Introduction
Game
Story Ltd.
(“Game Story”, “we”, “our” or “us”) develops and operates skill-based mobile games offering real-money
tournaments and associated activities (“Apps”). We also operate the
website https://gmstry.com/, its
subdomains, and related features (“Website,” collectively with the Apps referred to as the “Services”).
We
are dedicated to protecting your privacy rights and making our practices
regarding your Personal Data (as defined below) more transparent and fairer. This
Privacy Policy (“Policy”) explains how we collect, use, store, and
disclose your Personal Data and your rights regarding it. The Policy applies
whenever you visit our Website, use our Apps, or otherwise interact with the
Services.
Specifically,
this Policy describes ––
1. What types of Personal Data we collect?
2. Tracking
Technologies
3. Why
we process your Personal Data?
4. With
whom we share your Personal Data?
5. Marketing
and advertising
6. Your
rights
7. Transfer
of Personal Data
8. How
we protect your Personal Data?
9. Minors
10. Retention
11. Updates to this Policy
12. Controlling version
13. Data Protection Officer
14. Contact us
We strongly urge you to
read this Policy and make sure that you fully understand and agree to it. If
you do not agree to this Policy, please discontinue and avoid using our
Services. You have the right to cease using our Services, pursuant to this
Policy, at any time.
You
are not legally required
to provide us with any Personal Data, but without it we will not be able to
provide you with the full range or with the best experience of using our
Services.
This
Policy is integrated into and forms part of the Game Story Terms of Service
which are currently available here.
1. What types of Personal Data we collect?
We
collect Personal Data about you, meaning any information which potentially
allows your identification with reasonable means (for example, email address or
name, collectively “Personal Data“).
This section sets out the types of Personal Data we collect and process about
you.
1.1.
Account Information. If you choose to register an
account with our Services, we collect your full name, email address, username
1.2.
1.3.
Technical
Information. When you use our Services, we collect technical
information about your device and your interaction with our Services. Such
information may include: (i) device and other unique identifiers; (ii)
geolocation; (iii) device and operating system type and version etc.
1.4.
Usage Information. When using our Services we
collect information about your usage, including but not limited to: (i)
deposits and withdrawal; (ii) gameplay recording and data; (iii) usage
statistics etc.
1.5.
Communication Information. When you
send us an email or contact us the Services’ support, we collect the Personal
Data you provide us. This may include your name, email address and any other
information you choose to provide.
2. Tracking Technologies
When
you visit or access our Services, we use cookies, pixels, beacons, local
storage and similar technologies (“Tracking
Technologies“). These allow us to automatically collect information
about you, your device, and your online behavior, in order to enhance your
navigation in our Services, improve our Services performance, perform
analytics, customize your experience, and offer you, for example, tailored
content and advertisements that better correspond with your interests.
2.1.
What types of Tracking Technologies do we use?
When
you use or access our Services, we use the following categories of Tracking Technologies:
(a)
Strictly
Necessary Tracking Technologies – These
Tracking Technologies are automatically placed on your computer or device when
you access our Services or take certain actions on our Apps or Websites. These
Tracking Technologies are essential to enable you to navigate around and use
the features of our Services. We do not need to obtain your consent in order to
use these Tracking Technologies.
(b)
Tracking
and Advertising Tracking Technologies – These Tracking
Technologies collect information about your browsing habits in order to make
advertising more relevant to you and your interests. They are also used to
limit the number of times you see an advertisement as well as help measure the
effectiveness of an advertising campaign. The Tracking
Technologies remember the websites you visit and that information is shared
with other parties such as advertisers or publishers.
(c)
Functionality
Tracking Technologies – These Tracking Technologies
allow our Services to remember choices you make (such as your language) and
provide enhanced and personalized features. For example,
these Tracking Technologies are used for authentication (to remember when you
are logged-in) and support other features of our Services.
(d)
Performance
Tracking Technologies – These
Tracking Technologies collect information about your online activity (for
example, the duration of your visit on our Services), including behavioural
data and content engagement metrics. These Tracking Technologies are used for
analytics, research and to perform statistics (based on aggregated
information).
2.2.
How and by whom Tracking Technologies are stored on your device?
We store
Tracking Technologies on your device when you visit or access our Services (for
example, when you are visiting our Website) – these are called “First
Party Tracking Technologies”. In addition, Tracking Technologies are
stored by third parties (for example, our analytics service providers, business
partners, and advertisers), who run content on our Services – these are called
“Third Party Tracking Technologies”. Both types may be stored temporarily during your session
(session cookies) or for longer periods (persistent cookies) depending on the
purpose.
2.3.
Managing Tracking Technologies
There are various ways in which you can manage and control your
Tracking Technologies settings. You can change your preferences using our cookie settings tool (available
in jurisdictions where required by law). Other
methods of managing your Tracking Technology preferences include: changing your
browser settings to send a “Do-Not-Track” signal. In such case, your browser
will send us a special signal to stop tracking your activity. However, please
note that certain features of the Website may not work properly or effectively
if you delete or disable cookies.
To learn more about how you can manage your cookies, below is a
list of useful links that can provide you with more information:
(a)
Google
Chrome
(b)
Microsoft
Edge
(c)
Mozilla
Firefox
(d)
Safari
(Desktop)
(e)
Safari (Mobile)
(f)
Android
Browser
You can learn more and turn off certain third party targeting and
advertising cookies by visiting the following third-party webpages:
(a)
The
Interactive Advertising Bureau (US)
(b)
The
Interactive Advertising Bureau (EU)
(c)
European Interactive Digital
Advertising Alliance (EU)
You can withdraw your consent to personalized advertising
experience on your device at any time by using your device settings as follows:
(a) On iOS, depending on the applicable iOS version, you may withdraw
consent across all apps by either enabling the “Limit Ad Tracking” setting or
disabling the “Allow Apps to Request to Track” permission in your iOS device
settings. Depending on the applicable iOS version, instead of withdrawing
consent on a device-wide basis, you may also have the option of withdrawing
consent on a per-app basis by disabling tracking permissions for specific apps
that appear under the “Allow Apps to Request to Track” setting in your iOS
device settings (precise directions may differ depending on the applicable iOS
version).
(b) On Android devices, you may withdraw your consent in the Google
Ads settings within your Android settings by enabling the “Opt out of Ads
Personalization” setting (precise directions and the name of the setting may
differ depending on the applicable Android versions and device manufacturer).
3. Why we process your Personal Data?
This section explains
for what purposes we use your Personal Data,
|
Purpose |
Legal Basis |
|
Provision of our Services; support. We use your Personal Data, such as your name and email address, and
other account and usage information, to provide and enhance our Services.
This includes responding to your inquiries and facilitating support. |
The legal bases for processing this data are the performance of
our contractual obligations towards you; your consent; and our legitimate
interests. Our legitimate interests in this case are provision of our
Services and supporting our customers. |
|
Payments. We collect certain payment information for the purpose of
connecting your payment instrument to your account on our Services, making
charges and sending you statements and invoices. |
The legal bases for processing this data are the performance of
our contractual obligations; the protection of our legitimate interests, in
this case provision of our Services; and compliance with legal obligations to
which we are subject. |
|
Improve our Services. We collect and analyse information about you and your usage of
our Services to improve the usability and effectiveness of our Services,
including to enhance gameplay and customer experience. |
The legal bases for processing this data are our legitimate
interests, in this case – providing and improving our Services. |
|
Marketing and Advertising. We use certain usage and contact information in order to provide
you with personalized advertisements when you visit our Services or other
third-party services, including personalized and non-personalized
advertising. We may also use your email and other contact details for
promotional purposes. |
|
|
Integrity and fraud prevention. When you create an account, play our games, make payments or
withdrawals or otherwise interact with our Services, we may use your Personal
Data for anti-cheating and fraud prevention and anti-money laundering
purposes and to enforce our policies. |
The legal bases for processing this data are your consent (where
required), compliance with our legal obligations, and our legitimate
interests. Our legitimate interests in this case are keeping the integrity of
our Services and the safety of our end-users.
|
|
Compliance with applicable laws. We process your Personal Data in order to comply with our legal
obligation under applicable laws. This may include responding to lawful requests
by public authorities, preventing fraud, ensuring compliance with data
protection laws and to exercise or defend our legal claims. |
The legal basis for
processing this data is compliance with our legal obligations and our
legitimate interests. Our legitimate interests in this case are compliance
with our legal obligations and assisting law enforcement agencies.
|
|
Mergers and acquisitions. We may transfer, sell or otherwise
share your Personal Data in case of entering into a business transaction such
as merger, acquisition, investment reorganization, bankruptcy, or sale of
some or all of our assets. |
The legal basis for processing this data is your consent (where
legally required) or our legitimate interests. Our legitimate interests in
this case are business and commercial interests. |
4. With whom we share your Personal Data?
We may share, sell and
disclose your Personal Data as described below:
(a)
Affiliated
companies: We may share Personal Data internally with our affiliated
companies and subsidiaries, for the purposes described in this Policy.
(b)
Payment
processors: We share your payment information with third party payment processors,
for the purpose of facilitating your payments when using our Services.
(c)
Service
providers: We may share your data with third-party service providers who
assist us with various tasks, including customer service, hosting, email
delivery, and marketing support.
(d) Advertising partners: We partner with third
parties to either display advertising our Services or to manage our advertising
on third party websites and apps. Such third parties may collect or receive
Personal Data (including through Tracking Technologies), as well as aggregate
metrics on ad performance and usage statistics.
(e) Third
Party Integrations: The Services may allow you to integrate
with certain third party services, such as in order to connect your Facebook or
Apple account to our Apps, in which case you will be bound by the terms and
conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook). Please make sure that you read
and accept them in advance. We do not receive or store your passwords for any
of these third-party services.
(f)
Governmental
bodies and law enforcement entities: We may
disclose any Personal Data about you to government or law enforcement officials
or private parties as we, in our sole discretion, believe necessary or
appropriate to respond to claims and legal procedures (including but not
limited to subpoenas), to protect our or a third party’s property and rights,
to protect the safety of the public or any person, or to prevent or stop any
activity we may consider to be, or to pose a risk of being, illegal, unethical,
inappropriate or legally actionable. We may also be required to disclose an
individual’s Personal Data in response to a lawful request by public
authorities, including meeting national security or law enforcement
requirements.
(g)
Auditors
and advisers: We may share your Personal Data with our
external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers)
for ensuring our compliance with regulatory requirements and industry standards
and resolve disputes.
(h)
Potential
investors and acquirers: we may transfer, sell or
otherwise share your Personal Data with third parties such as potential
investors or acquirers in case of entering into a business transaction such as
merger, acquisition, reorganization, bankruptcy, or sale of some or all of our
assets.
In the 12 preceding
months, we have collected or disclosed the following categories of Personal
Data:
|
Category of Personal Data
Collected |
Personal Data Collected |
Categories of
recipients to whom Personal Data was disclosed for a business purpose |
Categories of
recipients to whom Personal Data was shared/sold (as these terms are define
under the CCPA) |
|
Identifiers |
Full name, email address, social media identifiers,
username, birthdate, IP address, MAC, UDID, telephone number, debit or credit
card number, passport or other government or state ID card number. |
Affiliated companies Service providers Payment processors
|
Advertising networks |
|
Protected classification characteristics (under the
relevant applicable laws)
|
National origin, citizenship |
Affiliated companies Service providers Payment processors |
N/A |
|
Commercial data |
Product or services purchased
|
Affiliated companies Service providers Advertising networks
|
Advertising networks
|
|
Biometric Data
|
Faceprints
|
Service providers |
N/A |
|
Internet or Other Electronic Network Activity Information |
Browsing history, search history, information on a
consumer’s interaction with a website, application, or advertisement. |
Affiliated companies Service providers
|
Advertising networks
|
|
Geolocation Data |
Physical location or movements, including the location of
your device location or movement.
|
Affiliated companies Service providers |
Advertising networks
|
Sources of Personal
Data
In
the 12 preceding months, we have collected the above-mentioned categories of Personal
Data from the following categories of sources:
●
Consumer
directly. Personal Data you provide to us directly through account
registration, gameplay, or other interactions.
●
Advertising
networks. Personal Data collected through Tracking Technologies used for
advertising and other Personal Data that may be share by our advertising
partners.
●
Social
networks. Personal Data obtained through integrations with third-party
social networking platforms when you use their services to connect with us.
●
Payment
processors. We may receive certain Personal Data about you
from our payment processors in order to process your payments.
●
KYC
Providers. When running KYC checks, we may get Personal Data about you from
our KYC providers.
5. Marketing and advertising
We may use your Personal Data ourselves or by
using our third-party subcontractors for the purpose of providing you with promotional
materials concerning the Services as well as products, services, websites and applications
which relate to: (i) affiliated companies; or (ii) Game Story’s business
partners and affiliates (collectively, “Marketing
Affiliates”), which we believe may interest you.
You may at
any time decline receiving further marketing offers from us or from our
business partners and Marketing Affiliates by
Please note that even if you unsubscribe from
our marketing mailing list, we may continue to send you
6. Your rights
Depending on the
jurisdiction in which you reside, you may have certain rights under relevant
applicable laws regarding the collection and processing of your Personal Data.
To the extent these rights apply and concern you, you can contact us via the
contact details available below and ask to exercise the following rights.
6.1.
Rights of access to your Personal Data:
You have the right to
receive confirmation as to whether or not Personal Data concerning you is being
processed, and access your stored Personal Data, together with supplementary information.
6.2.
Right of data portability:
You have the right to
request us to move, copy and transfer your Personal Data easily from one IT
environment to another, in a safe and secure way, without affecting its
usability.
6.3.
Right of rectification:
You have the right to
request rectification of your Personal Data in our control in the event that
you believe the Personal Data held by Game Story is inaccurate, incomplete or
outdated.
6.4.
Right of deletion/erasure:
You have the right to request that Game Story erases or deletes Personal Data held about
you at any time.
6.5.
Right to restriction or objection to processing:
You have the right to
request that Game Story restricts or ceases to conduct certain Personal Data
processes at any time.
6.6.
Right to withdraw your consent:
To the extent we process
Personal Data on the basis of your consent, you have the right to withdraw your
given consent at any time.
6.7.
Right to limit use and disclosure of your sensitive Personal
Data:
You have the right to
request to limit the collection of your sensitive Personal Data, to that use
which is necessary to perform our Services.
6.8.
Right not to be subject to automated decision making:
You have the right not to be
subject to a decision based solely on automated processing, including
profiling, which produces legal effects or similarly significantly effects to
you.
6.9.
Right to opt-out of the sale or share of Personal Data:
You have the right to submit
a request to opt-out of the sale or share for behavioural advertising purposes of
your Personal Data. After you opt-out, we may continue disclosing some Personal
Data to our partners to help us perform business-related functions such as, but
not limited to, providing the Services, ensuring that the Services are working
correctly and securely, providing aggregate statistics and analytics and
preventing fraud.
6.10.
Right to non-discrimination:
You have the right to be
free from any discrimination for exercising your rights, such as offering you
different pricing or products, or by providing you with a different level or
quality of services, based solely upon your request.
Please note that these
rights are not absolute and may be subject to our own legitimate interests and
regulatory requirements. You are welcome to contact us for any
questions or requests through our contact details below. If you are unsatisfied
with our response, you can lodge a complaint with the applicable data
protection supervisory authority.
Authorized
agent
(a)
You can use
an authorized agent to make a request to exercise your rights under applicable
laws on your behalf if:
i.
The
authorized agent is a natural person or a business entity; and
ii. You sign a written declaration that you authorize the authorized
agent to act on your behalf. If you use an authorized agent to submit a request
to exercise your right, please provide us with a certified copy of your written
declaration authorizing the authorized agent to act on your behalf using the
contact information below.
(b)
The request
must:
i.
Provide sufficient
information to allow us to reasonably verify you are the person about whom we
collected Personal Data or an authorized agent. We cannot respond to your
request or provide you with Personal Data if we cannot verify your identity or
authority to make the request and confirm the Personal Data relates to you; and
ii.
Describe
your request with sufficient details to allow us to properly understand,
evaluate, and respond to it.
(c)
We will
only use Personal Data provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request.
(d)
Making a verifiable
consumer request does not require you to create an account with us.
7. Transfer of Personal Data
We operate globally,
thus any information that we collect, disclose or share, including your
Personal Data, can be stored and processed in various jurisdictions around the
world, including (but not limited to) the European Economic Area (EEA), the United
Kingdom (UK), Israel and the United States, for the purposes detailed in this
Policy.
To
ensure that your data is protected during international transfers, we implement
appropriate safeguards, as required by applicable data protection laws. Where
the GDPR or UK GDPR apply, these include:
(a)
Transferring
Personal Data to recipients located in countries that have been deemed to
provide an adequate level of data protection under applicable laws (e.g.,
adequacy decisions by the European Commission for EEA-based data).
(b)
Executing
agreements with recipients based on the European Commission’s Standard
Contractual Clauses (SCCs) or other mechanisms approved under applicable laws,
ensuring that the Personal Data remains secure.
(c)
In cases where no adequacy decision or
appropriate safeguards are in place, we rely on specific derogations under the
GDPR, such as obtaining your explicit consent or ensuring the transfer is
necessary for the performance of a contract with you.
Please
note that privacy laws vary between jurisdictions, and the protections
available in the destination country may differ from those applicable in your
country of residence. If you reside in a jurisdiction where your consent is
required for transferring Personal Data internationally, you hereby provide us
with your express and unambiguous consent to facilitate the transfer to provide
our Services.
8. How we protect your Personal Data?
We have implemented
administrative, technical, and physical safeguards to help prevent unauthorized
access, use, or disclosure of your Personal Data. While we seek to protect your
information to ensure that it is kept confidential, no system or internet
transmission can be guaranteed to be 100% secure. You should be aware that
there is always some risk involved in transmitting information over the
internet and that there is also some risk that others could find a way to
thwart our security systems. Such breaches can lead to things such as
reputational harm, fraud or identity theft. Therefore, we encourage you to
exercise discretion regarding the Personal Data you choose to disclose. If you
feel that your privacy was treated not in accordance with our Policy, or if any
person attempted to abuse the Services or acted in an inappropriate manner,
please contact us directly via our contact
details available below.
9. Minors
We do not knowingly
collect or solicit Personal Data from anyone under
In the event we learn
that we have collected Personal Data from minor, we will delete that
information upon discovery. If you are a parent or guardian and you have
discovered that your child has submitted Personal Data to us, you can request
the deletion of your child’s information, please send an email to support@gmstry.com.
10. Retention
We will retain your
Personal Data for as long as necessary to provide our Services, and as
necessary
Retention periods will
be determined considering the type of Personal Data that is collected, the
purpose for which it is collected, and applicable legal requirements. For
example, we may retain certain Personal Data for a few years after account
closure if required to meet legal obligations or exercise legal rights. We
strive to delete or anonymize outdated, unused information promptly and
securely.
11. Updates to this Policy
We reserve the right to
change this Policy at any time. The most current version will always be posted
on our Services (as reflected in the “Last Updated” heading). If we decide to
make material changes, we will notify you by placing a notice on our website or
by sending a notice to the email address on file. You are advised to check for
updates regularly.
12. Controlling Version
The Privacy Policy has
been drafted in the English language, which is the original and controlling
version of this Privacy Policy. All translations of this Privacy Policy into
other languages shall be solely for convenience and shall not control the meaning
or application of this Privacy Policy. In the event of any discrepancy between
the meanings of any translated versions of the Privacy Policy and the English
language version, the meaning of the English language version shall prevail.
13. Data Protection Officer
The Company has a “
14. Contact Us
If you have any further
questions, please contact us by email at: support@gmstry.com.