Privacy Policy

Effective as of: September 01, 2023

1. Introduction

a. This Policy covers the services that are offered by the Vameon Software Design, a Dubai International Financial Centre (“DIFC”) company, license number 1052671 (“Vameon”, “Company”, “we,” “our,” or “us”).

In this Privacy Policy, the Controller or Controllers (“Controller”) of your Information means the company that decides the purposes for which it is processed and how it is processed. Which company is the Controller in relation to the processing of your Information will depend on which services you are using; it will often be the company responsible for providing these services, as may be set out in our terms and conditions.

This Policy applies only when those Vameon Services are linked to this Policy or tell you it applies.

In some circumstances, more than one Controller may be responsible for processing your Information, for example, where Information is shared with other companies for a purpose set out in this Privacy Policy. If you still have questions about the relevant Controller, please contact us using one of the methods set out below.

It’s up to you to decide how much detail you want to know. We have just-in-time explanations that appear when we ask you to input your personal information. As well as what’s in this Policy, a service might have a short privacy notice. In that privacy notice you can find key information on what we do with your personal information when you use that service. And if you’re after more detail have a look at these topics.

Scope of Application of the Privacy Policy. This Privacy Policy together with our Terms and any additional provisions that may be incorporated by reference into the Terms apply to your use of our website, applications or services, including, without limitation, Vameon Game(s), including the game “dEmpire of Vampire”” (“Vameon Services”).

b. Contents of the Privacy Policy. This Privacy Policy sets out the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

c. To agree with this Privacy Policy, you must be an adult of the legal age of majority in your country of residence. By accepting this Privacy Policy, you acknowledge and affirm that you are of the legal age of majority in your country of residence and that you are legally and financially responsible for all actions using or accessing the Vameon Services, whether or not authorized by you.

If you are under the legal age of majority in your country of residence (“minor” or “child”), you may not agree to this Privacy Policy. Your parent or legal guardian must review this Privacy Policy and accept it on their own behalf. Subject to any applicable laws, regulations or rules regarding minors, a parent or legal guardian who has accepted this Privacy Policy on their own behalf may permit a minor to use Vameon Services, provided that the parent or legal guardian acknowledges and agrees that they are legally and financially responsible for all actions using or accessing the Vameon Services, including the actions of any minor or child they allow to access their user account, whether or not authorized by the parent or legal guardian.

2. Information about Whom is Collected

a. This Policy covers the collection and processing of Information received from:

Non-registered users of the website;
Registered users of the Vameon Game(s);

b. From non-registered users of the website we may automatically receive the following Information about a device these users are using to access our website:

IP (internet protocol) address;
device information;
device ID;
app ID;
vendor ID;
advertising ID;
IP address;
Information about nearby cell towers and Wi-Fi access point information;
cookies.

What type of location data (for example Country, Region, City or Town) is collected depends on the product or service your using, the device you’re using (for example Apple or Android) and your devices settings (whether permissions are enabled or disabled). You can change your permissions on or off any time in your device’s settings.

c. From users, who request additional paid Vameon Services from us using Vameon Game(s) by using Third-Party Payment Systems we may receive from these Payment Systems as much Information about the counterpart of a transaction as stated in privacy policies of these Third-Party Payment Systems and collected by them, so please read these policies before finalizing transaction. We usually do not receive such information on a specific transaction from Payment Systems or other third parties so if we receive it, it is necessary for immediate use or legal investigation and it will not be retained long than it is necessary for such purposes.

d. We do not gather any additional personal information about you, unless you provide us with it on your own by email, Social Media Sites or other means of communication.

3. Data Retention

In broad terms, we will only retain your Information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of Information and the reason that we have collected the Information in the first place. For example, some Information related to the provision of Vameon Services to you or to receiving any payments from you will be kept for a number of years in order to comply with various finance and tax related legal obligations. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defense of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.

4. How Do We Use Personal Information

a. We have to have a valid reason to use your personal information – lawful basis for processing or your consent provided according to this Privacy Policy. Sometimes we may ask your additional permission to do things, like when you subscribe to an email. Other times, when you’d reasonably expect us to use your personal information, we don’t ask your additional permission, but only when:

the law says it’s fine to use it, and
it fits with the rights you have.

b. We use your information for these purposes:

to run our business, deliver our services and to provide you with information about them;
to facilitate payments;
to deal with your requests, complaints and enquiries;
to help us understand what kind of services you may use;
to research and innovate. We may use your Information for the purpose of analyzing, improving, personalizing and evaluating Vameon Services and your use of them, as well as to develop new services. This may include analyzing your responses to consumer surveys;
to contact you about various things including customer support services – including dealing with your queries and complaints (including troubleshooting), whether you contact us by the website, telephone, email or social media websites;
to detect, prevent and investigate criminal and other illegal activities;
to comply with legal obligations, including accounting rules, responding to requests from regulators, judicial authorities and law enforcement or governmental bodies.
to exercise and/or enforce the rights granted to us under the Terms of Service.

c. We may use your information to contact you about different things, like:

to update you on any changes to the Vameon’s policies, practices and Terms of Service;
to answer you when you’ve contacted us, or to respond to a comment or complaint;
to invite you to take part in surveys about Vameon Services, which are always voluntary;
to send you notifications on your device depending on your settings.

We’ll only contact you when we need to or when you’ve given us permission.

5. Consent

a. Before using our website or Vameon Game(s), please indicate that you agree on our processing of your Personal Data as the User.

b. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE THE WEBSITE AND VAMEON GAME(S).

c. Once you provide consent, you may change your mind and withdraw consent at any time by contacting us at [email protected] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

6. Information Sharing and Disclosure

We share Information with and disclose it to the following parties, for the purposes set out below:

Third Party Service Providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of Vameon Services, conducting marketing, providing IT services and security, handling payments, conducting research, measurement and analytics, deriving insights, or customer service.
Linked Third Party Social Media Sites. Some of Vameon Services may contain links to other sites, including Social Media Sites, for the purposes of customer interaction and marketing. The information practices of the Social Media Sites can be different from ours so you should consult their privacy policy and terms before submitting your personal information, as we have no control over personal information that is submitted to or collected by these third parties.
AdTech Providers. We may share certain Information with third parties (e.g. other companies, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, participatory databases, publishers, and non-profit organizations) for processing generally in a hashed or de-identified form, to provide advertising to you based on your interests, including where applicable, through real-time bidding. In some instances, we may also share segments or custom audience data with third parties for marketing purposes.
Other third parties. In the event of a likely change of control of the business (or a part of the business) such as a sell, a merger, and acquisition, or any transaction, or reorganization, we may share your Information with interested parties, including as part of any due diligence process with new or prospective business owners and their respective professional advisers.
Law enforcement bodies, the authorities and courts. We disclose Information where necessary for the prevention, investigation or prosecution of criminal activities, and also in response to legal process, e.g. in response to a court order or a subpoena, or in response to a regulator, government authority or law enforcement body’s request.
We may also disclose your Information: (i) to enforce or apply any other agreements, including but not limited to for billing and collection purposes; or (ii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, including but not limited to exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. International Transfer

We are a UAE-based company with several other affiliated companies. We operate internationally, and some of the processes involved in our use of your Information will require your Information to be stored or processed in countries outside the country where you are located, including countries where the level of legal protection for your Information may be different and where you may have fewer legal rights in relation to it.

8. Individual Rights

a. Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.

Right to access and rectification: You can request details of the Information we hold, along with a copy of your Information, and the correction of any errors in your Information.
Right to erasure (“right to be forgotten”): The right, in certain circumstances, to ask for your Information to be deleted. In specific cases, we may not be able to delete some types of Information, in particular, where we have a legal obligation to keep that Information (e.g. for regulatory reporting purposes).
Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes.
Right to portability: The right in some cases to receive your Information in a digital format or to have it transmitted directly to another controller (where technically feasible).
Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Information on the basis of our legitimate interests, including for direct marketing purposes.
Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of Information which is based upon a consent.

b. We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Customer Support Officer, please submit a request to [email protected].

9. Automatic Data Collection Technologies and Cookies

a. As you use Vameon Services or interact with any of our advertising materials on third party services, we may use automatic data collection technologies to collect certain information about your equipment, interactions with our website or Vameon Game(s), and patterns, including, without limitation: (a) details of your usage of Vameon Services, including our website, including traffic data, location data, and other communication data and the resources that you access and use of the Vameon Services; and (b) information about your device and internet connection, including your IP address, operating system, and device type.

b. The technologies we use for this automatic data collection may include, without limitation:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website or Vameon Game(s).
Flash Cookies. Certain features of Vameon Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website or Vameon Game(s). Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related websites.
Tracking Pixels. Certain features of Vameon Services may use tracking pixels to allow us to advertise more efficiently by excluding certain users from promotional content or delivering advertisements on other websites.
Google Analytics and Other Similar Services. We may use Google Analytics and other similar services that use cookies to help us analyze how users interact with our website or Vameon Game(s) and improve your experience in it.

c. Cookies are used:

to remember information about you, so you don’t have to give it to us again;
to keep you signed in, even on different devices;
to help us understand how people are using our services, so we can make them better;
to deliver advertising;
to help us personalize the website or Vameon Game(s) to you by remembering your preferences and settings;
to find out if our emails have been read.

d. Some cookies are always on when you visit us, and you can’t turn them off unless you change your browser settings. These are strictly necessary cookies. We use them to make sure our website or Vameon Game(s) work correctly and are meeting audience needs and interests.

We also use functional, performance and advertising cookies to make your experience more enjoyable. You can switch these on or off at any time and you can always change your mind. We’ll only use them if you’ve agreed.

Bear in mind there are some other cookies out there from other companies. These “third-party cookies” may track how you use different websites, including ours. For example, you may get a social media company’s cookie when you see the option to share something. You can turn them off, but not through us.

e. Some cookies are erased when you close the browser on your website or app. Others stay longer, sometimes forever, and are saved onto your device so that they’re there when you come back.

f. Strictly necessary cookies are always on when you visit our website or start Vameon Game(s). On your first visit, we’ll tell you about our other types of cookies and ask you to choose which cookies we can use. You can always change your mind by going to your settings.

Stopping all cookies might mean you can’t access some Vameon Services, or that some of them might not work properly for you.

10. Third-Party Use of Cookies and other Tracking Technologies

a. Some content or applications, including advertisements, on our website or in Vameon Game(s) are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use Vameon Services. The information they collect may be associated with your Information or they may collect information, including Information, about your online activities over time and across different websites and other online services.

b. Among content and applications served by third-parties, we may use, without limitation, the following services:

GameAnalytics. Please visit their website for further information on their privacy practices – gameanalytics.com/privacy;
GameSparks. Please visit their website for further information on their privacy practices – gamesparks.com/privacy-policy;
Slack. Please visit their website for further information on their privacy practices – slack.com/privacy-policy;
Unity3D. Please visit their website for further information on their privacy practices – unity3d.com/legal/privacy-policy;
AppsFlyer. Please visit their website for further information on their privacy practices – appsflyer.com/services-privacy-policy;

c. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

11. Safety

a. We do our best to guarantee the safety and confidentiality of your Information. We use physical, administrative and technical measures to prevent theft, leakage, unauthorized access to your Information. Your Information:

is stored on publicly inaccessible servers;
is encrypted (password protected);
is available only to employees with appropriate access and is not accessible to the rest of our personnel.

b. Nevertheless, despite the caution and means of protection, you should know that we cannot be responsible for the safety of your Information when transmitting / receiving over the Internet or wireless means.

c. You are responsible for the security of Information through the creation of a strong password, its safety and inaccessibility to third parties. If you suspect a security breach of your data, you must inform us immediately.

12. Changes to our Privacy Policy

It is our practice to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Information, we will notify you by updating our Privacy Policy on the website and in Vameon Game(s). Any changes will be automatically effective after 30 days of update on the website and in Vameon Game(s). You are responsible for periodically visiting our website and in Vameon Game(s) and this privacy policy to check for any changes.

13. Governing Law And Dispute Resolution

This Privacy Policy and any dispute arising hereunder will be governed by the laws of England and Wales without regard to its choice of law or conflicts of law principles. Both you and the Company agree that all claims and disputes arising out of or relating to this Privacy Policy will be litigated exclusively in the courts located in UAE.

14. How to Contact Us

If you have any questions about this Privacy Policy, you can contact us and our Customer Support Officer by email: [email protected] or by post: Vameon Software Design, Office 102-A5, NASER AHMED SAEED MHD AL AWADHI BUILDING, Al Garhoud, Dubai, UAE.