Privacy Policy

Last updated on December 12th, 2018

Summary:

In this document, you will find:

1. what information we and our partners collect when you use the Oraharo games (including Euler the Elephant and other Oraharo games) and services;
2. where that information is stored and how it is protected;
3. how we use that information;
4. how long we retain that information; and
5. your rights in relation to that information.

This Privacy Policy explains to you how your personal information is collected and stored and what happens to it regarding the Oraharo Services. If you have any queries you can contact us at office@oraharo.com.

1. WHO WE ARE AND WHAT THIS PRIVACY POLICY GOVERNS

1.1. Who is Oraharo?  We are Oraharo Entertainment DOO, incorporated and registered in Serbia with company registration code 21085693, having an address at Oraharo Entertainment DOO, Pukovnika Petra Mišića 4/30, 11000 Belgrade, Serbia, and Oraharo OÜ, incorporated and registered in Estonia with company registration code 14455483, having an address at Sepapaja 6, Tallinn 15551, Estonia, hereby jointly referred to as "Oraharo".

1.2. Which services does this Privacy Policy apply to? This Privacy Policy applies to our video games, including Euler the Elephant, our websites (including www.oraharo.com and its subdomains), plus all other Oraharo products and services, including but not limited to user accounts, customer and technical support, official forums, wikis, blogs, social media services and all other services Oraharo might provide in the future (we will just refer to “Oraharo Services” to cover all these things).

1.3. What information does this Privacy Policy apply to? Specifically, this Privacy Policy governs personal data (or, in the USA, personally identifiable information) and applicable non-personal information (or, in the USA, non-personally identifiable information), which we collect from you when you are using the Oraharo Services (“personal data” means information which, on its own or in combination with other information, can be used to identify you).

1.4. What about children? We recognise we have a special obligation to protect personal information obtained from children. Legally you must be at least 13 years old to use the Oraharo Services. We do not and will not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact office@oraharo.com.

1.5. Will we ever change this Privacy Policy? We may change this Privacy Policy from time to time, for example to reflect changes in our services or to reflect applicable laws. If we do, we will make the changed Privacy Policy available online, make reasonable efforts to notify you of this and update the “Last Updated” date. Once we change the Privacy Policy, it will become legally binding on you as of the date of publication (i.e. the new “Last updated” date). You are welcome to contact us if you have specific questions about the changes at office@oraharo.com. If you do not agree to those changes (regardless of whether you email us), then unfortunately we must ask you to cease using all Oraharo Services. In order to make the Oraharo Services work properly we need to have everyone using them under the same rules instead of different people having different rules.

1.6. What about GDPR? We respect your right to privacy and will only process personal information in accordance with applicable legislation in the EU (which includes the General Data Protection Regulation (EU) 2016/679 or the GDPR as it is often referred to), the USA and elsewhere. For personal information contained in this Privacy Policy which is used by Oraharo in connection with the Oraharo Services, Oraharo OÜ (Estonia) is the data controller under European Union data protection legislation.

2. WHAT INFORMATION IS COVERED?

2.1. What information might we collect from you?

When you sign up for, download, use or play the Oraharo Services then we will collect certain information from you. The information that we collect varies depending on the particular Oraharo Services used, but this information may include:

1. User Accounts and Newsletters. To access certain Oraharo Services you may need to create a user account. Or if you sign up to a newsletter you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable Oraharo Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
2. Third Party Accounts. In certain circumstances (e.g. joining forums or websites) you may be able to log into certain Oraharo Services via third party accounts (e.g. Facebook). If you choose to do so, you are asked to share certain information with us (the exact information will depend on the particular third party account displayed to you on the permissions page when you attempt to log in, but may include your name, location, gender, birth date, email address, photo, profile URL and friends list).
3. Technical Details. When you use, play or access the Oraharo Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; device memory; your operating system, browser type or other software; and your hardware or other technical details. We may collect this information anonymously or we may create a unique user ID to track your use of the Oraharo Services. This unique user ID is stored in connection with your information.
4. Your Activities. When you use, play or access the Oraharo Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; in-game purchases; achievements; scores; gameplay statistics; time spent playing; and your geographical location data.
5. Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, forums or other areas of the Oraharo Services, we may collect and maintain a record of your contact details and the content of your communications.

Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.

2.2. What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment method/processor. Oraharo will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within the Oraharo Services, we are notified by the payment processor once a transaction takes place, but we will not receive any of your actual payment details.

3. WHERE IS YOUR INFORMATION STORED?

Where will your information be stored? The information we hold will primarily be stored and processed in the EU, but there may be circumstances where we need to work with trusted third parties outside of the EU in order to provide the Oraharo Services to you (e.g. where we run games servers in the US, or if the development team from Serbia needs to look at some specific feature that requires such information). By submitting your personal information, you explicitly agree to such transfer, storing or processing of data outside the EU. We will take all steps reasonably necessary to ensure that this information is treated securely and in accordance with this Privacy Policy.

All information we hold is stored on our secure servers (which we own or license from appropriate third parties). We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.

4. HOW IS YOUR INFORMATION STORED?

4.1. How might your information be used? We may use the information above in order to (for example):

1. Perform our agreement with you: provide the Oraharo Services to you, including: to carry out our obligations arising from any contracts between you and us; allow you to participate in interactive features of the Oraharo Services when you choose to do so; and provide you with chat functionality and other communication systems.
2. For our legitimate commercial interests: monitor the performance of the Oraharo Services; to ensure that the Oraharo Services are presented in the most effective manner for you and for your device; enforce our policies; notify you about changes to the Oraharo Services; provide, maintain, protect and improve the Oraharo Services; and to protect Oraharo and Oraharo Services users.
3. Comply with our legal obligations: where we are required to do so by law; and to comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
4. Based on consent: provide you with marketing information about products or services that you request from us and which we feel may interest you where you have asked us to do so; and send you push notifications on mobile devices where you have agreed to this.

4.2. Will we ever share any of your information with other parties?

1. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
2. We may engage third party service providers in the course of providing the Oraharo Services to you (e.g. data storage, server hosting, customer and technical support, game analytics, advertising etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
3. We may work with third party service providers (e.g. ad network and measurement services) to display advertising on the Oraharo Services and to manage our ads on third party sites. We may share certain information (such as your email address, country of residence and your age) with third parties so that we can better target ads and content to you. You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device and you may be able to opt-out from the collection of information by some of our advertising partners.
4. We may share your information within the Oraharo company group for the purpose of providing the Oraharo Services.
5. In the unlikely event of a reorganisation or merger of Oraharo we may transfer personal information to an involved third party who will protect this to at least the same level as we do in this Privacy Policy.

5. HOW YOU USE YOUR INFORMATION AND THIRD PARTIES?

Please remember that any communications you have via the Oraharo Services may reveal details about you. Also, any information you post publicly will be publicly available to other people. We are not responsible for your use of any otherwise private personal information which you make available, or the activities of other users or other third parties to whom you give or make available your information or content. The Oraharo Services may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies.

6. DATA RETENTION

How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all Oraharo Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

7. YOUR RIGHTS

7.1. Can you ask us to stop processing your personal information? You have the right to ask us not to process your personal information for marketing purposes. You can change your email settings to unsubscribe from email communications, opt-out from push notifications by turning them off at device level through your settings.

7.2. What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the GDPR) you have the right to access and obtain a copy of your personal data we possess; you may have the legal right to contact us to request that we delete your personal data from our system; and you have the legal right to ask us to rectify/correct your personal data. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain Oraharo Services may no longer function properly or be completely unavailable to you.

7.3. Special California concerns: Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Oraharo Entertainment DOO, Pukovnika Petra Mišića 4/30, 11000 Belgrade, Serbia, or Oraharo OÜ, Sepapaja 6, Tallinn 15551, Estonia. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.

7.4. Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact office@oraharo.com.