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Privacy Policy

Who We Are

FRVR Limited (VAT MT24548624) is a Maltese limited liability company located in Naxxar, Malta.

FRVR® is a registered trademark of FRVR Limited.

FRVR Limited
36, Flat 3,
Abbate Savoia Street,
Naxxar NXR 1141
Malta

Business ID C82019
VAT ID MT24548624

For questions, support and legal enquiries please contact legal@frvr.com

Our website address is: https://corp.frvr.com

FRVR: Privacy Policy

The original version of the Privacy Policy is the English version. In case of contradiction or any interpretative doubt, the original version supersedes.

FRVR Ltd (“FRVR” or “we”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). This Online Privacy Policy (“Privacy Policy”) has been crafted to inform you as to the ways we collect, store, use, and manage the information you provide in connection with any FRVR game or application (“Service”). Please note that the scope of this Privacy Policy is limited to only information collected from FRVR through use of the Service.

By using the Service, you are agreeing to the collection and use of your personal information as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes.

Information Collected and Used

FRVR is GDPR compliant.

FRVR’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.

When you install any of the FRVR games or applications, we may collect and record the information you provide us voluntarily through services such as www.facebook.com (“Facebook”) in accordance with the policies and terms of Facebook.

The types of personal information collected in accordance with the activities listed above may vary depending on the activity. This “personal information” is defined as information about you that can be used to contact or identify you.

Personal information may include: (1) your name, (2) Facebook user identification number, (3) or email address. Additionally, we may acquire information from you through (1) your access and participation in message boards on the Service (2) your email of a question to our customer support or (3) your purchase of a virtual product of any type.

Please note that because a third party site manages the purchases of virtual goods offered by the Service, we do not have access to your credit card details and billing information.

FRVR may also invite you to share non-personal information about yourself which may include but is not limited to: (1) your age or date of birth; (2) your gender; (3) information about the hardware you may own; (4) your favorite websites, friend information and fan pages (collectively referred to as “non-personal information”).

If non-personal information is collected for an activity that also requires personal information, FRVR may combine your non-personal information with your personal information in an attempt to provide you with a better user experience, to improve the quality and value of the Services and to analyze how our Service is used.

The Service will also record game play information such as your high scores or game session duration.

In addition to information collected as described above, you may choose to share additional information about yourself throughout the Service, such as in games or on message boards. Any action you perform with other players are considered public, and are your sole discretion.

Finally, any time you access the Service, we may collect aggregate information including but not limited to internet protocol addresses, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to better tailor the Service to your interests, to provide you more efficient customer support, and to overall enhance the Service.

In all cases of data access and collection, the information you provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose of providing you with and improving the Service.

Other Disclosure of Your Personal Information

You understand and agree that we may be required to disclose any personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public. Note that FRVR is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that FRVR may receive.

Additionally, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information may be transferred to FRVR’s successor or assignee, if permitted by and done in accordance with applicable law.

Cookies

A cookie is a small data file that we transfer to your computer’s hard disk, generally to quickly identify a user’s computer and to “remember” things about the user’s visit, such as your preferences or a user name and password. The Service sends cookies to your computer when you access or view content of a FRVR service. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although you may not be able to access or use features of the Service.

If you wish to return your browser to a cookie-free state for this domain, find your browser in the list below and follow the instructions.

Google Chrome:

https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=en

 

Firefox:

https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

 

Internet Explorer:

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

 

Internet Explorer Edge:

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

 

Safari (Mobile):

https://support.apple.com/en-us/HT201265

 

Safari:

https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Links

The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that FRVR endorses or authorizes that third party, nor is it a representation of our affiliation with that third party.

FRVR is in no way responsible for the privacy policies of these other websites to which you choose to access from the Service. Please be sure to read the privacy policies of those websites when exiting the Service.

Third Party Platform

When you use or connect to a FRVR website or download a FRVR mobile app by or through a Third Party Platform, such as Facebook or other social networking site, you allow us to access and/or collect certain information from your Third Party Platform profile/account (such as your Facebook account) or via any cookies placed on your device by such Third Party Platform as permitted by the terms of the agreement and your privacy settings with the Third Party Platform.

We will share such information with the Third Party Platform for their use as permitted by the terms of the agreement and your privacy setting with the Third Party Platform.

We will share some of the information we collect from you upon install of the mobile app with vendors and other service providers who are engaged by or working with us in connection with the operation of the services we provide to you and/or for analytics purposes which may require the reproduction and display of such information in an aggregated and anonymised manner such that will not in any way identify you.

Changing or Deleting Your Information

You may review, update, correct or delete any personal information by changing the applicable information by changing the applicable information in your Facebook profile page.

If you completely delete all this information, your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we are not legally obligated to retain the record.

Security

We have put in place reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes.

Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums.

Policy Regarding Minors

Services may be used by minors, submitted to permission given by parents or guardians. In case you are a minor and use the Services, you ensure and warrant towards us that you have obtained the necessary permission from your parent or guardian.

Our Services are classified according to the sensitivity of the content shown to our users. This classification materializes by establishing a minimum recommended age for playing our games. The minimum age established in each game might possibly differ based on games’ content. This is not related to the processing of data.

As we mentioned previously, most of our user’s game data is processed anonymously, thus we do not gear our Services towards children under the age of 13 and we do not knowingly collect personal identifiable information from children under the age of 13. If we know that a child under 13 has provided us with personal information we will delete such information from our files as quickly as possible.

If you are under 13 and do not understand the content presented in this Policy, please ask for support from your legal representatives – parents or legal guardians.

GDPR Compliance Statement

The General Data Protection Regulation (GDPR) is effective from 25th May 2018. The GDPR aims to strengthen the security and protection of personal data in the EU and will replace the European Privacy Directive and national legislations accordingly.

FRVR understands the importance of customer data and welcomes the arrival of the GDPR. At FRVR Limited, we believe that customers are the most important part of our business and the success of our company builds on the trust that our customers, employees and other stakeholders have in our ability to deliver premier quality including the protection of personal information.

FRVR Limited services complies with all applicable parts of the GDPR.

Any consent you may give or choose to withhold in relation to the GDPR shall apply to all services (games and website) provided by FRVR Limited as part of the frvr.com domain.

The following are key aspects of the GDPR, and how it relates to FRVR Limited.

What is GDPR

The GDPR is the General Data Protection Regulation established by the European Union.

At its core, GDPR is a new set of rules designed to give EU citizens more control over their personal data. It aims to simplify the regulatory environment for business so both citizens and businesses in the European Union can fully benefit from the digital economy.

Follows EU Data Protection Directive (Directive 95/46/EC). For more information, please see eugdpr.org.

Key Aspects of GDPR

There are 4 aspects to the GDPR that FRVR Limited has considered as part of our GDPR compliance:

The right to data portability

 Individuals have the right to a copy of all the personal data that controllers have regarding him or her. It also must be provided in a way that facilities reuse.

  • At any time, users may request any date we store on their behalf by contacting us via email on gdpr@frvr.com

The right to be forgotten

 This gives individuals the right to have certain personal data deleted so third parties can no longer trace them. FRVR Limited does not store any personal data, only authentication tokens to Facebook. Those tokens can be invalidated by removing the game app according to these instructions by Facebook.

Since we currently do not store any PII directly, and the only way to link game state and analytics data collected with a particular user is via their Facebook Access Token, simply removing the FRVR game app from the users’ Facebook profile will anonymize any information we hold. This will happen instantly, the moment the user removes our app.

Privacy by Design

This helps to facilitate the inclusions of policies, guidelines, and work instructions related to data protection in the earliest stages of projects including personal data.

  • This aspect does not apply to FRVR Limited.

Data Breach Notifications

Controllers must report personal data breaches to the relevant supervisory authority within 72 hours after having become aware of it. If there is an high risk to the rights and freedoms of data subjects, they must also notify the data subjects.

FRVR Limited has an escalated process in order to ensure the security of user data. Information about whether or not user data has been part of a breach is available upon request.

GDPR Compliance for FRVR

To Understand the position of FRVR in the compliance of GDPR, it is important to understand the actors. These actors are:

Data Controller

is the individual or the legal person who controls and is responsible for the keeping and use of personal information on a computer or in structured manual files.

Data Processor

in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller. “processing”, in relation to information or data means. obtaining, recording or holding the information or data.

Data Subject

means an individual who is the subject of personal data. In other words, the data subject is the individual whom particular personal data is about.

GDPR and FRVR Limited

The following are key elements of our GDPR Compliance:

We do not process personal data on behalf of the Customer and we don’t have access to any personal data in our customer’s systems (Customer Personal Data). Moreover, FRVR is not able to monitor the processing of Customer Personal Data in our customer’s systems.

What personal data do we collect/store?

 At FRVR we collect two types of data on our users; passive and active. Passive collection is the data that is collected when users play games, whether on their mobile device or the web. This data is collected using Google Analytics or similar and contains the following information:

  • IP address
  • approximate geographical location
  • session duration
  • in-game activity

This data does not contain any personally identifying information. Our active data collection is currently limited to high scores and game information, such as coins collected. We allow users to log in using their Facebook account, and from their Facebook account we store the following:

  • User Access Token: we simply use this token to identify a user from one play session to the next. We do not gain access to any details about the user.

As such we don’t store any data that can be used to identify and track an individual. The user access token can be invalidated at any time by removing our app from the users Facebook profile.

 

How does FRVR Address GDPR?

Data Access Control

The controller shall implement appropriate technical and organizational measures for ensuring that by default, only personal data which are necessary for each specific purpose of the processing are processed.

Monitoring of Access Activities

Each controller and where applicable, the controllers representative, shall maintain a record of processing activities under its responsibilities.

Data Encryption

Organizations must implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including the pseudonymisation and encryption of personal data.

Strong Compliance Framework

Appropriate technical and organizational measures may need to include “the ability to ensure the ongoing confidentiality, integrity, availability and resilience of the processing systems and services.

Questions?

Any FRVR Limited GDPR related questions and any data subject requests can be addressed to: gdpr@frvr.com.

FAQ

What are the requirements under GDPR for FRVR? 

  • Privacy measures should be implemented in the design phase
  • Right to be forgotten
  • Data portability

What information is covered by GDPR?

  • Any information relating to an identified or identifiable natural person
  • Any healthcare and sensitive data

When does GDPR come into effect? 

  • May 25, 2018

Which customers are affected by the GDPR?

  • Applies to controllers and processors who are established in the European Union or those who offer goods and services to data subjects in the EU
  • Entities that monitor behavior of data subjects in the EU

What type of actor is FRVR?

  • For information collected under this Privacy Policy, the data controller is FRVR Limited. Our Data Protection Officer can be contacted here: gdpr@frvr.com.