This Privacy Policy explains how personal information about you is collected, shared and used by Lotub.LLC and how you can exercise your privacy rights. This Privacy Policy applies to personal information that Lotub.LLC collect when you use Lotub.LLC's mobile game applications, forums, websites and other online products and services (collectively, the "Services") or when you otherwise interact with us.
This Privacy Policy governs all our Services.
We may amend and/or update this Privacy Policy from time to time by posting a new version in response to changing legal, technical or business reasons and developments. If we make material changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.
1. How We Collect Your Personal Data
We may collect information via our applications:
• We collect the following categories of your personal information and may sell it to third parties: identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences drawn from these categories.
• Your basic information such as your name, email address and gender etc if you connect your account with these social networks.
• Data about your device, model number, location and operation system
• There is however a social media component for your convenience. It is completely optional and turned off by default. How it works You may choose to connect your Facebook, Twitter or Google Plus profile for sharing your in-game achievements with your friends and other players. We may collect information about you in a variety of ways.
• We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
• User information from social networking sites including your name, your social network username, location, gender, birth date, email address, profile picture, image, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Application.
2. Use of information
We only collect, store and use your information if you have consented to it or, to the extent that it is necessary (i) for the performance of your agreement with us; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our global business. We have carefully balanced our legitimate business interests against your interests. Please contact us using the contact details provided below if you have questions on this balancing of interests.
We (or a third party data processor on our behalf) may collect, store and use information about you for the following purposes for the periods necessary to achieve such purposes:
1.Performance of Your Agreement with Us
①Provide our Services
②Provide and deliver the products and services you request, process transactions and send you related information
③Register you for an account on our Services and assist in the management of your account
④Register you for an account on our Services and assist in the management of your account
⑤Send you technical notices, updates, security alerts and support and administrative messages
⑥Process and deliver contest entries and rewards promoted by BNEI
2.Legitimate Interest
①For any purpose required or authorized for us to comply with our legal and regulatory obligations
②Monitor and analyze trends, usage and activities in connection with our Services
③Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity
④Obtain parent or legal guardian verification
⑤Provide contextual in-Service advertisement
⑥Monitor, analyze and develop our brands on social media by using social media monitoring services
3.Consent
①Communicate with you about products, services, offers, promotions, rewards, and events offered by BNEI and others, and provide news, information and other marketing materials that we think will be of interest to you
②Link or combine your data with other Services and with information we get from other sources to analyze service and monetization trends, create profiles of categories of users, create new games and services, and perform other analytics
③Link or combine with information we get from our advertising partners to help understand your needs and provide you with better in-Service personalized ads; serve in-Service advertisements that might be of interest to you; monitor and analyze trends, usage and activities in connection with the advertisements and our Services; creating profiles of types of Service users by combining your data with information from advertising partners
④Creating profiles of types of users by combining your data with information from our advertising partners, providing the data to our group companies, ad agencies and ad platforms to target advertisements of our (and our group company) games and services to you outside of this service, and otherwise performing advertising analytics and performance metrics
⑤For any other purpose for which you provided the information.
3. When we share information
We may share the information we collect about you (subject to necessary security, contractual and transmission safeguards). Below are some of the partners with whom we may share your personal data:
(a) user screening for internal functions of the application;
(b) third-party platform operators, such as Apple, Google Play, and other partner products that conduct various activities and services to support our products (collectively, "Platform Operators");
(c) advertising partners who serve advertisements in our products.
(d) marketing partners for marketing or promotions based on your communication preferences;
(e) in the event of a business reorganization, sale, purchase or joint venture affecting our business, the new owner or reorganizing entity and its advisers; and
(f) law enforcement agencies/authorities, when we are obliged to or authorized by law for law enforcement purposes.
Your personal data may be transferred to other countries where SEGA or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from which you access our products, but we will ensure that we rely on appropriate safeguards.
4. Children's Privacy
It is very important to us to protect the health of young children online. Accordingly, we do not knowingly collect or retain personal data or non-personally identifiable information from underage users, except as permitted by law to support our internal operations.
In this Privacy Policy, references to underage users refer to users who have not reached the age of consent to the processing of personal data in their country of residence:
Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia - 16 years or younger
Czech Republic, France, Greece, Slovenia - 15 years or younger
Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain - 14 years or younger
US, UK and any EU country not listed above - 13 years or younger.
5. Reserve
We will retain your information for as long as your account is active, or as we deem necessary for the purposes described in our Privacy Policy. We will also retain and use your information as necessary to comply with our legal obligations.
6. Obtain a copy of your data
At any time you can request a copy of the Data associated with your Account. You may also consult the Data, use it yourself or transfer it to another service provider. We has established a simple procedure for you to exercise your rights:
Please see the Account management page, in the “Privacy and Communication" Section, then “Download your information".
If you have been sanctioned in relation to our Services, we will not be able to give you access to the Data regarding your sanction so as to maintain our ability to detect or take action against such behaviour.
Correct your Data – “Right to rectification": You have the right to correct your Data when it is inaccurate or incomplete (for example, change your delivery address).
To do so, please see the Account management page, in the “Account information" Section.
Give and withdraw your consent – “Right to object and withdraw your consent": At any time, you may withdraw your consent or object to the receipt of newsletters or advertising emails, the personalisation of advertisements or the sharing of your Data with our partners (except for subsidiaries and technical service providers):
on the Account management page, in the “Privacy and Communication" Section,
on the Cookies page, to set the Cookies,
for some of our mobile games, in the privacy settings,
on your telephone or your tablet, in the settings, by activating “Limit Ad Tracking" on telephones, or activating “Opt-out of Ads Personalisation" on Android telephones.
Delete your Account – “Right to erasure (right to be forgotten)": You can request the closure of your Account and the deletion of the associated Data.
To do so, please see the Account management page in the “Account information" Section then “Close your account".
If you have been sanctioned in relation to our Services, we cannot delete the Data regarding your sanction as to allow us to maintain your sanction.
Limit the use of your Data – “Right to restriction of processing": You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the regulatory authority in your country.
7. How to contact us
If you have any questions about anything in this policy, or would like to exercise any rights you may have, please contact us at lotub.com@gmail.com