we have a legal basis for this and to the extent such sharing is needed to achieve the purpose. Such third parties will provide the same or equal protection of your data as stated in this Privacy Policy and required by applicable laws.
4. INTERNATIONAL DATA TRANSFERS
4.1. Our Services are global by nature and your data can therefore be transferred and processed in other countries other than the country in which you are resident. 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. Adequate safeguards that our partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection for personal data of EU residents or standard contractual clauses approved by the EU Commission or other methods approved by the relevant regulators in other countries.
5. YOUR RIGHTS
5.1. Depending on your country of residency, you may generally have the following rights with regard to our processing of your personal data (some of the rights have their particular execution conditions, i.e. can be exercised providing certain conditions are met):
5.1.1. Right to access: You have the right to access the personal data we hold about you and certain information about processing of such data (e.g. categories of data collected, purposes of processing, data recipients, retention period, the sources of collected data, etc.);
5.1.2. Right to rectification: You have the right to request us to rectify your personal data (if they are inaccurate or incomplete);
5.1.3. Right to erasure: You have the right to request the erasure of your personal data (where we do not have a legal basis to continue to process such personal data or in other particular circumstances);
5.1.4. Right to data portability: You have the right to receive the personal data you have provided us with, in a structured, commonly used and machine-readable format, as well as to request us to transfer your personal data to another controller, where this is technically feasible (in certain circumstances and under certain conditions);
5.1.5. Right to withdraw consent: You have the right to withdraw your consent (when we rely on consent as the legal basis for processing). Note that withdrawal of your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent;
5.1.6. Right not to be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects or could significantly affect you;
5.1.7. Right to object: You have the right to object to or restrict how we process your data (in certain circumstances). Please note in case of such a request we may not be always able to provide you with all the Services functionalities and / or the Services performance may suffer;
5.1.8. Right to lodge a complaint: You have the right to lodge a complaint with a data protection supervisory authority (if you think that any of your rights have been violated by us).
5.2. If you wish to exercise any of the above rights, please contact us via (i) the in-app support feature, if available (Option 1) or (ii) the contact details in Section 10 of Privacy Policy (Option 2). If using Option 2, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond. Please note that your request for exercising any of your rights must:
5.2.1. provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
5.2.2. contain sufficient details describing your request to allow us to properly understand, review and respond to it.
5.3. We reserve the right not to respond to your request or provide you with personal data, in case we are unable to verify your identity or authority to make such a request.
5.4. Permissible number of requests, whether they are free of charge or not, and other conditions of requests shall fully depend on your home jurisdiction requirements.
5.5. If you are a resident of the United States, please read additional information about US Privacy Rights carefully.
5.6. Opt-out of personalized advertising. You can opt-out of personalized advertising on the app at any time by checking the privacy settings of your device or via the privacy settings of our apps.
Option 1 - Services Settings (where applicable under your local privacy laws):
- Open app Settings menu
- Select Consent Preferences
- Tap Manage preferences and adjust your choices
Option 2 – Device Settings
| Apple devices: | Android devices: |
|---|---|
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For iOS 14 and newer:
For iOS 13 and older:
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Delete your device’s advertising ID:
On version 4.4 or older versions of Android device:
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5.7. Push notifications. From time to time we can use push notifications to send you Services-related communications. If you opt-in to receive push notifications on your device, we will receive a push notification token, so we can verify whether we are allowed to send them to you. You can manage it any time in your device settings:
| Apple devices: | Android devices (settings can vary by phone, please see details here): |
|---|---|
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6. AGE RESTRICTIONS
6.1. The Services is intended for use only by adults (i.e. individuals who are over 18 years of age or of the age of majority in their country, whichever is older).
6.2. If we learn that personal data has been collected via the Services from children, then we will take the appropriate steps to delete this personal data.
6.3. If you are a parent or guardian and discover that your child is using the Services or that we may have collected information from that child through the Services, then you may alert us at contact@oona-trading.com and we will delete that child’s personal data from our systems as soon as possible.
7. SECURITY SAFEGUARDS
7.1. We are continuously developing and implementing administrative, technical and physical security measures to protect the confidentiality, security and integrity of the collected data and to prevent from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to the data under our control. In addition, we limit access to personal data by our personnel and partners on a need-to-know basis only.
7.2. Although we use commercially reasonable efforts to assure that your data remain secure when maintained by us, please; be aware that no security measures are perfect or impenetrable. Unfortunately, the transmission of data via the internet is not completely secure and we cannot guarantee the security of your data transmitted via the Services; any transmission is at your own risk. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
8. DATA RETENTION
8.1. We store the collected personal data of yours for as long as necessary to fulfil the purposes we collected it for, including for complying with our legal obligations. We may retain your personal data for a longer period in the event of any existing, upcoming or possible complaint, dispute or litigation.
8.2. To determine appropriate retention period with respect to your personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as applicable legal requirements.
8.3. In some circumstances we can anonymise your personal data (so that it can no longer be associated with you, even if combined with other data) for analytical or statistical purposes, in which case we may use this data indefinitely (i.e. also after deletion of your account) without further notice to you.
9. UPDATES
9.1. We may update our Privacy Policy from time to time. When we do so, we will revise the date at the top of the policy. Any updates to this Privacy Policy shall be effective as of the stated “Last updated”. If we make changes that are material, we will use reasonable efforts to notify you (such as by placing an in-game notice or a push-notification). If we make minor amendments, no notice will follow. We encourage you to check this Privacy Policy regularly for updates, so that you know our current practices.
10. CONTACT US
10.1. If you have questions about this Privacy Policy, or if you have any requests for exercising any of your privacy rights, you can contact us through the in-app support feature or via e-mail at contact@oona-trading.com. However, please note that we may still redirect you to make the same request through the in-app support feature to verify you as our user and/or request additional information necessary for us to respond.