DARK TRIP Privacy Policy Version 1
Date of Issue: 27 September 2024

We are Ayteylz EOOD, a company incorporated and registered in Bulgaria with the registered address at 8230, Bulgaria, oblast Burgas, obschina Nesebar, Ivan Vazov st., No 14, fl. 1, office 4 (“iTales VR”, “we” or “us”), we are a virtual reality games developer and publisher.

Where we decide the means or purpose of processing your personal data, iTales VR is the “controller”.

Privacy Policy Subject

This Privacy Policy explains how iTales VR collects and processes personal data, as a controller from users (individually referred to as a “User” and collectively referred to as “Users”) of DARK TRIP (“Game”) and any services provided by iTales VR in connection with the Game (“Services”). “You” and “your” shall refer to any User.

Please note, the Game, the Services, and this Privacy Policy may refer to websites or services not operated by iTales VR. You should refer to the privacy policy on those websites and services to understand how they process personal data.

Privacy Policy Updates

iTales VR may make updates to this Privacy Policy from time to time (for example because our services have changed or because of changes in the law), so do check back regularly. In some circumstances, we may also appropriately notify Users of any updates. The date this Privacy Policy was last updated can be found at the beginning of this Privacy Policy.

Collected data and the collecting purposes

We collect personal data directly from Users, related to the use of the Game and Services, and in some cases, from third parties (such as operators of certain third-party services that we use). The data we collect about Users varies depending on what is required for the Services we provide in connection to the Game. The following are the main purposes for the collection and processing of Users’ personal data by iTales VR:

  • to assist Users who contact iTales VR regarding the Game and/or Services for support;
  • with consent, we will process certain anonymous and aggregated data from Users to understand: a. how Users are playing the Game to improve, test and monitor the quality and delivery of the Game; and b. to identify and correct any problems in the Game (such as bugs or problems preventing progression).
All data collected and processed for the above purposes is done under one of the following legal bases:

  • Contract: where it is necessary, iTales VR will use personal data in order to perform a contract with the User and ensure we are able to complete any related obligations under the contract with our Users.
  • Legitimate interest: personal data may be needed for iTales VR’s business purposes, as balanced against the potential impact on a User’s privacy rights. This includes common purposes, such as to communicate with a User and respond to their requests, to ensure the smooth operation of the Game and Services along with working on improvements for the Game.
  • Legal: iTales VR processes personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement officials or in accordance with relevant regulatory frameworks.
  • Consent: for the processing of some data, iTales VR will be relying on the consent from the User, such as analytics. Consent can be withdrawn at any time, either in-Game on the Preferences screen or by contacting us via the contact email listed in the Contact section of this notice.

Information you provide to iTales VR

Where a User contacts iTales VR’s support email address for the Game or submits a report, a User may provide the following personal data to iTales VR:

  • their User ID and User Profile;
  • their name;
  • their email address; and
  • any other personal data provided by the User to iTales VR (for example, their telephone number to be contacted by).
Please note any missing or incorrect data may not enable iTales VR to fully assist with a support request.

Where iTales VR runs competitions and prize promotions in connection with the Game, iTales VR may collect social media handles/account names as well as any winner’s personal data (such as name, telephone number, email address and residential address (if required for delivery of any physical prize)) as necessary for the performance of any obligations tied to that activity.

Information iTales VR collects automatically from Users The following data is collected automatically from Users either directly through Users playing the Game or by third parties on iTales VR’s behalf:

  • data such as User ID, User Name, age group category, geographical region, language settings and internet latency;
  • in-Game activity and User choices, progression and events (including score and accuracy);
  • how long for and when a User plays the Game (including total game time and total session times); and
  • crash reports containing anonymised device and performance information.

Anonymous and aggregated data

To improve, test and monitor the quality and delivery of the Game and Services and to identify and correct any problems in the Game, anonymous and aggregated data might be collected, such as gameplay settings and the country of the device being used to play the Game.

Terms of keeping your personal data

iTales VR shall only store and retain the data for as long as necessary for the purposes outlined above and until it is no longer required for iTales VR. As a general principle, we will retain data necessary to provide the Game until it is discontinued or no longer supported. We may need to keep personal data for longer if required by law.

Data storage, transfers and disclosures

iTales VR may share or disclose your personal data with third parties as set forth below:

  • Affiliates and group members: We may disclose your personal data to other members of our corporate group in order to carry out the processing set forth in this Privacy Policy.
  • Service Providers: We may engage vendors and service providers to provide services to us or to you on our behalf, such as support, data storage, and monitoring services. Our contracts with these service providers do not permit use of your personal data for their own purposes.
  • Law enforcement or government authorities: We may disclose personal data to meet requests from regulatory, law enforcement, or government authorities or tribunals.
  • Investments, mergers, acquisitions or disposals: If involved in an investment, merger, acquisition or sale of our organisation or assets, personal data may be shared as required in the pursuit of the legitimate interests of us and other parties to such a transaction.

iTales VR is based in Bulgaria and may use subcontractors based in other countries. Where this is the case, we will use appropriate safeguards to ensure that personal data is given the same level of protection it has in the European Union. For more information, please contact us.

Your Rights

Users of the Game and Services have several rights regarding how your personal data is processed, including:

  • asking us to send a copy of your personal data to you or someone else;
  • asking us to restrict, stop processing, or delete your personal data;
  • objecting to iTales VR processing your personal data;
  • objecting to use of your personal data for direct marketing purposes; and
  • asking us to correct inaccuracies in your personal data.

If you would like to exercise any of the above rights, you may reach out to iTales VR via the contact email listed in the Contact section of this notice.

Please note, we may not be able to action certain requests due to:

  • the legal basis we are relying on to process your personal data;
  • it needs to be retained to satisfy certain legal requirements or obligations or for security purposes; or
  • otherwise, there are valid grounds under data protection laws to allow us to do so.

Users under the age of 13

iTales VR does not knowingly solicit data from or market the Game to children under the age of 13. If a User under the age of 13 accesses the Game through a parent-managed account, default privacy settings ensure that iTales VR does not collect any personal data from that User other than the personal data necessary to operate the Game. Please note that the default privacy settings cannot be changed until the User is the age of 13.

If a parent or guardian becomes aware that a User under the age of 13 has provided iTales VR with data without their consent, they should notify us at vr@itales.mobi. We will delete such data without delay.

Our Contacts Information

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: vr@itales.mobi

When making a request related to your data subject rights, please include the nature of the request in the subject line of the email to enable us to act promptly.

If we can’t resolve your issue, you can also get in touch with the data protection authority in your country.
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