Effective Date: 01 October 2021
We, at PAVETRA LTD (“PAVETRA” “we” or “us”), are committed to respecting your privacy and the integrity and security of your personal data.
PAVETRA is data controller with registered office Andrea Kalvou 5, office 501, 3085, Limassol, Cyprus
This Privacy Policy applies to www.pavetra.app, all other sites or online services that is owned or operated by PAVETRA, all mobile games published by PAVETRA, PAVETRA games that can be played through third party platforms (collectively “Services”) We reserve the right to change our practices and this Privacy Policy at any time. Each time a user accesses our Services the current version of the Privacy Policy applies, and you agree that the personal data we collect will be subject to the Privacy Policy, as updated. We encourage you to check this page regularly so that you know our current practices.
By downloading, accessing and/or using our Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to PAVETRA’s and our partners’ use of your data for the purposes as described below. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, you should not use our Services.
The personal data we collect will depend on the circumstances and the Services you are using. We collect data in three ways: (a) data you provide to us; (b) data we collect automatically; and (c) data we collect from our partners.
a. Data you provide to us
Contact information (such as name and email address)
Your messages to the Services (such as chat logs and player support tickets)
Limited and tokenized payment information may be collected when making a purchase
Other data you choose to give us
b. Data we collect automatically
Data about your game progress
Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
Data about your device, such as device name and operating system, browser type and language
General location data
Precise geo-location data (GPS, with your consent)
Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services
c. Data we collect from our partners
Data we receive if you link a third party tool with the Services (such as Facebook, or Google)
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Data from platforms that the games run on (such as to verify payment)
Data for advertising and analytics purposes, so we can provide you a better Services
To make the Services work
To perform the contract, we process data necessary to:
Allow you to use our Services
Operate the Services
Verify and confirm payments
Provide and deliver products and services you request
Send you Services-related communications
To make the Services more suitable for our players
To provide a great Services to our players, we have a legitimate interest to collect and process necessary data to:
Develop and improve the Services and player experience
Manage our relationship with you
Provide social features as part of the Services
Customize your Services experience
Respond to your comments and questions and provide player support
Provide you our offers in the Services
Send you related information, such as updates, security alerts, and support messages
Enable you to communicate with other players
To show personalized advertisements
To show you personalized advertisements in the Services we have a legitimate interest to process necessary data to:
Track the content you access in connection with the Services and your online behavior
Deliver, target and improve our advertising and the Services
For information on how to opt-out from personalized advertisements, see section “Your rights and options” below.
To keep the Services safe and fair
In order to keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
Analyze, monitor and moderate use of the Services and its social features
Take action against fraudulent or misbehaving players
To analyze, profile, and segment
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
Apart from PAVETRA, your data can be accessed by others in the following situations:
Other players and users
Social features are a core component of our Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Other companies and public authorities
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
Our Service Providers and Partners
We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.
For further information please go to www.pavetra.app/list-of-partners.html
Our Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
Opt-out of targeted advertising
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device.
Apple devices:
Open Settings
Select Privacy
Select Advertising and enable "Limit Ad Tracking"
Android devices:
Open Settings
Select Google
Select Ads and enable "Opt out of Ads Personalization"
Access the personal data we hold about you
If you request, we will provide you a copy of your personal data in an electronic format.
Your other rights
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.
We will respond to all requests within a reasonable timeframe. You may also contact your local data protection authority within the EEA for unresolved complaints.
Opt-out of marketing emails and other direct marketing
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may then not function properly.
For further information go to www.pavetra.app/cookie-policy.html
Security Safeguards
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
Data retention
We keep your information only so long as we need it to provide our Services to you and fulfill the purposes described in this Privacy Policy. We do periodic status checks to review when personal data needs to be deleted. However, as we process your personal data for various purposes, the actual period for which the personal data will be stored will depend on the circumstances. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that we cannot identify you.
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for use only by those aged 16 and over. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.
If you are a California resident, the California Consumer Privacy Act (CCPA) gives you the right to request disclosure of information that we collect about you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information). This section describes how to exercise those rights and our process of handling those requests. We reserve the right to ask for reasonable information to verify your identity before we process your request.
You may submit once a year, free of charge, a verifiable request to disclose what personal information we collect about you. The easiest way to submit a request is to use the in-app support feature (“Contact Us”) in our games. You may also submit your request via e-mail at privacy@pavetra.app
You have the right to request that we delete any of your personal information we collected and retained, subject to certain exceptions. Once we receive and verify your consumer request, we will delete your personal information from our records. However, we may deny your deletion request if retaining the information is necessary for us or our service providers under certain circumstances, which will be explained to you at the time of the denial, if any. Should you wish any information about you deleted, you may use the in-app support feature (“Contact Us”) in our games or submit your request via e-mail at privacy@pavetra.app
You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances we may share your information with our partners, who help us deliver advertisements in our games tailored to your interests. To learn what information we collect and how we share it with third parties for advertising purposes, please, go to www.pavetra.app/list-of-partners.html.
If you would prefer that your personal information is not shared with third parties in this way, please, visit “Do Not Sell My Personal Information”.
We may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny your our Services; (ii) charge you different prices or rates for our Services; (iii) provide you a different level or quality of Services; (iv) suggest that you may receive a different price or rate for Services or a different level or quality of Services.
You may exercise your CCPA rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. We reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, we may deny the request.
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact us at privacy@pavetra.app