Effective Date: August 1, 2019
1. Whom this notice applies to
This privacy policy (the “Privacy Policy”) describes how the proprietors of www.SBDplay.com (“we/us/our”) collect and use the personal information of visitors to and users of (“you/your/users”)www.SBDplay.com (the “Website”) as well as the iOS and Android applications (each, an “App,” together, the “Apps”). By accessing or using the Website, the Apps and/or the services offered through the Website and the Apps (collectively, the “Services”), you consent to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use our website or services.
Personal information is information about an identifiable individual (“Personal Information”). We collect Personal Information when you voluntarily provide it through our Services, or when you provide it to us through other means.
The Privacy Policy was last changed on August 1, 2019.
If you have any questions about the Privacy Policy, please email us at: privacy.officer@sbdplay.com
2. Why we collect Personal Information
We collect, store, and use your Personal Information to allow, facilitate, and improve access to the Services and for the purposes set out in more detail in section 4.
3. Legal requirements
We are required to collect parts of the Personal Information in order to comply with certain legal obligations, including, but not limited to, anti-fraud and know your customer (“KYC”) laws. If such information is not provided, we cannot agree to provide a product or service for you.
We may also collect your Personal Information and disclose it to law enforcement bodies or regulatory authorities upon reasonable request thereby, or pursuant to defending a legal claim.
We will retain Personal Information related to an investigation or a dispute until the issue is resolved.
4. What Personal Information we collect and how we use it
(a) We may collect the following information from users:
- IP address;
- device information (e.g. operating system, device identifiers, and mobile network system);
- Website usage data, such as webpages viewed, viewing time, click information, and other analytical data;
- error logging, event recording, and user experience data;
- hardware and browser settings;
- requests made;
- time and date of requests;
- the pages visited and search terms used;
- location information;
- email address;
- your full name
- billing address
- shipping address;
- date of birth;
- age;
- gender;
- any Personal Information posted on our social media accounts;
- any Personal Information provided when users enter our contests and giveaways;
- whether our emails were received and whether hyperlinks therein were accessed;
- marketing preferences; and
- and any other Personal Information that you choose to submit to us
We may also collect Personal Information about you from other sources.
We obtain this information from sources such as:
- our business partners;
- third party service providers, such as Google AdSense;
- other users of the Services;
- banking or other financial services providers; and
- publicly available sources
4(b) We may use your Personal Information to:
- deliver our Services to you;
- register your account on the Services;
- to verify and authenticate your account information;
- to supply you with requested goods, products, or services, including the use of our online store;
- to send you informational, administrative, or promotional communications
- alter and develop new services based on: the information collected, user behavior, and users’ technical capabilities;
- improve our services to better suit the behaviors and technical capabilities of the users;
- identify and remedy issues with the Website and our services;
- monitor the way the Website and the Apps are used (including, but not limited to, access points, access methods, and peak usage times);
- enter into, administer, and complete any and all contracts we enter into with users, including but not limited to verifying entries and winners, awarding prizes won by users in our contests and giveaways;
- administer games we run on the Website and the Apps;
- to publicize information concerning winners of our contests, giveaways, and games (for example, such information might be posted on our blog, vlog, or social media);
- to verify compliance with the official rules applicable to each contest, giveaway, or game;
- to verify compliance with our Terms of Service;
- to conduct investigations;
- to respond to inquiries and provide you with customer support;
- to increase the security and safety of our Services and users;
- to perform analytics on our Services;
- for any other purposes that are disclosed to you and to which you consent; and
- for any purpose required by law.
4(c) Our collection and use of your Personal Information aids our legitimate interests in managing our business and the Website. Our legitimate interests include, but are not limited to:
- tracking traffic to the Website and the Apps to ensure the future viability of our business and the Website;
- understanding how users use the Website and the Apps;
- understanding which services users value;
- improving the functionality and content of the Website and the Apps;
- ensuring the Website, the Apps and our network are safe and secure; and preventing fraud.
4(d) How we collect information through technological means
When you use the Services, we may collect information that is automatically sent to us by your web browser. This information may include your domain name, and your numerical IP address. We may also collect other information, such as the type of browser you use, which pages you view, and the files you request. We may also collect software and debug information, information from API access tokens, and referral website addresses through Apache webserver stats.
We use this information to improve our understanding of how users use our Services, to improve our Services, and attract more users. We may also use the information collected for our own research and development purposes.
The amount of information that is sent to us by technological means depends on your browser or device and settings you use. Please refer to the instructions provided by your browser or device if you want to learn more about what information it sends to Services you use, or how you may change or restrict this.
We and third parties we partner with may use cookies and other similar technological means (collectively, “Cookies”) on our Website to help us collect information through technological means. These technological tools may track or collect information such as: (i) IP addresses; (ii) the type of web browser and operating system used; (iii) and the pages of the Services visited.
We use Cookies for a number of different reasons:
- to improve functionality and performance of our Services, including tailoring our Services to increase relevancy of content displayed to you;
- to facilitate your transactions on the Services;
- to authenticate users of our Services;
- to provide us with insights on how users use our Services and other analytics, such as traffic on our Services;
- to remember your settings and preferences; and
- to deliver relevant advertisements to you based on your interests, preferences, and activities. Cookies also help to avoid delivering the same advertisements to you too many times and to measure the usefulness of advertisements you have been delivered. Information gathered by Cookies may be shared with third parties, including advertisers. This means that sometimes you’ll see our Services advertised elsewhere on the internet.
We obtain your consent to our Cookies by providing you with transparent information in our privacy policy and providing you with the opportunity to make your choice. You have the right to object to the use of Cookies. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective in relation to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s website (www.adobe.com).
Please be aware that if you disable or remove Cookies some parts of our Services will not work and that when you revisit our Services your ability to limit cookies is subject to your browser settings and limitations. You can also find out more information about managing, disabling, and deleting cookies at www.allaboutcookies.org.
5. How long we retain Personal Information
We retain Personal Information as long as it is reasonably necessary, this includes, but is not limited to, retaining the information until we have complied with all legal, accounting, and reporting requirements.
6. What information we share
There are certain circumstances in which we transfer your Personal Information, or parts thereof, to our employees, contractors, service providers, and/or other third parties (collectively, the “third parties”). These third parties may process your personal data for us, and the parts of the information we provide to the third parties will only pertain to the function of each third party.
The third parties will not be permitted to use your Personal Information for any purposes other than those outlined in this Privacy Policy. When we transfer your Personal Information to a third party to provide administrative, processing, or other services, we use appropriate measures to require that the party will only use your Personal Information to perform the services we specified.
We reserve the right to transfer Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We may also disclose your Personal Information for any other purpose permitted by law or to which you consent.
We may disclose your Personal Information in the good faith belief that such action is necessary to:
- To protect and defend our rights or property;
- To prevent or investigate possible wrongdoing in connection with our products or services;
- To protect the personal safety of our customers or the public; or
- To protect against legal liability.
7. Where the information is stored
In some cases, your information, including Personal Information, may be transferred to — and maintained and processed on — computers located outside of the Republic of Panama. Therefore, your Personal Information may be available to government authorities under lawful orders and laws applicable in those foreign jurisdictions.
8. What rights you have
You have certain rights in relation to the information, described in more detail below. Some of these rights will only apply in certain circumstances.
- Request: you are entitled to ask us if we are collecting and processing your information.
- Access: If we are processing your information, you may request access to your information, and receive a copy of the information pertaining to you.
- Correction: you may request that any inaccurate information about you is corrected.
- Erasure: you may request that we delete or remove your information, but we may refuse such requests if, for example, the personal data is required for compliance with any legal obligation or is connected to any claims.
- Transfer: you may request the transfer of your information to another party.
-
Objection: where
we are processing your personal information based on a legitimate
interest (or those of a third party) you may challenge this.
However, we may be entitled to continue processing your information
based on our legitimate interests or where this is relevant to legal
claims.
- You may also object to collection of your personal information for direct marketing purposes.
9. Our direct marketing practices
We may use the information you give us on the Website for direct marketing purposes to provide communications of interest to you. We will only do this with your consent (where required by law).
You can opt-out of receiving directing marketing from us at any time. You can do this by contacting us at privacy.officer@sbdplay.com.
10. Our use of third-party tools
We use third-party tools to personalize what is displayed to you on the Website and through the Apps.
We use third-party tools, including programmatic advertising and retargeting, to make the content of the Website more relevant and interesting to you.
For this purpose, we use cookies, web beacons, or similar technologies to collect information about your browsing behavior.
11. Our security measures
In order to protect your information, we have implemented physical and technical safeguards to prevent unauthorized access to the information.
12. Links to third-party Websites
The Website, the Apps and our communications with you may contain links to third-party websites.
Those websites are not subject to this Privacy Policy. The collection, retention, and treatment of your personal data by such websites is not our responsibility.
Such third-party websites may have their own privacy policies, detailing their own obligations and practices with respect to the collection, retention, and treatment of personal data.
14. Children may not submit personal information
OUR PRODUCTS AND SERVICES ARE NOT INTENDED FOR INDVIDUALS UNDER 18 OR THE AGE OF MAJORITY, WHICHEVER IS OLDER. IF YOU ARE UNDER THIS AGE, YOU MUST NOT ACCESS OR USE OUR PRODUCTS OR SERVICES AT ANY TIME OR IN ANY MANNER.
We do not knowingly collect any information from any persons under the age of 18. If you are under the age of 18, you may not submit any personal information to us.
We do not knowingly collect any information from any persons under the age of 18. If you are under the age of 18, you may not submit any personal information to us.
If you have reason to believe that we are in receipt of personal information pertaining to a person under the age of 18, contact us at privacy.officer@sbdplay.com and we will take appropriate steps to delete this information.
15. Privacy Contacts
If you have any questions or concerns about this Privacy Policy or the handling of your Personal Information, if you wish to withdraw your consent to our use or disclosure of your Personal Information, or to request access to or update any of your Personal Information we have on file, please contact our Privacy Officer at:
Privacy Officer:
Sandra Blanco
Privacy Officer Address:
PH Torre Banco Panama – Peso 15
Blvd. Costa del Este y Ave. La Rotonda
Costa del Este, Apartado 0832-00429
Panama City, Panama
16. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. Any changes will be posted on our Website. We will let you know via email and/or a prominent notice prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. Please check from time to time to ensure you are aware of our current policy.
