Last Updated: September 16, 2021

PLEASE NOTE THAT YOUR USE OF AND ACCESS TO OUR SERVICES ARE SUBJECT TO THE FOLLOWING TERMS; IF YOU DO NOT AGREE TO ALL OF THE FOLLOWING, YOU MAY NOT USE OR ACCESS THE SERVICES IN ANY MANNER. YOU HAVE THE RIGHT TO WITHDRAW ANY CONSENT PROVIDED PURSUANT TO THIS PRIVACY POLICY AT ANY TIME, BY EMAILING US AT LEGAL@BBUMGAMES.COM.

 

Introduction/General

Beach Bum Ltd. and its affiliates (“we” or “us”) provide game services and features included thereon (the “Services”). Protecting your privacy and personal information are of great importance to us. This Privacy Policy explains what information we collect about you while using the Services and why, what we do with that information and how we handle the information.

 

Information Collected

When you are using the Services, we may collect information about you based on your user type (“Guest” or “Facebook User”) in three ways: information you provide us, information we collect automatically and information we collect from third parties.

For Guests and Facebook Users:

We collect the following information about all users:

  • Information you provide us:

    • User nickname

  • Information collected automatically:

    • Information about your use of our Services, your interaction with us and with other users, device information such as operating system and browser type and device identifiers

    • Computer, mobile device, and connection information such as your IP address, the URL accessed, platform type, web log information and mobile device identifier

    • Game state and the date and time of activity on our games

  • Information from Third Parties:

    • Information from third party sites or apps connected to your account such as Facebook profile information including full name, profile picture, email address, gender, user ID, country and information from advertisers

 

For Facebook Users:

In addition to the information collected above, if you log in to the Services using Facebook, we also collect and receive the following information:

  • Information you provide us:

    • Profile photo

    • Username (first and last name)

    • Your user ID number (like your Facebook ID number), which may be linked to publicly available information like your name and profile photo

    •  Gender

    • Age or age range

    • Location information

    • Social network links

    • Details about other games you play

  • Information from Third Parties:

    • Information from third party sites or apps connected to your Facebook account including: Facebook profile information, full name, profile picture, email address, gender, user ID, country and information from advertisers

  

Use of Information

We use information for the following general purposes: to fulfill our contract with you, to fulfill your requests for our products and Services and to improve our Services and contact you.

Here are the ways we may use personal information you provide us:

  • To allow you to register for the Services and to administer and process the registration.

  • To communicate with you about our products, Services and related issues.

  • To evaluate the quality of our products and Services, and to enhance your experience on our site/application.

  • To maintain and administer our Services and comply with our legal or internal obligations and policies.

  • To troubleshoot problems with your account.

  • To provide other services requested by you as described when we collect the information.

  • To provide you with location-based services (such as advertising and other personalized content), based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;

  • To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages to offer certain events and promotions;

  • To prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and any security breaches or other potentially prohibited or illegal activities.

  • To enforce our terms of service https://www.bbumgames.com/terms-of-service, this Privacy Policy, or other policies

  • To improve and optimize the Services provided to you, including the development of new tools and features.

  • To transfer information to others solely as described in this Privacy Policy or to satisfy our legal, regulatory, compliance, or auditing requirements.

  • To charge you any fees and provide you with a receipt or resolve billing issues associated with your account.

  • In the case of accounts created using business email domains, to provide your contact information to an administrator of the business email domain to facilitate the provision of additional products and/or Services.

  • We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. 

 

Cookies

We use “cookies” (small text files sent to your device each time you visit our website or enter the Services, unique to your user account, your browser or device) to record log data. We use several types of cookies:

  • “Session” cookies (i.e., cookies that are temporary cookie files that last until you close your browser or exit the Services). Once you end your session by closing your browser or exiting the Services, all session cookies are deleted. Examples of how we use session cookies are: loading the Services in your preferred designated language.

  • “Persistent” cookies (i.e., cookies that remain on your device until you or your browser deletes them, or for the period set in the specific cookie). Such cookies are activated each time you use the Services or visit our website.

  • Local Shared Objects, commonly called “Flash” cookies, which are cookies from websites and services which use Adobe Flash. Examples of how we use “Flash” cookies are: the Services' application loading and graphics. We also use cookies to store your sound preferences or other settings so you don‘t have to set them up every time you visit the Service. Some of the cookies we use are associated with your account (including personal information about you, such as the email address you gave us), and other cookies are not.  These cookies and settings are entirely deleted upon removing the Services' application from your device.

 

Cookies are required for different functions of our Services:

  • Strictly necessary cookies – These cookies are essential in order for us to provide you with the Services. These cookies only collect information that is required for you to use our website or App, and not for other purposes such as marketing or users’ use of our Services.

  • Analytical cookies - These cookies assist us to improve the Services by analyzing how the Services are used by you and other users for the development of future features and maintenance. Examples of such cookies include Google Analytics.

  • Advertisement cookies – these cookies provide personalized content and ads while using the Services. Examples for such cookies include those related to in-app promotions you may view within our Services.

 

You are free to delete or block cookies from your device, by changing the preferences on your browser or device.  However, we cannot guarantee that our Services will fully operate should you choose not to accept cookies. For example, any preferences you may have defined on our website or application will not be saved. Most browsers accept cookies automatically, but generally provide the option to view the cookies currently stored on your device, and the choice to accept, reject or delete cookies, block third party cookies, block cookies from particular sites, accept all cookies or to receive notification when a new cookie is stored. Please see your browser’s or device’s ‘options’ or ‘preferences’ menu to change your cookie preferences.

 

Our partners may offer services to your device, which may use cookies or similar technologies placed by us or the third party. We do not have access or control over the cookies placed by third parties and the use of their cookies is subject to their own privacy policies. Such cookies are intended for uses such as: marketing, payment solutions, analytics.

Analytics Tools

We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service (for further information about cookies, please see the “Cookies” section in this policy).

We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html.

Aggregated Information

We collect and use anonymous, statistical and aggregated information and share it with third parties business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.

 

Third Party Sites/Cookies

Some third parties’ content or plugins embedded on the Services such as mobile attribution, group video chats or marketing analytics providers may allow their operators to learn that you have visited our website or used our Services, and they may combine this information with other information they have collected about your visits to other websites or online services. Some third-party applications and services that work with our Services may ask for permission to access the information in your account. Please consider your selection of such applications and services and your permissions. This Privacy Policy does not apply to the practices of companies that we do not own or control or employees that we do not manage. Information on our Services may contain links to third party services, websites or applications, and any information you provide to those sites and applications will be covered by any privacy policies they may have, for example, group video chat sessions are provided by Agora, Inc. and its affiliates and subject to its Terms of Service and Privacy Policy. Please be sure to read the privacy policies of any third-party applications, services and sites that you visit or provide permission to access your information. It is those third parties’ responsibility to protect any information you give them, so we will not be held liable for their wrongful use of your personally-identifying information.

 

Sharing Your Information with Third Parties

We do not disclose or share your personal information with other people or companies except to provide the Services, products or other services you’ve requested, or under the following circumstances:

  • We have your explicit consent to share the information.

  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.

  • We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.

  • We may transfer information that we collect if we will be acquired by or merged with another company. If that should occur, user information is typically one of the assets that get transferred. Similarly, if Beach Bum Ltd. or most of its assets were acquired, or in the unlikely event that we go out of business or enter bankruptcy, user information could be transferred or acquired. You should be aware that such events can occur, and you allow us to transfer your information in such event. If such event occurs, the buyer may continue to use your information. In such events, we will notify you before information about you is transferred and use best efforts to require our successor to comply with this privacy policy.

  • We share your information with service providers who process data on our behalf in order to operate and improve the features and functionality of the Services; complete your payment transactions; fulfill your product or service requests, including sales, delivery and support requests; and help us communicate with you as described elsewhere in this policy; these providers are subject to strict data protection requirements.

  • Entities we share your information with in order to provide you with the Services include data service hosting, mobile attributors, push notification providers, and analytical tools which we utilize in order to optimize the Services.

Legal Bases

In each case where we process your personal information, we do so lawfully in accordance with one of the legal basis set out under European data protection law (GDPR). The legal bases which we rely upon are the following:

  • Performance of a contract. We may use your personal information in order to provide you with Services that you have requested, such as our games, customer and support services;

  • Legitimate Interests. We may use your personal information based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our games and through other channels, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services;

  • Consent.  In limited cases, where you choose to sign up to receive direct marketing emails, where you accept cookies on our Services, we will process your personal information based on your consent.  You can withdraw your consent at any time by contacting us at: legal@bbumgames.com.

  • Legal Obligation. We may use your personal information when we need to do so to comply with a legal obligation, e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.

Retention

We will keep your information for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your personal information if you delete your account. We may also retain your personal information for legal and accounting purposes (i.e., as required to comply with our legal obligations and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use) in order to comply with our legal obligations.

Transfer of Information Outside Your Jurisdiction

We may store and process information in sites located throughout the world, including in sites operated and maintained by cloud based service providers. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction.  For information on our cloud service providers and sub-processors please contact our support at legal@bbumgames.com.

When you use our Services on your computing device, such as by using one of our downloadable applications, content you save will be stored locally on that device. When you sync your computing device with the Services, that content will be replicated on servers we and our service providers maintain in different countries.

 

AS PART OF THE STORAGE OF YOUR INFORMATION, INFORMATION THAT WE COLLECT ABOUT YOU, INCLUDING PERSONAL INFORMATION, MAY BE TRANSFERRED ACROSS BORDERS AND FROM YOUR COUNTRY OR JURISDICTION TO OTHER COUNTRIES OR JURISDICTIONS AROUND THE WORLD. TO THE EXTENT NECESSARY UNDER EU PRIVACY LAWS AND REGULATIONS, WE WILL IMPLEMENT DATA ONWARD TRANSFER INSTRUMENTS SUCH AS APPROPRIATE DATA PROTECTION AGREEMENTS (INCLUDING THE USE OF EU STANDARD MODEL CLAUSES) AND ADOPTION OF STRICT DATA PROTECTION PROCEDURES BY THE RECIPIENT.

 

Your GDPR Rights

To the extent you are subject to the protections of the EU General Data Protection Regulation (GDPR) (typically where we have collected personal data from you in relation to our products and services and you were located in the European Union), you have the following rights pursuant to the GDPR.

  • Right of Access. You have the right to know what personal information we maintain about you. You may request that we confirm to you whether or not we store Personal Data about you and that we provide you with a copy of the Personal Data we maintain about you. You may request information about: (a) the purposes of the processing of such personal information; (b) the categories of personal information being processed; (c) the names of the recipients or the categories of recipients to whom the personal information have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the personal information, or the criteria we use to determine that period; (e) the sources of the personal information, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

  • Right to Rectify. You may request that we rectify any personal information about you that we maintain that is incorrect. Depending on the purpose for which the data is used, this may also include the right to complete incomplete the personal information.

  • Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress personal information as it appears inside the European Union that relates to you where: (a) the information is no longer needed by us; (b) the information is collected with your consent and you withdraw that consent; (c) you have a right to object to our use of the information (as described below under, “Right to Object”); (d) we are not lawfully processing the information; or (e) we are otherwise required by law to delete the information. In certain cases, however, we may retain such information or we may refuse your request, for example, when we review the information for the purpose of defending ourselves, making legal claims or exercising are own rights.

  • Right to Restrict Processing. You may request that we restrict our use or processing of personal information about if: the personal information is inaccurate, during the time we investigate your claim; our processing of the personal information was unlawful; we no longer require the personal information; the legal basis for our processing of the personal information was our legitimate interests (and no other legal basis) and you object to this use, during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.

  • Right to Data Portability. You may request that we provide you with personal information about you that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer such personal information to another entity you choose (or have us transfer it directly to such entity).

  • Right to Object. You may, based on reasons specifically relating to you, object to our processing of personal information about you, when: (i) the information is used for our legitimate interests and our interests in processing the information does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.

  • Right to Object to Automated Decision Making. You may also request that you not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

  • Right to Withdraw Consent. When we process personal information about you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using such information for the purpose for which you have your consent, or altogether, depending on the situation.

  • Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here:

You can exercise rights that apply to us by contacting us by email at:legal@bbumgames.com.

We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

 

Please be aware that exercising rights to restrict, object to withdraw consent for processing of personal information, may lead to a restriction of our ability to provide you with our products and services, in whole or in part.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, you have may have certain rights with respect to the personal information we collect. Please see our California Privacy Notice for more information about our personal data collection and use practices and your rights under California law.  

Information Regarding Children

We do not knowingly collect any identifiable information from children under the age of 16. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at legal@bbumgames.com.

If we become aware that a child under age 16 has provided us with personally identifiable information, we will remove it.

Complaints

You have the right to file complaints with a data protection supervisory authority.

 

Changes to this Policy

We may update this policy from time to time. We will notify you about significant changes in the way we treat information by sending a notice to the primary email address specified you provided us and by placing a prominent notice on our website, and require your consent if required by law, in light of the nature of the changes.

 

Contact Us

If you do not agree to be bound by the terms of the new or modified Privacy Policy, you agree to stop using the Services or the application, as applicable.

For any questions, comments or concerns about our Privacy Policy or any other issue please contact us at legal@bbumgames.com.