LAST UPDATED: 10th August2022
DEFY Labs Pte Ltd is a subscription-based business, providing applications, smart technology and a user experience that is built on artificial intelligence, gamification and premium content. DEFY Labs Pte Ltd, its subsidiaries, parent companies, affiliates, joint ventures and other corporate entities under common ownership (collectively, “we”, “our”, or “us”) take our users’ (“users” or “you”) privacy rights seriously.
Personal Information and Non-Personal Information
Personal information also does not include “aggregate information”. Aggregate information is data we collect about the characteristics and activities of the users and visitors of the Services and enhance our Services and our sites, from which any Personal Information has been removed. Such information may include demographic information, such as your unique user or user identifier (when not matched with or tie to your Personal Information), city of residence, information about your computer, software, platform and Internet IP address. We collect aggregate information about the use of the Services to provide the best possible service and allow us to make certain recommendations and internal reports and share such information with our partners about how our customers use the Services so that our partners also understand how people use the Services and they can provide you with an optimal user experience.
We may combine Personal Information and Non-Personal Information to be used to improve your experience with or to aggregate it with information collected from other users to improve or analyze the Services.
How Personal Information Are Collected
I. INFORMATION COLLECTION AND USE
To assist us in personalizing and improving the Services, and allow our users to set up a user account and profile that can be used to personalize their experience in using the Services, Personal Information are collected from you.
We may collect your Personal Information in a number of ways such as, during your (1) registration or log-in for games, games subscriptions or our websites, (2) creation of a personal profile, (3) customer support or technical service requests, (4) purchase of a license to use in-game virtual money or virtual items directly from us, any relevant billing and financial information necessary to process your charges will be collected by us, which may include your email address, (5) download and use of our mobile applications and web-based applications, (6) request for services from third party service providers on our websites or the Services (such as, your response to advertisements therein), (7) communications with other registered users on our websites or through the Services, and (8) participations in promotional or marketing activities, surveys, and other alerts. Depending on the activity in which you are involved, information that we collect from you will vary.
What about Cookies? – We collect certain technical information when you use the Services in order to (i) manage advertising; (ii) analyze the usage of our sites and services; and (iii) provide a more personalized experience. We and our service providers use tracking technologies to collect and analyze certain types of technical information, including cookies (cookies are small files applied to your browser to track movements within websites), platform type, IP addresses, device and identifiers, domain names, landing pages, the number of clicks, the amount of time spent on particular pages, pages viewed and the order of those pages, URLs, browser types and language, referring and exit pages, game state and the date and time of activity on our sites or games, and other similar information. For our internal use, we may also associate this information with your user ID number. However, please note that we do not combine the general information collected through cookies with your other Personal Information to inform us your identity or what your email address or screen name is.
Other technologies may also be used by us, which include: (i) flash cookies (which help us in preventing fraud, remembering your in-game preferences and speeding up load times); (ii) tracking pixels (which permit us to advertise more efficiently by (a) not serving certain promotional messages to our current users, (b) identifying the source of a new installation or (c) delivering advertisements to you on other websites); and (iii) web beacons (which assist us in determining if a certain page was visited or whether an e-mail was opened).
When you download and use any of our games on your mobile device or on a personal computer, we also collect information regarding your in-game actions, your user identifier or unique device and country in which the mobile phone or device is registered or located, and may collect your mobile phone number, and other information you provide, such as user name, or e-mail address. When our mobile or web-based applications are used, we also collect information about your mobile device type, operating system, IP address and browser type. For Android games subscriptions, you are required to let us have your email address and consent to let us use it to contact you before you can download and use any of our games. We use such information in relation to providing our mobile and web-based applications, such as to authenticate you and to communicate with you regarding the Services by push notification, SMS, e-mail, text message or other electronic means to your mobile device. By using the Services, you agree to letting us retain all the above information in any form as we see fit. We only collect information to the extent that is reasonably necessary to comply with your requests and our legitimate business objectives.
How and Where Personal Information Are Stored, International Transfer and Personal Information Security
We also understand that it is important to keep your information safe and secure. Commercially reasonable security measures to safeguard and secure your information and to prevent the destruction, loss, misuse and alteration of information under our control have been implemented by us. We do not believe that there is any transmission method over website or Internet that is completely flawless, even though our commercially reasonable security measures have been put in place against possible breaches of our sites’ security and our user records and databases. We are not liable for data loss, hacking, unauthorized access or other breaches in relation to our servers and systems or guarantee the security of user account information. You transmit your information to our sites at your own risk. After we receive your information, we have procedures and security measures in place to attempt to prevent any unauthorised access. You also have the obligation to limit access to your computer (or other device) and browser by logging out after you have finished accessing your account to ensure that there is no unauthorized access to your account and Personal Information.
How Personal Information Are Used
We may use your Personal Information, Non-Personal Information or aggregate information collected from you in any one or more of the following ways to: (1) provide advertising and promotional information in connection with the Services; (2) prevent fraud or potentially illegal, unethical or legally actionable activities, and enforce the relevant terms of service; (3) notify you of new game releases or updates; (4) operate, maintain and manage the Services; (5) provide to government or law enforcement officials to protect our rights and property as well as those of third party and protect the safety of the public or any person; (6) solicit feedback and input to improve the Services, including our websites, products and services and personalize your user experience, diagnose problems with our server and develop new product and services; (7) communicate with you about the Services; (8) provide technical support and respond to user requests; or (9) if you consent or do not object to our use of your Personal Information in direct marketing (please see further details in the “Use of Personal Information in Direct Marketing” section below), conduct direct marketing activities, such as sending you offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.
Use of Personal Information in Direct Marketing
From time to time, we may conduct direct marketing of the Services through email, direct mails, telemarketing, fax and/or other form of communication to you. We intend to use your Personal Information for direct marketing carried out by us or one of our business partners or third party merchants. For the purpose of direct marketing, we shall use your name (including surname and given name), address, telephone number, email address and other information, if any, that you provide to us for offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.
Please note that we may not use or provide your Personal Information to others for direct marketing purposes unless exempted by the relevant regulations or we have received your consent (which includes an indication of no objection).
You may indicate your consent to the above by ticking the box(es) indicating your consent contained in the relevant communications. If you do not wish (i) any of your Personal Information to be used in any of the described direct marketing activities, or (ii) to receive from us (a) any promotional and direct marketing materials, (b) any particular types of promotional and direct marketing materials, and/or (c) such materials through any particular means of communication, you can at any time opt-out, free-of-charge, by contacting us at email@example.com, following the “opt-out” instructions contained in the relevant communications, or following the instructions in the “Your Options” section below.
How Personal Information Are Shared
In general, we do not sell or rent your Personal Information to other third parties. Your Personal Information is only shared in the following circumstances:
Responses to User Submissions
We may send email and other communication to you relating to your User Submissions as part of the Services. You agree that by posting such User Submissions, you may be receiving email and other communication from us that we determine in our sole discretion relate to your User Submissions.
We may display your user profile information including your username and other information entered by you (“User Submissions”) to other users to facilitate user interaction within the Services.
With Your Consent
Our games may display a third party hosted “offer wall”. Such offer wall allows third party advertisers to provide virtual money to users and in return such user will respond to an advertisement or complete an advertisement offer. Such offer wall may appear in the games and be displayed to you based on certain information, such as your geographic area or demographic information. When you click on one of these offer walls, you will leave our or our partners’ site at the time. A unique identifier, such as your user ID number, will be shared with the offer wall provider in order to prevent fraud and properly credit user accounts.
You agree that any of the information we have collected from you (including information you may have decided not to show to other users) may be used by us to choose or allow the advertisers to choose the appropriate audience for their advertisements.
Transfers of business
Affiliated businesses that we do not control
A variety of businesses may become affiliated and work closely with us. Through the Services, items may be sold to you by such affiliated businesses, and services or products may also be provided or sold to you by us jointly with such affiliated businesses. You can recognize when an affiliated business is associated with your transaction, and we may share your Personal Information that is related to such transactions with that affiliated business.
Protection of our rights and those of others
If we believe in good faith that the release of your Personal Information is necessary to comply with the relevant law and regulation, enforce or apply our conditions of use and other agreements, or protect our rights, property, or safety, or those of our employees, users or others, we may do the same. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Policies Regarding Children Under The Age of 13
Please note that this “Policies Regarding Children Under the Age of 13” section only applies to procedures when collecting information from children under the age of 13.
We recognise the obligation to protect Personal Information obtained from young children. The Services are not geared toward children under the age of 13 and we do not knowingly collect any Personal Information from such children other than those stated in this section. If we collect any personal information (as defined in the Children’s Online Privacy Protection Act (“COPPA”), which was established by U.S. Congress to protect children’s online privacy) from children under the age of 13, we will either (1) comply with the requirements of COPPA and gain prior verifiable parental consent or direct parental notification of the nature and intended use of such information, which shall include an opportunity for the parent to prevent use of the information and participation in the activity; or (2) take all reasonable steps to promptly remove from our files and records such information. For more information about COPPA and children’s rights to online privacy, please visit the Children’s Privacy section of the Federal Trade Commission’s website at www.business.ftc.gov/privacy-and-security/childrens-privacy.
In addition, we advise that children over the age of 13 shall ask their parents for permission before transmitting any of their information to anyone over the Internet, and we suggest parents to tell their children not to provide their personal information, without permission, when using the Internet.
What types of information do we collect from children?
We mainly collect persistent identifier (such as an IP address, mobile device id, or a unique device identifier) from the child.
Please note that all sites that are directed to children under the age of 13 are prohibited by COPPA from conditioning a child’s participation in an online activity on the child’s disclosure of more personal information than is reasonably necessary to participate in the activity.
How do we use and share the personal information collected from children?
We use the collected persistent identifier for the sole purpose of providing support for internal operations of the Service, including activities necessary for us to maintain or analyze the functioning of the Services, authenticate users or personalize content, serve contextual advertising or cap the frequency of advertising, protect the security or integrity of the user or the Service, or ensure legal or regulatory compliance.
The collected persistent identifier is not shared with other third parties. However, we may, from time to time contract with certain third party service providers to provide support for the internal operations of the Service. Your personal information is not used or disclosed by these contracted third party service providers except for the limited service for which they have been contracted.
We collect a child’s email address in connection with a question emailed to us by the child for the sole purpose of communicating with the child on a one-time-only basis (e.g. responding to a question from the child). We will not use or disclose such information to re-contact the child or for any other purpose, and such information will be deleted from our records promptly after responding to the child’s request. If we choose not to respond to the child’s request, we will immediately delete the child’s information.
How can parents review or delete personal information about their child?
At any time, parents of children under the age of 13 may review or delete personal information about their children from our records, or refuse to permit our further collection or use of such personal information. Please contact us at firstname.lastname@example.org if you would like to review or delete your child’s personal information, or to inform us about your refusal to permit our further collection of such personal information.
Whenever a parent requests a deletion of his or her child’s personal information, we will use reasonable efforts to delete the child’s information from our records as much as possible and will not collect any other personal information from such child. Please note that there may be residual information that will remain in our records that may or may not contain the personal information that was requested to be deleted. Such residual information will not be disclosed or shared with any other third party or used for any commercial purpose.
DEFY Labs Pte Ltd
Ellen L. Skelton Building, Fishers Lane, Road Town, Tortola, British Virgin Islands.
or send us an email at: email@example.com
Linked Third Party Sites’ Privacy Policies
The Services may also contain other third party service providers’ tracking tools. We may use such third parties’ APIs/SDKs in providing the Services to you, which may allow these third parties to analyze user information. Although these third parties may have access to your Personal Information when services are performed for us, they may not use such information for any purposes other than to provide their services.
How Personal Information Are Accessed or Amended
Any Personal Information collected and held by us may be accessed or amended by you by changing the relevant information through our sites. You may contact us at firstname.lastname@example.org if you decide to close your account(s). We will review, update, correct or delete the relevant information as appropriate and your information may still be retained in our systems for enforcing our user agreement, maintaining the security, integrity and operation of our sites and the Services and resolving any disputes.
If you would like to know what kind of information we are storing regarding your user, please email email@example.com and use the subject: “User Data”.
If you would like your personal data deleted, please email firstname.lastname@example.org and use the subject: “Delete User”.