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Privacy Statement - EEA

Please carefully read the following Privacy Policy

Privacy Statement - EEA

Version 21 July 2021

  1. General information

    Bizzon Case Ltd is committed to protecting the privacy of everybody who uses our website and applications. This privacy statement -"Website Privacy Statement Bizzon Case Ltd - EEA", or "Privacy Statement" for short, is meant to provide transparency to Bizzon Case Ltd's privacy practices and principles. It provides data about what we collect through our lupygames.com web platform, our Bizzon Case Ltd for Developers platform, our mobile applications from website visitors from the European Economic Area (EEA)* ("Website Visitors") Data information. General audience websites and applications (hereinafter together referred to as "Bizzon Case Ltd Website"). Please click this link for an overview of the domain called "Bizzon Case Ltd Site". The Bizzon Case Ltd website is exclusively for website visitors ("Site Visitors") aged 16 and above. If you are under 16, this website is not for you. This site is a safe environment for children under 16 years of age. To view our privacy practices in specific to the Bizzon Case Ltd for Kids website, please refer to the Children’s Site Privacy Statement-EEA. If you have any inquiries about this privacy statement, please contact us at [email protected]. The Bizzon Case Ltd website and Bizzon Case Ltd for Kids (collectively referred to as "all Bizzon Case Ltd websites") are operated by Bizzon Case Ltd BV (referred to in this privacy statement as "Bizzon Case Ltd", "we", "our" or " us"). Bizzon Case Ltd is an entity incorporated under the laws of the "COUNTRY". * Do note that we determine from which region you visit our website by your IP-address, thus if you use a VPN-connection, you may not be shown the Privacy Statement applicable to you.

  2. Which personal data is used and for what purposes?

    All functions on the Bizzon Case Ltd website can be used without registration of website visitors. Site visitors will not be asked for personal data (e.g. email address and phone number). In addition, our game developers will remove all outgoing links and branding/advertising (such as splash screens, social links and app store links) from the games in principle. Nevertheless, Bizzon Case Ltd does collect certain digital data. We can process this personal data in various ways. Please find general information about our processing of your personal data directly below. Here, you will find a brief review of the various topics that you can click on to learn more details about the processing of your personal data in that context.

General processing purpose

In general, we may process your personal data with the following goal:

  • For maintenance, management, and network and security purposes;
  • Used for internal control and business operations;
  • Used to analyze and improve our products;
  • Handle any requests, complaints and disputes;
  • Used to determine, exercise and defend our rights;
Comply with legal obligations (including fraud prevention) and the requirements of authorized government agencies. General processing grounds Generally speaking, we may process your personal info according our legal obligations. This means that we will process your personal data as far as legal obligations go. Such as complying with the legal minimum retention period.

Legitimate interest

Sometimes, we may indicate that we process your personal data based on the legal basis of "legitimate interest". This means balancing the interests of dealing with the interests of the service on the one hand and your privacy interests on the other, and the interests of the processing takes precedence. Each topic below contains related legal rights. If you want to know more about that, you can contact us directly through the contact information listed below. Minors and other people with a legal representative The Bizzon Case Ltd website is not addressed to people under 16 years of age. We also do not focus about people who are placed in a legal relationship, such as guardians or people who are supervised or managed by others. The General Bizzon Case Ltd Website We process personal data for providing, maintaining and improving our websites, our apps and for our social media activities. The people involved. Our website visitors: people who visit the Bizzon Case Ltd website. Purpose of processing. Should you visit the Bizzon Case Ltd website, we will process your personal data for the following purposes: Operation of the Bizzon Case Ltd website (including remembering your settings and agreeing to choices); Advertisement and marketing to you, targeted advertising, and provide you with relevant offers; Show you the privacy info related to your region (the specific personal data we process depends on the region where you visit the Bizzon Case Ltd website).

Personal data processed

When you visit the Bizzon Case Ltd website, we may process the following (personal) information collected automatically:

  • IP address;
  • device ID;
  • Browser type;
  • Global geographic region (e.g. country or city level location);
  • The advertisements shown to you and your interaction with them (for example, whether you clicked on that advertisement);
Other technical information, such as information about the interaction between your device and our website, web pages visited, links clicked, and log data. Sensitive data: In the context of the Bizzon Case Ltd website, we do not process sensitive information in principle. If we decide to process sensitive information under certain conditions, you will be separately notified of this processing and asked for your explicit consent when necessary.

Legal basis for processing

We use your personal data in the context of the Bizzon Case Ltd website based on one of the following legal grounds: Agreement. Sometimes, we process personal data based on the explicit agreement of the relevant person. For example, this applies to cookies and similar technologies that we only agree to use in our cookie pop-up window. Legitimate interest. We have legitimate rights and interests in providing and using our website, applications and social media; and pursuing the other processing purposes listed above. Social media platform. Bizzon Case Ltd uses diverse social media platforms, for example in the context of recruitment, selection and for marketing purposes. Bizzon Case Ltd is responsible for the content of the Bizzon Case Ltd website, but is not responsible for the management of the company's social media outlets. For more information on how such social media websites are using your personal data, we will refer to the information already on the websites of these platform providers. Below we provide links to the privacy policies of various social media platform providers, and we can use these links:

  • Facebook;
  • Twitter;
  • Instagram;
  • YouTube;
  • LinkedIn;
  • Google;
  • Reddit;

Bizzon Case Ltd for Developers (secondary domain: developers.lupygames.com)

The people involved. Game developers who provide games for the Bizzon Case Ltd website through the Bizzon Case Ltd for Developers platform have signed a contract with us. Purpose of processing. When you visit our Bizzon Case Ltd for Developers platform, we will compute your personal info for the following purposes:

  • Provide you with information about applicable conditions;
  • Provide you with a financial overview of your account and related invoices;
To provide you with information about our SDK (software development kit), for example, in principle, you need to remove all outgoing links and branding/advertisements (such as splash screens, social links, and app store links) from the game. The personal data that is processed. On our Bizzon Case Ltd for Developers platform, we may process the following personal data:
  • Full name;
  • E-mail address;
  • Phone/skype/discord;
  • Name company/studio;
  • Contract details;
  • Financial details;
  • Game(s) and related details such as game title and description, No. of app installs, App store URL, Web build URL;
Communication details incl. how you heard about us. Legal basis for processing. We use your personal data in the context of developer.lupygames.com based on one of the following legal bases: Contracts. If you have signed a contract with us, we will process your personal information in its context. For example, make sure you receive the payment due. Legitimate interest. We provide you with a developer platform and legal rights to pursue other processing purposes mentioned above.

About Bizzon Case Ltd (secondary domain name: about.lupygames.com)

You can find more information about our company on our "About Bizzon Case Ltd" page. On this page, we will not process any other personal data about you. It contains links to some of the above pages, such as developer.lupygames.com or jobs.lupygames.com. Job search platform of Bizzon Case Ltd (second-level domain name: jobs.lupygames.com) The people involved. Those who apply for a job through our designated website. Purpose of processing. When you apply for a job at Bizzon Case Ltd through jobs.lupygames.com, we will process your personal data for the following purposes: Evaluate whether you are suitable for our company; Contact you to learn about the further process of your application; To further process your application. Personal data processed. When you apply for a job through jobs.lupygames.com, we may process the following personal data: full name; Email address; LinkedIn profile; Motivation and answers to portfolio questions; restore*; telephone number*; Current company/employer*; How did you hear about this job*; Additional information, such as a cover letter*. * This information is not mandatory.

Legal grounds for processing

We use your personal information in the regards of jobs.lupygames.com based on one of the following legal grounds: agree. Sometimes, we will process personal data based on your (explicit) consent. For example, this applies when you choose Bizzon Case Ltd and may contact you within one year after the completion of the application process for other future job opportunities that you may be interested in. Legal rights. We have a legitimate interest in evaluating your application and other processing purposes mentioned above. Bizzon Case Ltd support The people involved. The person who sends an email to customer support, for example, via [email protected] Purpose of processing. When you contact Bizzon Case Ltd customer support or otherwise contact Bizzon Case Ltd, we will process your personal data for the following purposes: To provide you with support; Answer any questions you have about us.

Personal data processed

When you contact Bizzon Case Ltd customer support or otherwise contact Bizzon Case Ltd, we will process the following personal data:

    Email address; Name (if you provide);
Messages and related metadata you send to us Legal basis for processing. We use your personal data in the context of Bizzon Case Ltd's customer service based on legitimate interests. To provide you with support and answer any questions you ask us involves our legitimate interests.
  1. How do we obtain your personal data?

    We obtain your personal data in various ways: Provided by you. We receive some personal data directly from you. Examples include the information in the message you send us and the information you enter in our application form. Acquired internally. We may obtain your personal data from other Bizzon Case Ltd systems. An example of a game developer is the data contained in our CRM system. Obtained from a third party. We may also obtain personal data about you from other people or external parties. In general, we only use this possibility in two situations: Website visitors: In the context of the cookies and similar technologies we use, we may receive information about you from private third parties (especially the AdTech industry). Applicants: We may obtain information from the recommendation letter included in your application. Obtained automatically. Some personal data we obtain automatically, like through the use of cookies and technologies of this type. When your computer or mobile device contacts our web server (for example, when you visit the Bizzon Case Ltd website), our web server is set to collect usage information. Such usage information includes information about how visitors to our webpage use and browse the Bizzon Case Ltd website. It can include the number and frequency of website visitors to each page, as well as the length of time they stay, browser type, and citation data identifying the pages visited before and after visiting the Bizzon Case Ltd website. Derived. We will not receive certain personal data directly, but we can obtain it from the information we already have. For example, information about your preferences and interests. In principle, you are not obligated to provide us with any information about yourself. However, refusal to provide certain information may negatively affect your experience or functionality on the Bizzon Case Ltd website. If the provision of certain personal data is a legal or contractual obligation or a basic requirement of an agreement with us, we will provide other information about this separately without prior knowledge. In this case, if this information is not provided, we will also notify you of the possible consequences.

  2. Who do we share your personal data with? We only share your personal data with third parties if: This is necessary for service provision or third party participation. For example, in principle, subcontractors can only access the personal data they need to provide services. Persons within third parties who have access to personal data are obliged to keep personal data confidential. When necessary, this is also agreed in the contract. Third parties are obliged to comply with applicable laws and regulations that protect personal data, because we have reached an agreement with the third party or because our terms of use apply. This includes the party's obligation to ensure that appropriate technical and organizational security measures are taken, and that any personal data transfer to countries outside the EEA is fully legalized. We may share your personal data with the following parties as needed. In this case, "need to know" means that a party can only access personal data when the professional services provided by that party require it. Authorized personnel employed by Bizzon Case Ltd, who participated in related processing activities. For example, a member of the support team you contacted. Authorized personnel who are employed by service providers/subcontractors employed by Bizzon Case Ltd and participate in related processing activities. For example, the service provider of the Bizzon Case Ltd online store. We may share certain personal data with authorized personnel employed by various parties in the sector, such as our game developers and advertising partners. Traffic information may be shared with game developers and advertisers in an aggregated and anonymous manner. In addition, advertisers on the Bizzon Case Ltd website may receive information collected by cookies for targeted advertising purposes. For more information on the use of cookies, please refer to our Cookie Statement. Authorized government agency. For example, courts, police, and law enforcement agencies. We may publish information about visitors to our website, including IP addresses, when required by law, at the request of an investigative government agency, or in order to verify or enforce compliance with the Bizzon Case Ltd website and applicable laws and policies. We may also disclose such user information when we deem it necessary to disclose to protect the rights, property or safety of Bizzon Case Ltd or our respective business partners, customers or others. Summary information. We may also disclose non-identifying aggregate user statistics to third parties for various purposes, including describing our services to potential partners and other third parties. Examples of such non-personal information include the number of users who visited this Bizzon Case Ltd website or played a specific game during a specific period of time.
  3. How do we secure your personal data?

    Protecting your privacy and personal data is very important to us. Therefore, Bizzon Case Ltd has implemented appropriate technical and organizational measures to protect and protect personal data to prevent violations of the confidentiality, integrity and availability of data. All Bizzon Case Ltd employees and other personnel employed by Bizzon Case Ltd to process personal data are obliged to respect the confidentiality of personal data. Bizzon Case Ltd has internal documents that describe how we protect the appropriate level of technical and organizational security. In addition, the data breach procedure applies to Bizzon Case Ltd, which explains how to deal with (potential) data breaches. For example, when required by applicable laws, we will notify the competent supervisory authority and relevant data subjects.

  4. To which countries will we transfer your personal data?

    The parties involved in the processing of personal data originating from the European Union may be located in different countries/regions. If these parties are located outside the European Economic Area, the transfer is legalized in the following manner. For an overview of EEA countries, please refer to this link. Move to outside the European Economic Area. The transfer of your personal data to a third party outside the EEA can first be legalized based on the adequacy decision of the European Commission, which determines (partially) the relevant third country to ensure a sufficient level of data protection. For a summary of applicable adequacy decisions, please refer to this link. If your personal data is transferred to a country outside the European Economic Area, but there is no adequacy decision, we will reach an agreement with the relevant parties on the applicability of the relevant version of the standard contract clause. This is a standard procedure to protect your personal data. Approved by the European Commission, both parties fill in the attachment. For various framework standard contract terms, please refer to this link. Where appropriate, take additional protective measures. Under certain circumstances, we can also rely on the derogations of Article 49 of the GDPR to legalize data transmission. This means that we may transfer your personal data in the following situations: (i) with your explicit consent, (ii) if it is necessary to perform a contract with you or for your benefit , Or (iii) if it is necessary, or to establish, exercise or defend a legal claim. Finally, under special circumstances, if the data transfer is necessary for our compelling legitimate interests and is not covered by your interests or rights and freedoms, we may also transfer personal data. If you want to learn more about the way we legally transfer your personal data to countries outside the European Economic Area, you can contact us. Our contact details are listed at the bottom of this privacy statement.

  5. How do we determine how long we retain your personal data?

    Generally speaking, we will keep your personal data for no longer than the time required for the purpose for which we process the personal data. However, there may be exceptions that apply to general reservation clauses. Exception: shorter retention period. If you exercise certain privacy rights, Bizzon Case Ltd may delete your personal data before the generally applicable retention period, or conversely retain it for a longer period of time. For more information on this, please refer to the heading "What are your privacy rights (including the right to object)?" Exception: longer retention period. In some cases, we can process your personal data for longer than the time required for the processing purpose. For example, when we have to process your personal data for a longer period of time, this is the case: Retention obligations. Comply with the minimum retention period or other legal obligations that we must comply with in accordance with EU laws or the laws of EU member states; program. Your personal data is necessary for legal proceedings; freedom of speech. When it is necessary to further process your personal data to exercise the right to freedom of speech and information.

  6. What are your privacy rights (incl. right to object)? According to the General Data Protection Regulation ("GDPR"; (EU) 2016/679), you have various privacy rights. The extent to which you can exercise these rights depends on the processing conditions, such as the way Bizzon Case Ltd processes personal data and the legal basis for processing. Below we have summarized your privacy rights under the GDPR. For more information on this, please visit this page or this page of the European Commission. When it comes to your personal data, Bizzon Case Ltd provides you with certain options. Please review the information below that outlines your privacy rights and how to exercise those rights. We will respond to all requests immediately. If due to complexity or the number of requests, it takes more than a month for our complete response, we will notify you and notify you in time. In addition, please note that we may ask for more information to confirm your identity before taking action on any request. 6.1 Your privacy rights.

    In relation to our processing of your personal data, you have the following privacy rights. The right to withdraw consent. As far as our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time through our contact information listed below. Before you withdraw your consent, the withdrawal of consent will not affect the legality of the processing. If you withdraw your consent, Bizzon Case Ltd will no longer process the personal data for the purpose for which you agreed. However, we may still process personal data for other purposes, such as complying with the minimum retention period. In this case, you will be notified of the matter. Access rights. You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you (but not necessarily the file itself). We will then provide you with more detailed information about our processing of your personal data. For example, the purpose for which we process your personal data, where we obtain the data and who we share it with. The right to correction. You have the right to request correction of the personal data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you. If we process personal data about you, you have this right:

    1. In fact, it is incorrect;
    2. Incomplete or irrelevant to the purpose of collection;
    3. Use in any other way that conflicts with applicable laws.
    The right of correction is not used to correct professional opinions, investigation results or conclusions that you disagree with. However, in this case, Bizzon Case Ltd may consider adding your opinion on this to the personal data. Right to delete. You have the right to request the deletion of your personal data. This enables you to ask us to delete or remove personal data if:
    1. personal data is no longer needed,
    2. you have withdrawn your consent,
    3. you have objected to processing activities,
    4. personal data Data is processed illegally,
    5. personal data must be deleted in accordance with legal requirements, or
    6. personal data collected is to provide information society services.
    However, if processing is necessary, we do not have to meet your request:
    1. exercise the right to freedom of speech and information,
    2. comply with legal obligations that require processing,
    3. public interest reasons in the field of public health,
    4. For archival purposes, or
    5. to establish, exercise or defend legal claims.
    Right to object. You have the right to object to the processing of your personal data where we are relying on legitimate interest as processing ground (see above). As the processing of your personal data takes place for direct marketing purposes, we will always honor your request. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or that are related to the institution, exercise or substantiation of a legal claim. If such is the case, we will inform you on our compelling interests and the balance of interests made. Right to restriction. The right to restrict processing means that Bizzon Case Ltd will continue to store personal data at your request, but in principle may not conduct any further processing on it. In short, you have this right when Bizzon Case Ltd does not have (or no longer has) any legal basis for processing your personal data or if this can be discussed publicly. This right is particularly applicable to the following situations: Illegal processing. We may not (or no longer) process certain personal data, but you do not want us to delete this data. For example, because you still want to request data at a later stage. Personal data is no longer needed. Bizzon Case Ltd no longer needs your personal data for our processing purposes, but you still need this personal data for legal claims. For example, when there is a dispute. Waiting for appeal. You object to the processing of your personal data by Bizzon Case Ltd (see right to object below). Before verifying your appeal, we will no longer process this personal data at your request. Question the accuracy of personal data. You question the accuracy of certain personal data we process about you (for example through your right to correction; see above). During our evaluation of your competition, we will no longer process this personal data at your request. The right to data portability. You have the right to request the transfer of your personal data to you or a third party of your choice (right to data portability). We will provide you or such third parties with your personal data in a structured, commonly used, and machine-readable format. Please note that this right only applies to processing by us through automated means, and only if we conduct such processing on the basis of your consent or the performance of your contract as a party (see above). Automated decision-making. You have the right not to be bound by decisions based solely on automated processing, which will have a significant impact on you ("legal impact on you or similarly significant impact on you"). In this regard, please note that we do not use automated decision-making when processing your personal data. The right to complain. In addition to the above rights, you also have the right to lodge a complaint with the supervisory authority, especially in your usual residence, place of work, or EU member states that are suspected of infringement. Please refer to this page for an overview of the regulatory agencies and their contact details. However, we would like to have the opportunity to deal with your concerns before you contact the supervisory authority, so please contact us in advance.

    6.2 How to exercise your rights.

    You can exercise your privacy rights for free by phone or email through the contact information shown below. If the request is clearly unfounded or excessive, especially due to repetitiveness, we will charge you a reasonable fee or refuse to comply with the request.

    6.3 Verification of your identity.

    Before we further respond to your privacy request, we may ask you to provide specific information to help us confirm your identity.

    6.4 Follow-up of your requests.

    We will provide you with information about the follow-up action of the request in a timely manner, in principle, within 1 month after receiving the request. Depending on the complexity of the request and the number of requests, this period can be extended for another two months. We will notify you of such extension within one month of receiving the request. Applicable privacy legislation may allow or require us to deny your request. If we are unable to meet your request, we will notify you of the reason in accordance with any legal or regulatory restrictions.

  7. Who is responsible for the processing of your personal data? Bizzon Case Ltd is in principle responsible for the processing of your personal data in the context of the Bizzon Case Ltd Website.
    7.1 Externally hosted games, third party games and other websites

    This privacy statement does not apply to the processing of personal data by data controllers other than Bizzon Case Ltd, such as third-party game providers provided on the Bizzon Case Ltd website. The relevant providers of such third-party games are responsible for ensuring that any processing of their personal data in the gaming environment complies with applicable data protection laws. In principle, Bizzon Case Ltd does not allow third-party content providers to collect personal data about website visitors. However, if third-party content providers will collect any personal data, Bizzon Case Ltd will require them to process the personal data, for example, in accordance with applicable laws in the context of the game.


    7.2 Developers

    In principle, game developers on the Bizzon Case Ltd website must remove all outgoing links and branding/advertising (such as splash screens, social links and app store links) from their games. If the developer does collect (personal) information for his own purposes, Bizzon Case Ltd is not responsible for this processing: only the developer decides what (personal) data to process and for what purpose. However, because Bizzon Case Ltd believes that the security of your data while playing games is also very important, we have taken two measures. First, we have included contractual safeguards with developers. They are only allowed to include cookies and similar technologies in their games if the applicable law does not require consent.


    7.3 Advertisement partners

    Bizzon Case Ltd uses the services of multiple advertisers. These parties provide us with advertisements on the Bizzon Case Ltd website and are responsible for processing your personal data in this case. Nevertheless, in order to protect your privacy in this regard as much as possible, Bizzon Case Ltd has ensured that appropriate contractual measures are taken

  8. How can you contact us?

    If you have any questions concerning this Privacy Statement, or data collection in particular, please contact us at [email protected] or via: Bizzon Case Ltd 12-14 Ivan Denkoglu Street, Sofia, 1000

    Please let us know by email in advance if you prefer to have further contact over the phone via another preferred language. We will then provide you with the relevant phone number.

Changes

We may change this privacy statement from time to time to adapt to new technologies, industry practices, regulatory requirements or other purposes. The latest version can be checked at any time on the Bizzon Case Ltd website. Important changes will also be notified to you.