OliveX (BVI) Limited Privacy Policy
LAST UPDATED: 23 MARCH 2022
PLEASE NOTE THAT THIS PRIVACY POLICY APPLIES ONLY TO THOSE USERS OF
THE SERVICES WHO ARE AGE 13 AND OLDER. SPECIAL PROCEDURES ARE USED
WHEN COLLECTING INFORMATION FROM USERS UNDER THE AGE OF 13, WHICH ARE
DISCUSSED IN THE “POLICIES REGARDING CHILDREN UNDER THE AGE OF 13”
SECTION BELOW.
Privacy Policy
OliveX (BVI) Limited is a subscription-based business, providing
applications, smart technology and a user experience that is built on
artificial intelligence, gamification and premium content. OliveX
(BVI) Limited, its subsidiaries, parent companies, affiliates, joint
ventures and other corporate entities under common ownership
(collectively, “we”, “our”, or
“us”) take our users’ (“users” or
“you”) privacy rights seriously.
This Privacy Policy explains how we collect, use, store, disclose and
manage the personal information (“Personal Information”) you provide to us when using, or about to using, any of our
applications, games or software (collectively, the
“Services”). Whenever you access or use our website
and domain name, and any of the Services, you agree to allow us to
collect, use, store, disclose and manage your Personal Information as
explained in this Privacy Policy, and accept this Privacy Policy in
registration or game installation.
We have the right to amend this Privacy Policy from time to time. Use
of your information we collect now is subject to the Privacy Policy in
effect at the time such information is used. Whenever you use our
sites or the Services, please check this Privacy Policy to make sure
that you are aware of any amendments in our privacy practices. The
date our Privacy Policy was last updated will be displayed therein. We
will post a revised policy on our sites and/or mobile products to
inform you and other users if we make any material revisions to this
Privacy Policy. You understand that you accept the amendments to our
Privacy Policy by continuously using our sites or the Services.
This Privacy Policy does not apply to information collected and stored
by (1) web-based applications that are built from our mobile
applications but published by other third parties, (2) or through
websites and services provided by other third party companies or
entities to which our Services may link, or (3) mobile applications
that we distribute on behalf of other third parties which mobile
applications are hosted by such third parties, except otherwise as
mentioned herein,
IF YOU CHOOSE NOT TO ACCEPT THE TERMS OF THIS PRIVACY POLICY, PLEASE
DO NOT USE ANY OF OUR SITES, MOBILE PRODUCTS OR SERVICES.
Personal Information and Non-Personal Information
We collect both Personal Information and Non-Personal Information.
“Personal Information” is information about you that can be used to
identify or contact you on-line or off-line, such as your name, birth
date, home address, email address, credit card information and phone
number. “Personal information” may include your unique device or user
identifier when the identifier is combined with your personal
information. “Non-Personal Information” is information that, by
itself, cannot be used to identify or contact you personally and can
include gender, age or interests and cannot be used to connect with
you. This Privacy Policy does not restrict or limit our collection of
aggregate information or Non-Personal Information.
Personal information also does not include “aggregate information”.
Aggregate information is data we collect about the characteristics and
activities of the users and visitors of the Services and enhance our
Services and our sites, from which any Personal Information has been
removed. Such information may include demographic information, such as
your unique user or user identifier (when not matched with or tie to
your Personal Information), city of residence, information about your
computer, software, platform and Internet IP address. We collect
aggregate information about the use of the Services to provide the
best possible service and allow us to make certain recommendations and
internal reports and share such information with our partners about
how our customers use the Services so that our partners also
understand how people use the Services and they can provide you with
an optimal user experience.
We may combine Personal Information and Non-Personal Information to be
used to improve your experience with or to aggregate it with
information collected from other users to improve or analyze the
Services.
How Personal Information Are Collected
I. INFORMATION COLLECTION AND USE
To assist us in personalizing and improving the Services, and allow
our users to set up a user account and profile that can be used to
personalize their experience in using the Services, Personal
Information are collected from you.
We may collect your Personal Information in a number of ways such as,
during your (1) registration or log-in for games, games subscriptions
or our websites, (2) creation of a personal profile, (3) customer
support or technical service requests, (4) purchase of a license to
use in-game virtual money or virtual items directly from us, any
relevant billing and financial information necessary to process your
charges will be collected by us, which may include your email address,
(5) download and use of our mobile applications and web-based
applications, (6) request for services from third party service
providers on our websites or the Services (such as, your response to
advertisements therein), (7) communications with other registered
users on our websites or through the Services, and (8) participations
in promotional or marketing activities, surveys, and other alerts.
Depending on the activity in which you are involved, information that
we collect from you will vary.
What about Cookies? – We collect certain technical information when
you use the Services in order to (i) manage advertising; (ii) analyze
the usage of our sites and services; and (iii) provide a more
personalized experience. We and our service providers use tracking
technologies to collect and analyze certain types of technical
information, including cookies (cookies are small files applied to
your browser to track movements within websites), platform type, IP
addresses, device and identifiers, domain names, landing pages, the
number of clicks, the amount of time spent on particular pages, pages
viewed and the order of those pages, URLs, browser types and language,
referring and exit pages, game state and the date and time of activity
on our sites or games, and other similar information. For our internal
use, we may also associate this information with your user ID number.
However, please note that we do not combine the general information
collected through cookies with your other Personal Information to
inform us your identity or what your email address or screen name is.
Third-party advertising companies may be used by us to serve
advertisements on our sites. This Privacy Policy covers only the use
of our cookies and the respective privacy policies of other third
party advertising companies govern the use of cookies by such
advertisers. Our advertising partners, who may set cookies, may
deliver advertisements appearing in the Services to users, and may
also use other third-party advertising technology to target
advertising in the Services. When we serve advertisements to you, an
unique third-party cookie or cookies may be placed on your computer.
These cookies are used by the advertisements server to identify your
computer or other device each time an advertisement is served to you
in order to gather information about you or others users who use your
computer or device. Based on such information, advertisement networks
will deliver targeted advertisements that will be of interest to you.
Other technologies may also be used by us, which include: (i) flash
cookies (which help us in preventing fraud, remembering your in-game
preferences and speeding up load times); (ii) tracking pixels (which
permit us to advertise more efficiently by (a) not serving certain
promotional messages to our current users, (b) identifying the source
of a new installation or (c) delivering advertisements to you on other
websites); and (iii) web beacons (which assist us in determining if a
certain page was visited or whether an e-mail was opened).
Most browsers give you an option to alert you on attempts to place
cookies on your computer or other devices or disable the cookie
feature, which will not permit your browser to accept new cookies, or
allow you to decide to accept each new cookie in a variety of ways. If
you opt-out of the use of cookies, you may run the risk of losing some
of the features and functionality of playing our games or using the
Services, as you may need our cookies to track and enhance your game
activities. We strongly advise you not to disable the cookies feature
so that you can enjoy some of the Services’ most attractive features.
When you download and use any of our games on your mobile device or on
a personal computer, we also collect information regarding your
in-game actions, your user identifier or unique device and country in
which the mobile phone or device is registered or located, and may
collect your mobile phone number, and other information you provide,
such as user name, or e-mail address. When our mobile or web-based
applications are used, we also collect information about your mobile
device type, operating system, IP address and browser type. For
Android games subscriptions, you are required to let us have your
email address and consent to let us use it to contact you before you
can download and use any of our games. We use such information in
relation to providing our mobile and web-based applications, such as
to authenticate you and to communicate with you regarding the Services
by push notification, SMS, e-mail, text message or other electronic
means to your mobile device. By using the Services, you agree to
letting us retain all the above information in any form as we see fit.
We only collect information to the extent that is reasonably necessary
to comply with your requests and our legitimate business objectives.
How and Where Personal Information Are Stored, International Transfer
and Personal Information Security
We are an international organization and the Personal Information,
Non-Personal Information or aggregate information we collect or
receive are stored in data storage facilities in different locations.
We may use, transfer to, process or hold such information by computers
located in different countries, including countries outside your
country of residence or governmental jurisdiction where the privacy
laws may not be as protective as those in your jurisdiction, and used
for the purposes set out in this Privacy Policy. Your submission of
such information represents your agreement to that transfer.
We may use third parties service providers for the collection,
processing and storage of your Personal Information, Non-Personal
Information or aggregate information in the data storage servers
and/or equipment owned and operated by such third parties, and such
third parties will comply with our Privacy Policy and to use your
Personal Information only for the purposes for which they have been
engaged by us. We are not responsible for these third parties’ acts
and omissions, except as provided by the applicable laws. Please note
that other countries’ data protection laws may not be the same as
those of your country of residence or governmental jurisdiction. You
hereby consent to the transfer, storage and processing of your
Personal Information as mentioned in this section.
We also understand that it is important to keep your information safe
and secure. Commercially reasonable security measures to safeguard and
secure your information and to prevent the destruction, loss, misuse
and alteration of information under our control have been implemented
by us. We do not believe that there is any transmission method over
website or Internet that is completely flawless, even though our
commercially reasonable security measures have been put in place
against possible breaches of our sites’ security and our user records
and databases. We are not liable for data loss, hacking, unauthorized
access or other breaches in relation to our servers and systems or
guarantee the security of user account information. You transmit your
information to our sites at your own risk. After we receive your
information, we have procedures and security measures in place to
attempt to prevent any unauthorised access. You also have the
obligation to limit access to your computer (or other device) and
browser by logging out after you have finished accessing your account
to ensure that there is no unauthorized access to your account and
Personal Information.
How Personal Information Are Used
We may use your Personal Information, Non-Personal Information or
aggregate information collected from you in any one or more of the
following ways to: (1) provide advertising and promotional information
in connection with the Services; (2) prevent fraud or potentially
illegal, unethical or legally actionable activities, and enforce the
relevant terms of service; (3) notify you of new game releases or
updates; (4) operate, maintain and manage the Services; (5) provide to
government or law enforcement officials to protect our rights and
property as well as those of third party and protect the safety of the
public or any person; (6) solicit feedback and input to improve the
Services, including our websites, products and services and
personalize your user experience, diagnose problems with our server
and develop new product and services; (7) communicate with you about
the Services; (8) provide technical support and respond to user
requests; or (9) if you consent or do not object to our use of your
Personal Information in direct marketing (please see further details
in the “Use of Personal Information in Direct Marketing” section
below), conduct direct marketing activities, such as sending you
offers, promotions, rewards, discounts, events and benefits in
relation to the Services and products and services offered by our
business partners or third party merchants.
Use of Personal Information in Direct Marketing
From time to time, we may conduct direct marketing of the Services
through email, direct mails, telemarketing, fax and/or other form of
communication to you. We intend to use your Personal Information for
direct marketing carried out by us or one of our business partners or
third party merchants. For the purpose of direct marketing, we shall
use your name (including surname and given name), address, telephone
number, email address and other information, if any, that you provide
to us for offers, promotions, rewards, discounts, events and benefits
in relation to the Services and products and services offered by our
business partners or third party merchants.
Please note that we may not use or provide your Personal Information
to others for direct marketing purposes unless exempted by the
relevant regulations or we have received your consent (which includes
an indication of no objection).
You may indicate your consent to the above by ticking the box(es)
indicating your consent contained in the relevant communications. If
you do not wish (i) any of your Personal Information to be used in any
of the described direct marketing activities, or (ii) to receive from
us (a) any promotional and direct marketing materials, (b) any
particular types of promotional and direct marketing materials, and/or
(c) such materials through any particular means of communication, you
can at any time opt-out, free-of-charge, by contacting us at
legal@olivexbvi.com, following the “opt-out”
instructions contained in the relevant communications, or following
the instructions in the “Your Options” section below..
How Personal Information Are Shared
In general, we do not sell or rent your Personal Information to other
third parties. Your Personal Information is only shared in the
following circumstances:
Responses to User Submissions
We may send email and other communication to you relating to your User
Submissions as part of the Services. You agree that by posting such
User Submissions, you may be receiving email and other communication
from us that we determine in our sole discretion relate to your User
Submissions.
Users’ profiles
We may display your user profile information including your username
and other information entered by you (“User Submissions”) to other users to facilitate user interaction within the Services.
With Your Consent
Except as mentioned in this Privacy Policy, we will notify you when
your Personal Information may be shared with other third parties, and
you may elect not to share such information.
Offer wall
Our games may display a third party hosted “offer wall”. Such offer
wall allows third party advertisers to provide virtual money to users
and in return such user will respond to an advertisement or complete
an advertisement offer. Such offer wall may appear in the games and be
displayed to you based on certain information, such as your geographic
area or demographic information. When you click on one of these offer
walls, you will leave our or our partners’ site at the time. A unique
identifier, such as your user ID number, will be shared with the offer
wall provider in order to prevent fraud and properly credit user
accounts.
Advertisers
You agree that any of the information we have collected from you
(including information you may have decided not to show to other
users) may be used by us to choose or allow the advertisers to choose
the appropriate audience for their advertisements.
Transfers of business
If we decide to dispose our assets, we may include user information as
part of the business assets that are transferred to the buyer. At the
same time, if we, or substantially all of our assets, were acquired,
or in the unlikely event that we go out of business or enter
bankruptcy, information of our users would be one of the assets that
is transferred or acquired by a third party. You acknowledge that such
transfers may occur, and your Personal Information may continue to be
used by any of our purchasers or the purchasers of our assets as set
forth in this Privacy Policy.
Affiliated businesses that we do not control
A variety of businesses may become affiliated and work closely with
us. Through the Services, items may be sold to you by such affiliated
businesses, and services or products may also be provided or sold to
you by us jointly with such affiliated businesses. You can recognize
when an affiliated business is associated with your transaction, and
we may share your Personal Information that is related to such
transactions with that affiliated business.
Agents
We also use other companies and third parties to perform tasks for us
and we will share your information with them to provide you with the
relevant products or services. When such third parties collect or
possess any information other than non-personal, anonymous and/or
aggregated data, they do not have any right to use such Personal
Information we share with them beyond what is necessary to assist us,
unless you are told otherwise. Such agents are required to use your
Personal information consistently with our Privacy Policy and protect
and maintain the collected information’s confidentiality during their
engagement by us and refrain from using such information for any
purpose other than to provide the Services for us without your express
consent. You consent to our sharing of Personal Information for such
purposes.
Protection of our rights and those of others
If we believe in good faith that the release of your Personal
Information is necessary to comply with the relevant law and
regulation, enforce or apply our conditions of use and other
agreements, or protect our rights, property, or safety, or those of
our employees, users or others, we may do the same. This includes
exchanging information with other companies and organizations for
fraud protection and credit risk reduction.
To improve our games or the Services to serve you better, we may also
use your Personal Information for our own marketing and demographic
research. This Privacy Policy does not restrict or limit our
collection of aggregate information, and we may disclose this
information to any third parties.
Policies Regarding Children Under The Age of 13
Please note that this “Policies Regarding Children Under the Age of
13” section only applies to procedures when collecting information
from children under the age of 13.
We recognise the obligation to protect Personal Information obtained
from young children. The Services are not geared toward children under
the age of 13 and we do not knowingly collect any Personal Information
from such children other than those stated in this section. If we
collect any personal information (as defined in the Children’s Online
Privacy Protection Act (“COPPA”), which was
established by U.S. Congress to protect children’s online privacy)
from children under the age of 13, we will either (1) comply with the
requirements of COPPA and gain prior verifiable parental consent or
direct parental notification of the nature and intended use of such
information, which shall include an opportunity for the parent to
prevent use of the information and participation in the activity; or
(2) take all reasonable steps to promptly remove from our files and
records such information. For more information about COPPA and
children’s rights to online privacy, please visit the Children’s
Privacy section of the Federal Trade Commission’s website at
www.business.ftc.gov/privacy-and-security/childrens-privacy.
In addition, we advise that children over the age of 13 shall ask
their parents for permission before transmitting any of their
information to anyone over the Internet, and we suggest parents to
tell their children not to provide their personal information, without
permission, when using the Internet.
What types of information do we collect from children?
We mainly collect persistent identifier (such as an IP address, mobile
device id, or a unique device identifier) from the child.
Please note that all sites that are directed to children under the age
of 13 are prohibited by COPPA from conditioning a child’s
participation in an online activity on the child’s disclosure of more
personal information than is reasonably necessary to participate in
the activity.
How do we use and share the personal information collected from
children?
We use the collected persistent identifier for the sole purpose of
providing support for internal operations of the Service, including
activities necessary for us to maintain or analyze the functioning of
the Services, authenticate users or personalize content, serve
contextual advertising or cap the frequency of advertising, protect
the security or integrity of the user or the Service, or ensure legal
or regulatory compliance.
The collected persistent identifier is not shared with other third
parties. However, we may, from time to time contract with certain
third party service providers to provide support for the internal
operations of the Service. Your personal information is not used or
disclosed by these contracted third party service providers except for
the limited service for which they have been contracted.
We collect a child’s email address in connection with a question
emailed to us by the child for the sole purpose of communicating with
the child on a one-time-only basis (e.g. responding to a question from
the child). We will not use or disclose such information to re-contact
the child or for any other purpose, and such information will be
deleted from our records promptly after responding to the child’s
request. If we choose not to respond to the child’s request, we will
immediately delete the child’s information.
How can parents review or delete personal information about their
child?
At any time, parents of children under the age of 13 may review or
delete personal information about their children from our records, or
refuse to permit our further collection or use of such personal
information. Please contact us atlegal@olivexbvi.com
if you would like to review or delete your child’s personal
information, or to inform us about your refusal to permit our further
collection of such personal information.
Whenever a parent requests a deletion of his or her child’s personal
information, we will use reasonable efforts to delete the child’s
information from our records as much as possible and will not collect
any other personal information from such child. Please note that there
may be residual information that will remain in our records that may
or may not contain the personal information that was requested to be
deleted. Such residual information will not be disclosed or shared
with any other third party or used for any commercial purpose.
Changes in our Privacy Policy Regarding Children Under the Age of 13?
We may amend our Privacy Policy Regarding Children Under the Age of 13
at any time. We will provide parents notice by e-mail of any material
changes in the way we intend to collect, use, and/or share a child’s
personal information. Please note that, at all times, parents should
update their personal information to provide us current e-mail
addresses. We will apply material changes in our Privacy Policy
Regarding Children Under the Age of 13 only in conformance with
applicable law, including any applicable provisions of COPPA that
require parental consent.
Contact us
If you have any other questions about our Privacy Policy for Children
Under the Age of 13, including our practices in relation to children’s
personal information, in particular collecting or maintaining such
personal information, please contact us at:
OliveX (BVI) Limited
Ellen L. Skelton Building, Fishers Lane, Road Town, Tortola, British
Virgin Islands.
or send us an email at: legal@olivexbvi.com
Linked Third Party Sites’ Privacy Policies
Our sites and the Services may contain links to websites of other
third parties that we do not own or have any control. It does not mean
that we authorise, sponsor or endorse those third parties, nor is it a
representation of our association with them, when we provide such
links to other websites. If you click on such links, including
clicking on a banner ad or other type of advertisement, you will leave
our site and will be directed to those third parties’ sites. As we do
not have any control over such third parties’ activities, we are not
responsible for their websites’ content or privacy practices, the
collection or use of your information or any of their products or
services. We cannot provide assurance that such third parties employ
the same or similar privacy and security practices as us. We strongly
advise you to review such other websites’ privacy policies, as their
privacy policy governs any information you provide to these third
parties. Only information collected on or through the Services is
subject to this Privacy Policy.
The Services may also contain other third party service providers’
tracking tools. We may use such third parties’ APIs/SDKs in providing
the Services to you, which may allow these third parties to analyze
user information. Although these third parties may have access to your
Personal Information when services are performed for us, they may not
use such information for any purposes other than to provide their
services.
Your Options
You may not wish to disclose any of your information, even though such
information may be necessary to take advantage of or register for
certain features of the Services. Please let us know at
legal@olivexbvi.com if you decide to close your
account(s). We will review, update, correct or delete the relevant
information as appropriate and your information may still be retained
in our systems for enforcing our user agreement, maintaining the
security, integrity and operation of our sites and the Services and
resolving any disputes.
How Personal Information Are Accessed or Amended
Any Personal Information collected and held by us may be accessed or
amended by you by changing the relevant information through our sites.
You may contact us at legal@olivexbvi.com if you
decide to close your account(s). We will review, update, correct or
delete the relevant information as appropriate and your information
may still be retained in our systems for enforcing our user agreement,
maintaining the security, integrity and operation of our sites and the
Services and resolving any disputes.
Contact Us
If you would like to know what kind of information we are storing
regarding your user, please email legal@olivexbvi.com
and use the subject: “User Data”.
If you would like your personal data deleted, please email
legal@olivexbvi.com and use the subject: “Delete
User”.