Undawn Website

www.undawn.game/gl

Privacy Policy

Last Updated: May 26, 2022

Thank you for visiting the Undawn Website (www.undawn.game/gl) (together with the sub-pages thereof and other webpages of Undawn linked therein, the “Site”)! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we collect?

If you contact us or subscribe for our newsletters, we will collect your name and e-mail address and other information you decide to provide us as part of your communication. More Information.

How will we use your information?

If you contact us, we use your e-mail address to get in touch with you.  If you register for our newsletters, they are sent to the e-mail address you provide. More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience. When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us operate and maintain the Site.  We may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in United States and Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including in Singapore and the United States. More Information.

How long do we keep hold of your information?

We only retain your personal information (i) for so long as you are a subscriber of our newsletter; and (ii) for two years on AIHelp’s servers, unless we are otherwise required to retain information to fulfil the purpose for which it was collected or in accordance with legal or regulatory obligations. More Information.

How can I exercise my rights over my information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: Proxima Beta Pte. Limited | Email: dpo_undawn@proximabeta.com 

EU Representative: Proxima Beta Europe B.V. Email: dpo_undawn@proximabeta.com

UK Representative: Image Frame Investment (UK) Limited Email: dpo_undawn@proximabeta.com 

Serbia Representative: Karanovic & Partners o.a.d. Beograd | Email: local.representative@karanovicpartners.com

Turkey Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı | Email: proximabeta@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters, such as bans, investigations, civil or criminal complaints.

Welcome to the Undawn Website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with your access to the Undawn Website (www.undawn.game) (together with the sub-pages thereof and other webpages of Undawn linked therein, the “Site”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop accessing the Site. By accessing the Site you are acknowledging the rules regarding your personal information as described in this Privacy Policy.

This Site has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Site is Proxima Beta Pte. Limited, which is a Singaporean company within our corporate group. The registered address of Proxima Beta Pte. Limited is 10 Anson Road, #21-07 International Plaza Singapore (079903). Our data protection officer can be contacted at dpo_undawn@proximabeta.com.

Our representative in the EU for the purpose of EU data protection laws is Proxima Beta Europe B.V., which is a Dutch company within our corporate group. The registered address of Proxima Beta Europe B.V.is Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands. Our representative in the EU can be contacted at dpo_undawn@proximabeta.com.   

Our representatives for data protection purposes in certain jurisdictions are as follows:

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo_undawn@proximabeta.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below. 

The following is a high-level summary of the types of personal information we use:

· Newsletter information (via Mailchimp SDK): If you subscribe for our newsletters, we will collect your e-mail address and transactional email information.

· Contact information: If you contact us, we will collect your name, e-mail address and other information you decide to provide us as part of your communication.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience on the Site. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

3. Children

Children must not access the Site for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age.  For users located in certain countries we have listed the relevant minimum age in the table below.

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_undawn@proximabeta.com and we will delete such information.

4. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, Thailand, Brazil or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

5. How We Store and Share Your Personal Information

Our corporate group operates around the world. Your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers are located in the United States and Singapore. In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the United States and Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties such as AIHelp and Mailchimp that provide services in support of the Site or its features. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the Site or its features. All related group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

6. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted via the Internet; any transmission is at your own risk.

7. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information. 

8. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Site, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, you may have other rights which apply. Certain rights are set out in the section Supplemental Terms – Jurisdiction-Specific below.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Argentina, India and Russia.

The sub-section entitled “Advertising” also apply to users that are located in Hong Kong, Macau, Malaysia, Singapore, Thailand, Argentina, Brazil, Cambodia, Egypt, India, Indonesia, Laos, Maldives, Mexico, Morocco, Myanmar, Philippines, Russia, Sri Lanka, Taiwan, Turkey, UAE, Saudi Arabia and Vietnam.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us at dpo_undawn@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_undawn@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us at dpo_undawn@proximabeta.com. 

Erasure

You can request that we delete your personal information by contacting us at dpo_undawn@proximabeta.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo_undawn@proximabeta.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_undawn@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. 

Announcements

We may from time to time send you announcements when we consider it necessary to do so. You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

You may choose to stop receiving newsletters or promotional information from us when using the Site by clicking here, by following the opt-out instructions included in the Settings section of the Site or by contacting us at dpo_undawn@proximabeta.com. 

9. Contact & Complaints 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_undawn@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_undawn@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

10. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

11. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for visitors of the Site, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Algeria

By using this Site, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (local cloud providers to back up your data or our affiliates around the world to help us deliver the Site) located in Algeria, Singapore, and the United States (as described in the Privacy Policy) where it is manually and electronically treated.

Argentina

Your rights

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar).

Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Site, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore and the United States.

Age Restriction

In order to use the Site, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

This section applies to users located in Brazil:

Language

This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact dpo_undawn@proximabeta.com. This may affect our provision of the Site to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Site for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Colombia

Language

This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy.

Proceedings For The Exercise Of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us.

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.

Egypt

This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.   

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Site.

You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular Singapore and the United States of America.

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at dpo_undawn@proximabeta.com. 

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Age Restrictions

Parental consent is required for children under the age of 18 years to use the Site.

Withdrawal Of Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_undawn@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Site.

Data Subject Rights

You have the right to access your personal information stored in our Site from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Site, we will notify you through the contact information provided by you or via the Site, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Site by unsubscribing or ceasing your use of the Site at any time, if you cease to agree with the amended  Privacy Policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export and storage of your personal information as described in this Privacy Policy including (without limitation) for the purposes of showing you advertising when you use the services.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Site to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Language

In the event of any discrepancy or inconsistency between the English version and Bahasa Melayu version of this Privacy Policy, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the Site.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Site, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. 

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Site to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

· Our data protection officer, responsible for the management and safety of your personal information

o Telephone: +603-22872388

o Email: dpo_undawn@proximabeta.com

Mexico

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

Age Restrictions

You won’t be able to use the Site unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section 1 "The types of personal information we use” and section 2 “How we use your personal information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you  personalised recommendations and advertising. We may also use your personal data for the voluntary purpose of sending information to your email that we may consider relevant to you. You may object the processing of your personal data for voluntary purposes as stated in the section “Your Rights” below.

Please, be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section 3 “How we store and share your personal information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 3 “How we store and share your personal information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Site and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights” below.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, and “Advertising” included in Section “Your Rights” above also apply to users that are located in Mexico.  

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at dpo_undawn@proximabeta.com. 

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at dpo_undawn@proximabeta.com.  

You can also register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising on your phone number.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data (detailed in the relevant sections above). You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Site may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie Policy.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Site.

By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Site.

Kindly note:

· the identity of the Data Controller is Proxima Beta Pte. Limited, email: dpo_undawn@proximabeta.com.

· the purposes of the processing for which the data is intended are set out in the table in the section “How we use your personal information”.

· recipients or categories of recipients are set out in the second paragraph of the section “How We Store and Share Your Personal Information”.

· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to the section “How we use your personal information” and the section “Your Rights” (sub-paragraph “Objection”).

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: dpo_undawn@proximabeta.com. 

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Site.

Your Rights

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

Qatar

If you are using the Site in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Russia

The Service is not directed at Russian users or Russian market and, in particular, is not available in the Russian language. However, if you happen to be using the Site in Russia, by using the Site you consent to:

· for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Site or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);

· the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore and the United States;

· for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and

· for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications.

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, “Objection” and “Advertising” of the section “Your Rights” above apply to users in the Russian Federation.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Site after the notification.

As regards the representative for Russia, you can contact us at dpo_undawn@proximabeta.com.  Please include the word “Russia” in the subject line of your email.

Separate consent for using certain data

By using the Service you also consent to the sharing of your personal information with certain third parties for the purposes set out under section 3 “How We Store and Share Your Personal Information”.

You determine, in your discretion, the terms of disclosure to the general public of your personal data by choosing to use certain features of the Service and by choosing the appropriate privacy settings in respect of your personal information in the Service.

We process your personal information subject to the terms of this Privacy Policy and your chosen features and settings.

This consent is granted for as long as you use the Services. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (dpo_undawn@proximabeta.com): please include the word “Russia” in the subject line of your email.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

· Name: Karanovic & Partners o.a.d. Beograd

· Address: Resavska 23, Belgrade, 11000, Serbia

· Telephone Number: +381 11 3094 200

· E-mail: local.representative@karanovicpartners.com

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, Singapore and the United States.

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_undawn@proximabeta.com. 

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact dpo_undawn@proximabeta.com. 

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo_undawn@proximabeta.com. 

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Site.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your personal information, we will provide you with our response to the request within 21 working days.

Personalised Marketing

By clicking “accept”, you hereby consent to being shown personalised advertisements. You may choose to stop receiving personalised advertising from us by following the opt out instructions included in the Settings section of the Site or by contacting us at dpo_undawn@proximabeta.com. 

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Site platform. If you are under 7 years of age, please do not attempt to use or register for our Site or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Site. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Site.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Site.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo_undawn@proximabeta.com. 

We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

· learn whether or not your personal data has been processed;

· request information about processing if your personal data has been processed;

· learn the purpose of processing of your personal data and whether they have been used accordingly;

· know the third parties in the country or abroad to whom personal data has been transferred;

· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and

· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy, including (without limitation) for the purposes of showing you advertising when you use the Site.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy, including (without limitation) for the purposes of showing you personalised advertising when you use the Site.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.    

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, it will disclosed upon receipt of written request from such organisations.

Your Rights

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.