Last updated: November 22, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure
of Your information when You use the Service and tells You about Your privacy rights and how
the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree
to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of whether they
appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
■ Account means a unique account created for You to access our Service or parts of our
Service.
■ Affiliate means an entity that controls, is controlled by or is under common control
with a party, where "control" means ownership of 50% or more of the shares, equity
interest or other securities entitled to vote for election of directors or other managing
authority.
■ Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity
that collects Consumers' personal information and determines the purposes and means
of the processing of Consumers' personal information, or on behalf of which such
information is collected and that alone, or jointly with others, determines the purposes
and means of the processing of consumers' personal information, that does business in
the State of California.
■ CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as
amended by the California Privacy Rights Act of 2020 (the "CPRA").
■ Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to GAMADU LTD, Platonos & K. Mourouzi, Georgia Court, 2nd
Floor, Flat/office 202, 4001 Limassol, Cyprus
For the purpose of the GDPR, the Company is the Data Controller.
■ Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a
California resident. A resident, as defined in the law, includes (1) every individual who
is in the USA for other than a temporary or transitory purpose, and (2) every individual
who is domiciled in the USA who is outside the USA for a temporary or transitory
purpose.
■ Cookies are small files that are placed on Your computer, mobile device or any other
device by a website, containing the details of Your browsing history on that website
among its many uses.
■ Country refers to: Bulgaria
■ Data Controller, for the purposes of the GDPR (General Data Protection Regulation),
refers to the Company as the legal person which alone or jointly with others determines
the purposes and means of the processing of Personal Data.
■ Device means any device that can access the Service such as a computer, a cellphone or
a digital tablet.
■ Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities,
in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to
develop and implement a mechanism for allowing internet users to control the tracking
of their online activities across websites.
■ GDPR refers to EU General Data Protection Regulation.
■ Personal Data is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such
as a name, an identification number, location data, online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or
social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that
identifies, relates to, describes or is capable of being associated with, or could
reasonably be linked, directly or indirectly, with You.
■ Service refers to the Website.
■ Service Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by the
Company to facilitate the Service, to provide the Service on behalf of the Company, to
perform services related to the Service or to assist the Company in analyzing how the
Service is used. For the purpose of the GDPR, Service Providers are considered Data
Processors.
■ Third-party Social Media Service refers to any website or any social network website
through which a User can log in or create an account to use the Service.
■ Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of a page
visit).
■ Website refers to any websites operating by Gamadu LTD including https://gamadu.net
■ You means the individual accessing or using the Service, or the company, or other legal
entity on behalf of which such individual is accessing or using the Service, as
applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the
individual using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, 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
■ Usage Data
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 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 unique ID, the IP address of Your mobile device, Your mobile operating system, the type
of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or
when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the
following Third-party Social Media Services:
■ Google
■ Facebook
■ Twitter
If You decide to register through or otherwise grant us access to a Third-Party Social Media
Service, We may collect Personal data that is already associated with Your Third-Party Social
Media Service's account, such as Your name, Your email address, Your activities or Your
contact list associated with that account.
You may also have the option of sharing additional information with the Company through Your
Third-Party Social Media Service's account. If You choose to provide such information and
Personal Data, during registration or otherwise, You are giving the Company permission to use,
share, and store it in a manner consistent with this Privacy Policy.
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. Learn more about cookies on the Privacy Policies website article.
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.
For more information about the cookies we use and your choices regarding cookies, please visit
our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
■ To provide and maintain our Service, including to monitor the usage of our Service.
■ To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the
Service that are available to You as a registered user.
■ For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any
other contract with Us through the Service.
■ To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application's push notifications
regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or
reasonable for their implementation.
■ To provide You with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or enquired about unless You have opted not to receive such information.
■ To manage Your requests: To attend and manage Your requests to Us.
■ For business transfers: We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of
some or all of Our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Data held by Us about our Service
users is among the assets transferred.
■ For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Service, products, services, marketing and
your experience.
We may share Your personal information in the following situations:
■ With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to contact You.
■ For business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another company.
■ With Affiliates: We may share Your information with Our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company and any other subsidiaries, joint venture partners or other companies that We
control or that are under common control with Us.
■ With business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
■ With other users: when You share personal information or otherwise interact in the
public areas with other users, such information may be viewed by all users and may be
publicly distributed outside. If You interact with other users or register through a Third-
Party Social Media Service, Your contacts on the Third-Party Social Media Service
may see Your name, profile, pictures and description of Your activity. Similarly, other
users will be able to view descriptions of Your activity, communicate with You and
view Your profile.
■ With Your consent: We may disclose Your personal information for any other purpose
with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set
out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain your data to comply
with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to strengthen the security or to
improve the functionality of Our Service, or We are legally obligated to retain this data for
longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and
in any other places where the parties involved in the processing are located. It means that this
information may be transferred to — and maintained on — computers located outside of Your
state, province, country or other governmental jurisdiction where the data protection laws may
differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents
Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely
and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place
to an organization or a country unless there are adequate controls in place including the security
of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have
collected about You.
Our Service may give You the ability to delete certain information about You from within the
Service.
You may update, amend, or delete Your information at any time by signing in to Your Account,
if you have one, and visiting the account settings section that allows you to manage Your
personal information. You may also contact Us to request access to, correct, or delete any
personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal
obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be
transferred. We will provide notice before Your Personal Data is transferred and becomes subject
to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if
required to do so by law or in response to valid requests by public authorities (e.g. a court or a
government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is
necessary to:
■ Comply with a legal obligation
■ Protect and defend the rights or property of the Company
■ Prevent or investigate possible wrongdoing in connection with the Service
■ Protect the personal safety of Users of the Service or the public
■ Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We strive
to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its
absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party
vendors collect, store, use, process and transfer information about Your activity on Our Service
in accordance with their Privacy Policies.
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional
materials and other information that may be of interest to You. You may opt-out of receiving
any, or all, of these communications from Us by following the unsubscribe link or instructions
provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
■ Twilio
Their Privacy Policy can be viewed at https://www.twilio.com/en-
us/legal/privacy?_gl=1evqmrd_gcl_auMTAwNjQzOTE1MC4xNzE1Nzc3Mzc2_gaMzc5
OTU4NzA3LjE3MDc5MDAxOTE._ga_8W5LR442LD*MTcxODIwODAyNy4xMi4xLj
E3MTgyMDgwMjcuMC4wLjA.
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
■ Consent: You have given Your consent for processing Personal Data for one or more
specific purposes.
■ Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations
thereof.
■ Legal obligations: Processing Personal Data is necessary for compliance with a legal
obligation to which the Company is subject.
■ Vital interests: Processing Personal Data is necessary in order to protect Your vital
interests or of another natural person.
■ Public interests: Processing Personal Data is related to a task that is carried out in the
public interest or in the exercise of official authority vested in the Company.
■ Legitimate interests: Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee
You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
■ Request access to Your Personal Data. The right to access, update or delete the
information We have on You. Whenever made possible, you can access, update or
request deletion of Your Personal Data directly within Your account settings section. If
you are unable to perform these actions yourself, please contact Us to assist You. This
also enables You to receive a copy of the Personal Data We hold about You.
■ Request correction of the Personal Data that We hold about You. You have the
right to have any incomplete or inaccurate information We hold about You corrected.
■ Object to processing of Your Personal Data. This right exists where We are relying
on a legitimate interest as the legal basis for Our processing and there is something
about Your particular situation, which makes You want to object to our processing of
Your Personal Data on this ground. You also have the right to object where We are
processing Your Personal Data for direct marketing purposes.
■ Request erasure of Your Personal Data. You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue processing it.
■ Request the transfer of Your Personal Data. We will provide to You, or to a third-
party You have chosen, Your Personal Data in a structured, commonly used, machine-
readable format. Please note that this right only applies to automated information which
You initially provided consent for Us to use or where We used the information to
perform a contract with You.
■ Withdraw Your consent. You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You with
access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting
Us. Please note that we may ask You to verify Your identity before responding to such requests.
If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of
Your Personal Data. For more information, if You are in the European Economic Area (EEA),
please contact Your local data protection authority in the EEA.
CCPA/CPRA Privacy Notice
This privacy notice section for California residents supplements the information contained in Our
Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of
California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer
or Device. The following is a list of categories of personal information which we may collect or
may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the
CCPA/CPRA. This does not mean that all examples of that category of personal information
were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that
some of that information from the applicable category may be and may have been collected. For
example, certain categories of personal information would only be collected if You provided
such personal information directly to Us.
■ Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, driver's license
number, passport number, or other similar identifiers.
Collected: Yes.
■ Category B: Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver's license or state
identification card number, insurance policy number, education, employment,
employment history, bank account number, credit card number, debit card number, or
any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Collected: Yes.
■ Category C: Protected classification characteristics under California or federal
law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).
Collected: No.
■ Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
■ Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data.
Collected: No.
■ Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
■ Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
■ Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
■ Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
■ Category J: Non-public education information (per the Family Educational Rights
and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or student
disciplinary records.
Collected: No.
■ Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
■ Category L: Sensitive personal information.
Examples: Account login and password information, geolocation data.
Collected: Yes.
Under CCPA/CPRA, personal information does not include:
■ Publicly available information from government records
■ Deidentified or aggregated consumer information
■ Information excluded from the CCPA/CPRA's scope, such as:
■ Health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of
Medical Information Act (CMIA) or clinical trial data
■ Personal Information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or
California Financial Information Privacy Act (FIPA), and the Driver's Privacy
Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of
sources:
■ Directly from You. For example, from the forms You complete on our Service,
preferences You express or provide through our Service.
■ Indirectly from You. For example, from observing Your activity on our Service.
■ Automatically from You. For example, through cookies We or our Service Providers
set on Your Device as You navigate through our Service.
■ From Service Providers. For example, or other third-party vendors that We use to
provide the Service to You.
Use of Personal Information
We may use or disclose personal information We collect for "business purposes" or "commercial
purposes" (as defined under the CCPA/CPRA), which may include the following examples:
■ To operate our Service and provide You with Our Service.
■ To provide You with support and to respond to Your inquiries, including to investigate
and address Your concerns and monitor and improve our Service.
■ To fulfill or meet the reason You provided the information. For example, if You share
Your contact information to ask a question about our Service, We will use that personal
information to respond to Your inquiry.
■ To respond to law enforcement requests and as required by applicable law, court order,
or governmental regulations.
■ As described to You when collecting Your personal information or as otherwise set
forth in the CCPA/CPRA.
■ For internal administrative and auditing purposes.
■ To detect security incidents and protect against malicious, deceptive, fraudulent or
illegal activity, including, when necessary, to prosecute those responsible for such
activities.
■ Other one-time uses.
Please note that the examples provided above are illustrative and not intended to be exhaustive.
For more details on how we use this information, please refer to the "Use of Your Personal Data"
section.
If We decide to collect additional categories of personal information or use the personal
information We collected for materially different, unrelated, or incompatible purposes We will
update this Privacy Policy.
Disclosure of Personal Information
We may use or disclose and may have used or disclosed in the last twelve (12) months the
following categories of personal information for business or commercial purposes:
■ Category A: Identifiers
■ Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
■ Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not
mean that all examples of that category of personal information were in fact disclosed, but
reflects our good faith belief to the best of our knowledge that some of that information from the
applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We
enter a contract that describes the purpose and requires the recipient to both keep that personal
information confidential and not use it for any purpose except performing the contract.
Share of Personal Information
We may share, and have shared in the last twelve (12) months, Your personal information
identified in the above categories with the following categories of third parties:
■ Service Providers
■ Our affiliates
■ Our business partners
■ Third party vendors to whom You or Your agents authorize Us to disclose Your
personal information in connection with products or services We provide to You
Sale of Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating orally, in writing, or
by electronic or other means, a Consumer's personal information by the Business to a third party
for valuable consideration. This means that We may have received some kind of benefit in return
for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow
Service Providers to use Your personal information for the business purposes described in Our
Privacy Policy, and these may be deemed a sale under CCPA/CPRA.
We may sell and may have sold in the last twelve (12) months the following categories of
personal information:
■ Category A: Identifiers
■ Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
■ Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not
mean that all examples of that category of personal information were in fact sold, but reflects our
good faith belief to the best of Our knowledge that some of that information from the applicable
category may be and may have been shared for value in return.
Sale of Personal Information of Minors Under 16 Years of Age
We do not sell the personal information of Consumers We actually know are less than 16 years
of age, unless We receive affirmative authorization (the "right to opt-in") from either the
Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less
than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of
future sales at any time. To exercise the right to opt-out, You (or Your authorized representative)
may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with
personal information, please contact Us with sufficient detail to enable Us to delete that
information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal
information. If You are a resident of California, You have the following rights:
■ The right to notice. You have the right to be notified which categories of Personal
Data are being collected and the purposes for which the Personal Data is being used.
■ The right to know/access. Under CCPA/CPRA, You have the right to request that We
disclose information to You about Our collection, use, sale, disclosure for business
purposes and share of personal information. Once We receive and confirm Your
request, We will disclose to You:
■ The categories of personal information We collected about You
■ The categories of sources for the personal information We collected about You
■ Our business or commercial purposes for collecting or selling that personal
information
■ The categories of third parties with whom We share that personal information
■ The specific pieces of personal information We collected about You
■ If we sold Your personal information or disclosed Your personal information for
a business purpose, We will disclose to You:
■ The categories of personal information categories sold
■ The categories of personal information categories disclosed
■ The right to say no to the sale or sharing of Personal Data (opt-out). You have the
right to direct Us to not sell Your personal information. To submit an opt-out request,
please see the "Do Not Sell My Personal Information" section or contact Us.
■ The right to correct Personal Data. You have the right to correct or rectify any
inaccurate personal information about You that We collected. Once We receive and
confirm Your request, We will use commercially reasonable efforts to correct (and
direct our Service Providers to correct) Your personal information, unless an exception
applies.
■ The right to limit use and disclosure of sensitive Personal Data. You have the right
to request to limit the use or disclosure of certain sensitive personal information We
collected about You, unless an exception applies. To submit, please see the "Limit the
Use or Disclosure of My Sensitive Personal Information" section or contact Us.
■ The right to delete Personal Data. You have the right to request the deletion of Your
Personal Data under certain circumstances, subject to certain exceptions. Once We
receive and confirm Your request, We will delete (and direct Our Service Providers to
delete) Your personal information from our records, unless an exception applies. We
may deny Your deletion request if retaining the information is necessary for Us or Our
Service Providers to:
■ Complete the transaction for which We collected the personal information,
provide a good or service that You requested, take actions reasonably
anticipated within the context of our ongoing business relationship with You, or
otherwise perform our contract with You.
■ Detect security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity, or prosecute those responsible for such activities.
■ Debug products to identify and repair errors that impair existing intended
functionality.
■ Exercise free speech, ensure the right of another consumer to exercise their free
speech rights, or exercise another right provided for by law.
■ Comply with the California Electronic Communications Privacy Act (Cal. Penal
Code § 1546 et. seq.).
■ Engage in public or peer-reviewed scientific, historical, or statistical research in
the public interest that adheres to all other applicable ethics and privacy laws,
when the information's deletion may likely render impossible or seriously
impair the research's achievement, if You previously provided informed
consent.
■ Enable solely internal uses that are reasonably aligned with consumer
expectations based on Your relationship with Us.
■ Comply with a legal obligation.
■ Make other internal and lawful uses of that information that are compatible with
the context in which You provided it.
■ The right not to be discriminated against. You have the right not to be discriminated
against for exercising any of Your consumer's rights, including by:
■ Denying goods or services to You
■ Charging different prices or rates for goods or services, including the use of
discounts or other benefits or imposing penalties
■ Providing a different level or quality of goods or services to You
■ Suggesting that You will receive a different price or rate for goods or services or
a different level or quality of goods or services
Exercising Your CCPA/CPRA Data Protection Rights
Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure
of My Sensitive Personal Information" section for more information on how to opt out and limit
the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a
California resident, You can contact Us:
■ By email: support@gamadu.net
Only You, or a person registered with the California Secretary of State that You authorize to act
on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
■ Provide sufficient information that allows Us to reasonably verify You are the person
about whom We collected personal information or an authorized representative
■ Describe Your request with sufficient detail that allows Us to properly understand,
evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We cannot:
■ Verify Your identity or authority to make the request
■ And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving
Your verifiable request. The time period to provide the required information may be extended
once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable
request's receipt.
For data portability requests, We will select a format to provide Your personal information that is
readily usable and should allow You to transmit the information from one entity to another entity
without hindrance.
Do Not Sell My Personal Information
As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating orally, in writing, or
by electronic or other means, a Consumer's personal information by the Business to a third party
for valuable consideration. This means that We may have received some kind of benefit in return
for sharing personal information, but not necessarily a monetary benefit.
We do not sell personal information as the term sell is commonly understood. We do allow
Service Providers to use Your personal information for the business purposes described in Our
Privacy Policy, and these may be deemed a sale under CCPA/CPRA.
You have the right to opt-out of the sale of Your personal information. Once We receive and
confirm a verifiable consumer request from You, we will stop selling Your personal information.
To exercise Your right to opt-out, please contact Us.
Limit the Use or Disclosure of My Sensitive Personal Information
If You are a California resident, You have the right to limit the use and disclosure of Your
sensitive personal information to that use which is necessary to perform the services or provide
the goods reasonably expected by an average Consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide
the Service. For more information on how We use Your personal information, please see the
"Use of Your Personal Data" section or contact us.
"Do Not Track" Policy as Required by California Online Privacy Protection Act
(CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to inform websites
that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or
settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents
with an established business relationship with us can request information once a year about
sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if You are
a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code
Section 22581)
California Business and Professions Code Section 22581 allows California residents under the
age of 18 who are registered users of online sites, services or applications to request and obtain
removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using
the contact information provided below, and include the email address associated with Your
account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or
information posted online and that the law may not permit or require removal in certain
circumstances.
Children's Privacy
The Service may contain content appropriate for children under the age of 13. As a parent, you
should know that through the Service children under the age of 13 may participate in activities
that involve the collection or use of personal information. We use reasonable efforts to ensure
that before we collect any personal information from a child, the child's parent receives notice of
and consents to our personal information practices.
We also may limit how We collect, use, and store some of the information of Users between 13
and 18 years old. In some cases, this means We will be unable to provide certain functionality of
the Service to these Users. If We need to rely on consent as a legal basis for processing Your
information and Your country requires consent from a parent, We may require Your parent's
consent before We collect and use that information.
We may ask a User to verify its date of birth before collecting any personal information from
them. If the User is under the age of 13, the Service will be either blocked or redirected to a
parental consent process.
Information Collected from Children Under the Age of 13
The Company may collect and store persistent identifiers such as cookies or IP addresses from
Children without parental consent for the purpose of supporting the internal operation of the
Service.
We may collect and store other personal information about children if this information is
submitted by a child with prior parent consent or by the parent or guardian of the child.
The Company may collect and store the following types of personal information about a child
when submitted by a child with prior parental consent or by the parent or guardian of the child:
■ First and/or last name
■ Date of birth
■ Gender
■ Grade level
■ Email address
■ Telephone number
■ Parent's or guardian's name
■ Parent's or guardian's email address
For further details on the information We might collect, You can refer to the "Types of Data
Collected" section of this Privacy Policy. We follow our standard Privacy Policy for the
disclosure of personal information collected from and about children.
Parental Access
A parent who has already given the Company permission to collect and use his child personal
information can, at any time:
■ Review, correct or delete the child's personal information
■ Discontinue further collection or use of the child's personal information
To make such a request, You can write to Us using the contact information provided in this
Privacy Policy.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a
third party link, You will be directed to that third party's site. We strongly advise You to review
the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by
posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change
becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
■ By email: support@gamadu.net
