PRIVACY & COOKIE POLICY

Last updated: December 3, 2024

This is the Privacy & Cookies Policy (the “Policy”) of Z BOSON STUDIO EOOD or “ЗЕТ БОЗОН СТУДИО” ЕООД (“zBoson”). This Policy describes the ways in which zBoson collects and uses information about you when you visit zBoson’s website at www.zbosonsutdio.com (the “Website”) or when you play one of zBoson’s games (each a “Game” and together the “Games”) on a browser, through a social networking site or as an app. It also details how zBoson collects and uses information about you when making a complaint to zBoson by e-mail, as well as if you choose to make a job application.

This policy is based on the rules of the General Data Protection Regulation (“GDPR”), which applies when you reside in the European Union and use our Services. When we refer to the GDPR we are referring to the Bulgarian General Data Protection Regulation as well, which applies when you reside in the Bulgaria, unless we otherwise specify that we are referring to only one of these laws. All definitions set out in Art. 4 GDPR apply to this Privacy Policy.

If you do not reside in the European Union and use our Services, the descriptions of this privacy policy may not fully apply to you and other data protection laws might be applicable. If you are a resident of the State of California, please see Section 13 below for detailed information according to the California Consumer Privacy Act (“CCPA”).

zBoson may change this Policy at any time, please check it from time to time to understand which data we collect and the purposes for which we use it.

For the purposes of data protection legislation, zBoson is the controller for the processing of your personal data.

If you have any general queries about this Policy, please contact zBoson using the contact details set out at paragraph 11 below. Alternatively, if you wish to exercise your rights in connection with the personal data we hold about you, please refer to paragraph 12.


1. WHAT PERSONAL DATA IS AND WHO THIS POLICY APPLIES TO

Some terms we use in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), a data protection law of the European Union. When we refer to the GDPR we are referring to the General Data Protection Regulation of the UK as well since both laws are very similar, unless we otherwise specify that we are referring to only one of them. Art. 4 GDPR gives detailed definitions of terms which we also apply in this Privacy Policy.

We’d like to explicitly mention the meanings of the following terms in simple words since they are used quite often throughout this Privacy Policy. Please check Art. c. GDPR for the detailed definitions:

To the extent that the California Consumer Privacy Act (“CCPA”) is applicable, the definition of “personal data” includes “personal information”; the definition of “data subject” includes “consumer”; the definition of “controller” includes “business”; and the definition of “processor” includes “service provider”, all as defined under the CCPA.

This Policy applies to the following people:


2. VISITORS TO THE WEBSITE

The Website is essentially a brochure for zBoson’s business, its Games and opportunities to work with and for zBoson. The Website collects information from you in the following ways:


3. PEOPLE WHO CONTACT OR MAKE COMPLAINTS TO ZBOSON BY EMAIL

When zBoson receives complaints by email it shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. zBoson will only use this information to process the complaint and to check on zBoson’s services and staff.

zBoson shall retain information in relation to a complaint for a maximum of six (6) years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis. zBoson relies on Art. 6 para. 1(b) GDPR to collect the information set out in this paragraph.


4. PEOPLE WHO USE THE GAMES


5. HOW ZBOSON USES COLLECTED INFORMATION FROM PEOPLE WHO PLAY THE GAMES

zBoson will use the information it collects as set out in paragraph 4 above to:


6. SHARING INFORMATION WITH THIRD PARTIES

zBoson will not pass your information to third parties other than as described in this paragraph. zBoson may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:


7. THIRD PARTY COOKIES

Third Party advertisers may place or read cookies and/or Technologies on your browser or device in the Games and/or on the Website.

This Policy is applicable only to the use of cookies or Technologies by zBoson and does not cover the use of cookies or Technologies by any third parties (including advertisers or Meta). For example, Meta will place cookies to maintain a secure login to the Facebook network, amongst other things.

More details of Meta’s cookies are available on its website and further links to third party cookies and Technologies are also set out in paragraphs 14 and 15 below.


8. LINKS TO THIRD PARTY WEBSITES AND THIRD PARTY ADVERTS

zBoson cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Games/Website, adverts in the Games/Website or from adverts on a webpage when you are playing the Game/are on the Website.

zBoson recommends that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

In addition, if you link to the Games from a third party site or via a social network (e.g. X, Meta), zBoson cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.


9. SECURITY, STORAGE AND DATA RETENTION

zBoson has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.

Where you log-in via a social network, you may also change your account settings on your social network to prevent both us and third parties seeing certain information in relation to you, such as your Meta profile.

zBoson’s physical servers are operated by third party cloud service providers and are located worldwide including in the EEA and USA. Where such information is transferred outside the EEA, zBoson has taken steps to ensure that its agreements with such third party providers contain provisions to ensure the adequacy of such transfer including any additional safeguards.

zBoson has a retention policy in place with respect to the data it holds, ensuring that it does not retain such data for longer than is reasonable in line with the purposes for which it was originally collected.

zBoson automatically delete your game data after 3 months of inactivity.


10. ZBOSON'S POLICY TOWARDS CHILDREN

zBoson’s Games and Apps are intended for anyone who is:

Where zBoson processes personal data and the lawful basis for the processing is consent, zBoson shall be satisfied that such consent is valid and lawful where:

zBoson does not knowingly collect personally identifiable information in relation to children under the age of 13. If zBoson discovers it has collected personal data in relation to any children under 13, zBoson shall take reasonable steps to delete such information.

From time to time we may require a higher minimum age to access certain features within our Games and Apps, as indicated in our Terms of Service.


11. CONTACT DETAILS

If at any time you would like to contact zBoson about your views on this Policy or any enquiry relating to your personal information, including but not limited to your rights under the GDPR and/or CCPA (as applicable), you can email our Data Protection Manager at dataprivacy@zbosonstudio.com.

zBoson’s registered address is 7 Rayko Daskalov str., 9850 Veliki Preslav, Shumen, Bulgaria. We are a company incorporated in Bulgaria with UIC 207626464.


12. EXERCISING YOUR RIGHTS

Under the GDPR you have the following rights when we process your personal data:

You can exercise your rights, including your right to have personal data about you deleted, by using our webform here.

zBoson may ask you to verify your identity before zBoson responds to such requests.

It may not always be possible for us to process requests. If we are unable to identify your data within our systems then we will not able to retrieve or delete your data. For example, if you uninstalled the app without recording your User ID and did not log in via social media, we are highly unlikely to be able to identify your data within our systems.

Please note that under the CCPA, zBoson is not required to delete information that is necessary to perform certain actions as outlined in the CCPA (e.g. to complete a transaction for which the information was collected or to provide the goods or services requested by you).

You will not be discriminated against in retaliation for exercising the above rights and rights under the CCPA.


13. PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a consumer residing in California, the California Consumer Privacy Act (“CCPA”) applies when you use our Services. The CCPA defines personal information and sensitive personal information as follows:

“Personal information”means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular you as consumer or a household.

“Sensitive personal information” is personal information that reveals:

zBoson do not collect, use, and share/sell your Sensitive personal information.

The information we provide in Section 4 of this Privacy Policy regarding which personal data we process, and for which purposes we process it, apply correspondingly to cases in which we process Personal Information of yours as resident of California.

zBoson may share personal information with third parties for certain purposes. For example, we share personal information with:

We value your trust and are committed to safeguarding your personal information. If you have any questions or concerns about the way we share your data with third parties, please don't hesitate to contact us using the information provided in the "Contact Us" section of this Privacy Policy.

Your Rights

If you are a resident of California, you have the following rights:

14. INTERNATIONAL DATA TRANSFERS

If you are an EU resident, we rely on certain safeguards when sharing your personal data with a recipient established outside of the EEA/EU.

Some vendors with which we share your personal data are established outside of the European Union. Principally, there are two possible safeguards we can rely on when we share your personal data with these recipients:


15. COOKIES AND OTHER SIMILAR TECHNOLOGIES


16. COOKIES USED ON THE WEBSITE

We use cookies to enhance your experience by remembering your language preferences and the fields of filled-out forms.


17. TECHNOLOGIES USED IN THE GAME


18. NO AUTOMATED DECISION-MAKING

zBoson does not process your personal data with means of automated decision-making (e.g., profiling).