Promotion Privacy Notice

Effective Date: November 10, 2023

Plarium Global Ltd and its affiliates (“Plarium” or “we”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). This Promotion Privacy Notice (the “Notice”) has been provided to inform you as to the ways we collect, store, use, and manage (“process”) your personal information when you participate in the promotions organized by us (“the Promotion”).

“Personal information” means any information relating to an identified or identifiable natural person, thus who can be identified, directly or indirectly.

Plarium Privacy Policy and the Terms and Use for our website (collectively, the “Site”), or any Plarium game or application (the Site, games and applications are, collectively, the “Service”) apply to the use of our Services when participating in the Promotions as well. You can read them here: Plarium Privacy Policy https://plarium.com/en/legal/privacy-and-cookie-policy/ ; Plarium Terms of Use https://plarium.com/en/legal/terms-of-use/ , In addition, by participating in the Promotion, you agree to the terms of the Administrators' Privacy Policy. and Twitch.tv Privacy Policy https://www.twitch.tv/p/en/legal/privacy-notice/.

Please note that the scope of this Notice is limited only to information collected by Plarium through a participation in the Promotion by using the Site or the Service. This Notice does not apply to the practices of third parties that Plarium does not own or control.

Plarium is the controller of your personal information collected within the Promotion and will process your personal information in accordance with applicable law. If you do not agree to this Privacy Notice, please do not participate in our Promotions.

Processing of your personal information for the performance of the Promotion

If you choose to participate in our Promotions, we ask you to provide your User I.D., Twitch.tv I.D. and Email address as required on the Twitch Extension Signing-in page. We process this information so that you can participate in our Promotions and so that we can send you by Zorka Mobi Ltd (the “Administrator” as specified in the Promotion Official Rule) Prize Notification, in accordance with the Official Rules agreed between us.

If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.

In the cases outlined above the legal basis for processing your personal data is the performance of a contract.

You are under no obligation to provide us with any personal data, but if you don’t provide all relevant information, we may not be able to help respectively you may not be able to participate in the Promotion.

Processing of your personal information for other purposes

Your personal information will be used primary for the purposes of managing and administering the Promotion, including contacting you if you are a winner and to respond to your inquiries as outlined above.

In addition, we may use user information for the following purposes:

Protecting rights and interests. To protect the safety, rights, property, or security of Plarium, the Service, any third party, or the general public; to detect, prevent or otherwise address fraud, security or technical issues; to prevent or stop activity which may be consider to be, or to pose a risk of being, an illegal or legally actionable activity; to use as evidence in litigation; and to enforce this Notice and our Promotion Official Rules.

The legal basis for processing your personal data in this regard is our legitimate interest to protect our Site and Services, defend our rights and to prevent and track unauthorized activities.

Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

The legal basis for processing your personal data in this regard is the compliance with a legal obligation according to Art. 6 (1) lit. c) GDPR.

Corporate Transaction. We may transfer your personal information to third parties as part of a corporate transaction (Asset Deal).

The legal basis for processing your personal data in this regard is our legitimate interest according to Art. 6 (1) lit. f) GDPR to sell our company or merge with other entities or your consent according to Art. 6 (1) lit. a) GDPR as far as legally required.

Publication of your name as a winner. In case you are a winner of the Promotion we will publish your name on a winner’s list provided you have consented to a respective publication.

The legal basis for the processing of your personal data in this regard is your consent according to Art. 6 (1) lit. a) GDPR.

We do not perform automated decision making (including profiling).

Sharing of personal information with third parties

We do not sell the personal information we collect. We do, however, disclose personal information as described in this policy. In the past 12 months, we have disclosed personal information to the following categories of recipients:

Other Plarium users. If you win a Promotion, we may share and publish your name with regards to the winner publicly, with other Plarium users in our Services, provided you have given your consent to do so.

Third parties for legal, fraud prevention, and security purposes. We may share your information with third parties as required by legal or regulatory obligations; as requested by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; or as Plarium otherwise deems necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to Plarium or others.

Third-party service providers and Partners. insofar as it is reasonably necessary for the purposes set out in this privacy notice, we may share your personal information with third party companies that perform services on our behalf such as: hosting services and customer service. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested service. Under the same conditions, we may partner with a third party as specified in the Promotion Official Rules in order to assist us fulfill our obligations to you under our Promotion Terms of Use.

Third parties in the context of a merger, acquisition, corporate transaction, or other legal process. We may disclose your information to another entity in connection with, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

International Transfers

We may transfer your personal information outside your country of residence, including possibly to countries that do not provide a level of data protection equivalent to your country of residence. Please note that Plarium is located in Israel, a country that is deemed to provide an adequate level of data protection according to an adequacy decision of the European Commission.  Where Plarium onward transfers your personal information to a company located outside of Israel, or the EU, we will take steps to ensure that your information is given a similar level of protection as that given in Israel or the EU by concluding standard contractual clauses. You have the right to request from us information about, including a copy of, the contractual safeguards Plarium puts in place to achieve this.

Data retention

We will keep your information for as reasonably necessary for the purposes set out above in accordance with applicable law, generally no longer than 3 years from the date you stopped using our services. To determine the appropriate retention period, we will consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process the personal information and whether we can achieve such purposes through other means, as well as applicable legal and regulatory requirements.

Security

We have implemented technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, please note that no system or network is 100% secure and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes.

Your rights and choices in relation to your personal information

Subject to the respective legal requirements, you are entitled to the following data protection rights:

You have the right to request information from us about the personal information we hold in relation to you and correct any inaccurate data we hold

You also have rights to request that we delete any personal information about you, if you decide to delete or anonymize your personal information, you may no longer be able participate in our Promotions.

You also have a legal right to ask for a restriction of processing and the right to data portability.

You also have the right to withdraw your consent, on the basis of which we process your personal information, at any time. However, this does not affect our lawful processing based on your consent before this withdrawal.

You may object to processing based on our legitimate interests, on grounds relating to your particular situation. In this case, we will re-examine the corresponding data processing. You may also object at any time to the processing of your personal data for direct marketing purposes, including profiling, in order to stop such processing.

California Residents Rights:

The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months; (2) request deletion of your personal information; (3) opt out of sale of your personal information (for the purposes of CCPA, we do not sell your Personal Information) ; and (4) not be discriminated against for exercising these rights.

If you or an authorized agent wants to exercise any of these rights, please contact us at: privacy.support@plarium.com or via https://dsr-support.plarium.com/hc/requests/new. You can freely exercise these rights and choices. Once we receive your request from you, we may verify it through your account or by requesting information sufficient to confirm your identity.

While we prefer that you contact us in case you have any issue or feel we do not respond adequately to your questions or concerns, please note that you have a right to lodge a complaint with your competent supervisory authority.

Links to other websites or applications

Links from the Plarium Service to third party websites or applications are provided for your convenience. In addition, content in the Service may be hosted by other websites or applications. Any personal information you provide on the linked pages or applications is provided to that third party and is subject to that third party's privacy notice, not ours. These other websites and applications maintain their own policies regarding cookies and the collection and use of personal information. We encourage you to review those policies yourself.

Policy regarding Minors

The terms of our Promotions prohibit users aged under 18 years from participating our Promotions and we do not knowingly collect data relating to minors under the age of 18.

If we become aware that personal information from a child has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you learn about any personal information, we have collected from a child under age 18, please contact us immediately.

Changes to this Notice

Plarium may amend this Notice from time to time. Use of information we collect now is subject to the Notice in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you, such as by posting an announcement on our Service or sending you an email to an email address that you may have provided to us.

Questions or concerns & contact details

In compliance with Art. 27 GDPR, we have appointed Plarium Europe S.A.R.L. as our representative for GDPR purposes in the EU.  You may address questions relating to the way we process your personal information either to Plarium at the address identified below, or to our representative at the following address: 9, Allée Scheffer, L-2520 Luxembourg.

If you have any questions or concerns regarding privacy at Plarium, please contact us at:

Email: privacy.support@plarium.com.

Postal address: Plarium Global Ltd. (Company number 514563956)

2 Abba Eban Blvd.

Herzliya, Israel