Holyday Studios and its affiliates and subsidiaries.
hardware/software/firmware. Non-Personal Data also includes “Usage Data” which is anonymous data tied to the User’s computer, mobile device, and/or game system platform, such as the actions the User take within and outside of the Services, the browser the User use, the identity of other apps included on the User’s device, the date and time of the User’s use of the Services, the User’s game progress, play time, score and achievements, and the URLs the User visited and/or apps the User used before and after using our Services; “Personal Data” which is information about an identifiable individual as such term is defined in the General Data Protection Regulation (GDPR) (EU) 2016/679 of the European Parliament and of the Council, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, as this term may be amended by law. Personal Data may include, but is not limited to, a person’s name, email address, residential address, precise geolocation information (i.e., the User’s specific location), telephone number, payment card information, transaction history, other billing information and, in some cases, usernames; “Services” including, but not limited to the Site, the Software, mobile services and their
applications, downloadable and/or installable services for personal computers or gaming consoles including clients and web-based services accessed by means of a browser or other online communication method, and also includes all updates, upgrades, patches or other improvements as well as any and all accompanying manuals, packaging and other written documents, files, digital or other online materials or documentation and any and all copies of all such software and materials, and any part thereof; and “Site” refers to the site http://holydaygames.com/.
ACCEPTANCE OF TERMS AND REVISIONS
INFORMATION COLLECTED AND APPLICATION
Holyday Studios may partner with third party Service Providers to provide access to existing payment gateways. The User’s credit card, banking and other billing information is kept with payment processors and other service providers where the User can read more about their privacy policies.
PRODUCTS OFFERED IN PARTNERSHIP WITH THIRD PARTIES
COLLECTION OF INFORMATION
Holyday Studios only collects the following Non-Personal Data as permitted by law and as follows:
1. Holyday Studios may collect information such as the User’s username, player ID and city of residence.
2. Holyday Studios will not collect any Personal Data from the User simply by virtue of the User’s visiting any of our websites; Holyday Studios will only collect it if the User chooses to submit it to Holyday Studios. Holyday Studios do, however, collect Non-Personal Data such as device IDs and usage data (such as save files), whenever the User uses the Services. Such Non-Personal Data is not combined with Personal Data unless the User chooses to submit Personal Data to us.
Holyday Studios does not collect Personal Data through the use of our Services unless the User chooses to provide it. If the User does not wish to have Holyday Studios collect the User’s Personal Data the User can choose not to provide it.
USE OF INFORMATION
Holyday Studios may use the User’s information for administrative, analytical, research, optimisation, security and other purposes, including, without limitation, for the following purposes and where applicable:
1. to provide the User with any goods, services, or functionality the User have requested,including the Services;
2. to improve our Services, and any future Services Holyday Studios may produce;
3. to send the User information related to our Services, including confirmations, technicalnotices, updates, security alerts, and support and administrative messages;
4. to track the User’s use of our Services to help us learn more about the User’s activities and understand the User’s preferences and tendencies so that Holyday Studios can personalise the User’s experience, provide the User with offers and notifications that are tailored to the User, and otherwise enhance the User’s experience; to personalise the User’s content and offers;
5. to respond to customer service inquiries;
6. to troubleshoot problems with the Services and to improve Services;
8. to protect against cheating, crime or fraud, or for other security reasons;
9. to provide the User advertising that better suits the User’s interests and profile and is age/gender-appropriate and targeted to the User’s general location;
10. to compile statistics;
11. to take any other action permitted by law.
DISCLOSURE OF INFORMATION
Holyday Studios will not transfer the User’s data (including Personal Data) to third parties, except for our business partners who have agreed to comply with legally required privacy standards and who will use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose. Notwithstanding the foregoing, Holyday Studios reserves the right to disclose information, including Personal Data, if Holyday Studios reasonably believes that Holyday Studios are required to do so by law or legal process or if Holyday Studios are otherwise requested by any law enforcement officer or agency acting in such a capacity as to allow the disclosure of such information by law.
In addition, Holyday Studios reserve the right to disclose Personal Data and Non-Personal Data in order to:
2. investigate and/or take action against illegal activity, suspected abuse or unauthorised use of the Services;
3. protect and defend the rights or property of Holyday Studios; and
4. act in urgent circumstances to protect the safety or security of the public or users of the Services.
PROTECTION OF INFORMATION
Holyday Studios has implemented reasonable physical and technical measures to protect the information Holyday Studios collect or are provided with from unauthorized access or against loss, misuse or alteration by third parties. Further, while Holyday Studios attempt to ensure the integrity and security of our network and systems, Holyday Studios cannot guarantee that our security measures will prevent third-parties from illegally obtaining access to this information.
Holyday Studios do not warrant or represent that the User’s information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Holyday Studios cannot guarantee its absolute security. For further information on how Holyday Studios protects information Holyday Studios collect or are provided with, contact us using the information listed below.
RETENTION OF INFORMATION
The data and information that Holyday Studios collect will be stored and maintained by Holyday Studios or our third party service providers until the User instruct us otherwise, or, in our sole discretion, for the longer of (i) the amount of time necessary or appropriate to carry out the purpose(s) for which such information was collected and (ii) for so long as Holyday Studios are required to maintain such information by law or other applicable rules or regulations and the User’s consent to such purposes remains valid after termination of our relationship with the User.
Currently, Holyday Studios or our third party service providers retain and store information collected by, or provided to, us on secure servers in Amazon Datacenters (Oregon and Ireland). As Holyday Studios and some of our third party service providers may store information received from users (including Personal Data) outside of these locations, and under the laws of those other jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or
security authorities in those other provinces or foreign jurisdictions may be entitled to access information.
The User is responsible for maintaining the confidentiality of the User’s account and/or passwords as these may be applicable or required to access the Services and for restricting access to the User’s computer, device or game system platform, and the User agrees to accept responsibility for all activities that occur under the User’s account.
ACCESS AND ACCURACY
Holyday Studios will use commercially reasonable efforts to provide the User access to the User’s Personal Data (to the extent Holyday Studios are in possession of any) if the User requests such access in writing submitted to Holyday. Unless otherwise required under applicable law, Holyday Studios reserves the right to deny access to the User’s Personal Data:
1. when such denial of access is required by law;
2. when granting the User access is reasonably likely to negatively impact other people’s privacy;
3. when such access is cost prohibitive; or
4. when such requests are frivolous or made in bad faith.
The User is responsible for ensuring that all information created through the User’s use of any of our Services is accurate, reliable and complete and the use of information created from our Services is at the User’s own risk. Holyday Studios ask that the User keeps the Personal Data that the User
provides to Holyday Studios current and correct.
The User represents and warrants that any Personal Data the User provides is true and correct and relates to the User and not to any other person. If the User believes that any Personal Data maintained by Holyday Studios about the User is inaccurate or incomplete, the User may notify Holyday Studios in writing describing in details any inaccuracies or omissions, submitted to the email address below. Following receipt of such a properly submitted written notice, Holyday Studios will, within a reasonable time period, use commercially reasonable efforts to, in Holy Studio’s sole discretion, to either: (i) amend or correct the User’s Personal Data to reflect corrected or additional information provided by the User, or (ii) in connection with the User’s Personal Data, make note of any claimed inaccuracies or omissions reflected in the notice submitted by the User.
OUR POLICY REGARDING CHILDREN
Holyday Studios recognizes the privacy interest of children and Holyday Studios encourage parents and guardians to take an active role in their children’s use of our Services. Our Services are not intended for children under the age of 13 (“Minors”) and Holyday Studios do not target our Services to Minors. Holyday Studios does not knowingly collect or use any Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the email address below. Holyday Studios will delete such information from our files within a reasonable time.
If the User is between the age of 13 and 18, the User must obtain their parent or guardian’s permission prior to using any of the Services or providing Holyday Studios with any Personal Data.
Those who choose to use or access any of the Services from outside the Cyprus do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the Internet, each viewer and user shall comply with all local rules regarding online conduct and submission of acceptable materials.