Privacy Policy

Personal Data

While using Our Website and/or Our software application, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data (including data related to your purchases)
• Date of birth
• Income
• Marital status
• Educational level
• Preferences

To conduct KYC verification of User's data, our Service can involve third parties (please see Section “Sharing of Your information” of this Privacy Policy), including those who verify the User's passport data, driver's license, and other documents, which confirm the identity and age of the User.

We store some parts of the User's information, some information can be transferred for processing and storage by third parties.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, device Information, referral source, network information, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, in-app purchases and their amounts, session information, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect, store, and use information about apps or games installed on Your mobile device through Company or separately, either before or during the use of Service. This information is collected, stored, and used for targeting and personalization to improve user experience and personalization.

Additionally, we may collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Data related to Your purchases

We collect and store information related to your purchases made through our Service or services We are promoting. This data may include details such as the purchase amounts, timestamps and games/services You make them in.

This information is collected for targeting and content personalization purposes. For these purposes, we can use profiling and automated decision-making technologies.

We retain purchase data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Typically, your purchase information will be stored for a period that allows us to comply with Our legal and accounting obligations.

These third parties are obligated to protect Your data and use it solely for the purpose of providing their services.

You have the right to access more information about profiling and automated decision-making related to Your purchases as well as the right to opt out of profiling You based on data related to Your purchases by sending a request to Us through privacy@scrambly.io.

Newsletters through Your email

When You register and provide Your email address, We may use it to send you communications (such as newsletters) about special subscription offers, new features, and other news related to the Service, based on our legitimate interest. These newsletters help keep you informed with the latest updates about the Service, including the best price deals. You also acknowledge and agree to the processing of certain categories of Your personal data (such as your name, if provided, registration date, activity data, etc.) for market analysis purposes, particularly to deliver targeted newsletters that best match your needs and interests. The email address You provide may be transferred to an email marketing tool for optimizing and automating the email delivery process. You can unsubscribe or opt out of receiving emails from us at any time by using the unsubscribe link provided in each email. Your request to unsubscribe will be processed within a reasonable timeframe.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies
• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Further information for Users in California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia states

This part integrates with and supplements the information contained in the rest of the Privacy Policy and applies to all Users, who are residents in the following states: California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the Privacy Policy. We collect the Personal Data, either directly or indirectly, from you when You use the Service.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

• The right to opt out of the Sharing of your Personal Data for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Data to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Data is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Colorado, Connecticut, Montana, Oregon, Texas and Virginia

In addition to the rights listed above common to all Users in the United States, as a User residing in Colorado, Connecticut, Montana, Oregon, Texas, and Virginia you have

• The right to opt out of the processing of your Personal Data for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny, or withdraw your consent for the processing of your Sensitive Personal Data. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Data is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have

• The right to opt out of the processing of your Personal Data for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Data. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Data is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, You need to submit Your request to Us by contacting us viaprivacy@scrambly.io.

For Us to respond to Your request, we must know who You are. We will not respond to any request if We are unable to verify Your identity and therefore confirm the Personal Data in our possession relates to You. We will use any Personal Data collected from You in connection with the verification of Your request solely for verification and shall not further disclose the Personal Data, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If You are an adult, you can make a request on behalf of a child under Your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise Your right to opt-out of Sale or Sharing and Targeted Advertising You can also use the privacy choices link provided in this Privacy Policy above.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, We will explain to you the reasons why, and how much more time we need.

Should we deny your request, We will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to Your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, We may charge a reasonable fee or refuse to act on the request. In either case, We will communicate our choices and explain the reasons behind them.