Last updated [December 02nd, 2020]
We respect the privacy of our users and every person who visits our Mobile Application VNM App. Here, ORPHIC GAMES refers to as (“we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy in accordance with General Data Protection Regulation (GDPR). If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at email@example.com.
At VNM, we offer you a meticulously designed app that’s allows users to find and post events based on certain preferences picked. The user’s signs up and logs in by putting their phone number in and being sent a verification code. The users then pick from a selection of music genres and event types, and shares location to show them events near them matching their requirements. Any user can post an event with a 8 hour gap in between. Any user can report an event, if an event gets enough reports it will get taken down. If a user gets 3 of their events taken down their account will be blocked.
We are located in United Kingdom.
WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when registering with us, expressing an interest in obtaining information about us or our services, when participating in activities on the Mobile Application, or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Mobile Application, the choices you make, and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first name, email address, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Google, or other social media account.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Mobile Application. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Mobile Application and other technical information. If you access our Mobile Application with your device, we may automatically collect device information (such as your device ID, model, and manufacturer), operating system, version information, and IP address. This information is primarily needed to maintain the security and operation of our Mobile Application, and for our internal analytics and reporting purposes.
Information collected from other Sources
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties.
HOW DO WE USE YOUR INFORMATION?
We use your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is under your marketing preferences. You can opt-out of our marketing emails at any time (see below).
To send administrative information to you for related to your account, our business purposes, and/or for legal reasons. We may use your personal information to send you a product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Mobile Application.
To protect our Mobile Application for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Mobile Application safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications with your consent. We may use your information to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions, and policies for our business purposes and as legally required.
To respond to legal requests and prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Mobile Application, products, services, marketing, and your experience.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share and disclose your information in the following situations:
Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.
Business Transfers. We may share or transfer your 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.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you use the Mobile Application. These companies may use information about your usage of our Mobile Application and other websites that are contained in web cookies and other tracking technologies to provide advertisements about goods and services of interest to you.
With your Consent. We may disclose your personal information for any other purpose with your consent.
Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Mobile Application) or otherwise interact with public areas of the Mobile Application, such personal information may be viewed by all users and may be publicly distributed outside the Mobile Application in perpetuity.
A cookie is a small text file that a website or Mobile Application saves on your computer or device when you access the Mobile Application. In general, cookies have two main purposes: to improve your browsing experience by remembering your actions and preferences and to help us analyze our website traffic.
You are always free to delete cookies that are already on your device through your application settings, and you can set to prevent them from being added to your device.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers are located in Great Brittan, London, Enfield We will not transfer your personal information to an overseas recipient.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Mobile Application is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 16 years of age. By using the Mobile Application, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Mobile Application. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us at firstname.lastname@example.org.
EU General Data Protection Regulation (GDPR) has provided the below rights to the EU residents:
Right to information - The purposes for processing Personal Information and the rights of the individual.
Right to access the Personal Information that is processed.
Right to erasure (”Right to be forgotten”).
Right to rectification.
Right to restriction of the processing.
Right to object (opt-out) to processing.
EU residents can exercise these rights by raising a request directly at email@example.com
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
ACCESS AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer 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 purpose 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 (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that Mobile Application to delete your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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 provider(s) 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 (including fraudulent user-generated content such as product reviews), or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise a 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.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our mobile application. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within 12 months. The verifiable consumer request 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 Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
OPT-OUT AND OPT-IN RIGHTS
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers if 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 Personal Information sales may opt-out of future sales at any time.
exercise the right to opt-out, you (or your authorized representative) may submit a request to us at email: firstname.lastname@example.org.
We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our Mobile Application, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our Mobile Application or write us at our email address listed on our webpage.
WHAT ARE YOUR PRIVACY RIGHTS?
You may at any time review or change the information in your account or terminate your account by:
Contacting us using the contact information provided below
Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented us for Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on Third-Party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.
Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on Mobile Applications, including our App. However, on many devices, App users may opt-out of certain ads via their device settings.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration. You can also opt-out by:
Contacting us using the contact information provided below.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Mobile Application.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions concerning this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection Officer, at our e-mail firstname.lastname@example.org
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, email us at email@example.com