Privacy Policy

OUR APPROACH TO PRIVACY

FORTUNES OF TRIVIA
(“FORTUNESOFTRIVIA.COM”, “FOT”, “we”, “our”, or
“us”) is committed to protecting and respecting your privacy. This
privacy policy sets out how we collect, store, process, transfer, share and use
data that identifies or is associated with you (” personal information
“) and information regarding our use of cookies and/or other similar
technologies.

FOT operates a service that
allows you to play Quiz Game Challenges (the “Service” or “app”).

This privacy policy applies to
our Service. Before accessing or using our Service, please ensure that you have
read and understood how we collect, store, use and disclose your personal
information as described in this privacy policy.

FORTUNES OF TRIVIA is the data
controller of the personal information we hold about you.

PERSONAL INFORMATION WE COLLECT ABOUT YOU AND
HOW WE USE IT

We collect personal information
that you voluntarily submit directly to us when you use our Service. This can
include information you provide to us when you register for an account and user
profile, fill in a form on our Service, create or edit your user profile on the
Service, correspond with us by e-mail or otherwise, respond to trivia questions
or use some other feature of our Service. We may also collect personal
information from third parties, such as social networks.

We will indicate to you where the
provision of certain personal information is required in order for us to
provide you certain features of the Service. If you choose not to provide such
personal information, we may not be able to provide the Service to you or
respond to your other requests.

The table at Annex 1 sets out the
categories of personal information we collect about you and how we use that
information, as well as the legal basis which we rely on to process the
personal information.

We also automatically collect
personal information indirectly about how you access and use the Service and
information about the device you use to access the Service.

The table at Annex 2 sets out the
categories of personal information we collect about you automatically and how
we use that information. The table also lists the legal basis which we rely on
to process the personal information.

We may link or combine the
personal information we collect about you and the information we collect
automatically. This allows us to provide you with a personalised experience
regardless of how you interact with us.

We may anonymise and aggregate
any of the personal information we collect (so that it does not directly
identify you). We may use anonymised information for purposes that include
testing our IT systems, research, data analysis, improving our Service and
developing new products and features. We may also share such anonymised
information with others.

We will store the personal
information we collect about you for no longer than necessary for the purposes
set out in Annex 1 and Annex 2 and in accordance with our legal obligations and
legitimate business interests.

We may also collect the automatically
given information provided by Google and Facebook.

We may also collect information
about the location of your mobile device.

We will share your information
with third parties only in the ways that are described in this privacy statement.

We may disclose Collected
Information:

  • as required by law, such as to comply with a
    subpoena, or similar legal process;
  • when we believe in good faith that disclosure is
    necessary to protect our rights, protect your safety or the safety of others,
    investigate fraud, or respond to a government request;
  • with our trusted services providers who work on
    our behalf, do not have an independent use of the information we disclose to
    them, and have agreed to adhere to the rules set forth in this privacy statement.
  • if FORTUNES OF TRIVIA is involved in a merger,
    acquisition, or sale of all or a portion of its assets, the new owner and/or
    partner will have access to all the information collected provided that the
    mentioned policies and principles of the privacy policy are followed and
    respected as stated above.
  • to advertisers and third party advertising
    networks and analytics companies as described in the section below

The Service does use third party
services that may collect information used to identify you.

Log Data

We want to
inform you that whenever you use my Service, in a case of an error in the app we
may collect data and information (through third party products) on your phone
called Log Data. This Log Data may include information such as your device
Internet Protocol (“IP”) address, device name, operating system version, the
configuration of the app when utilizing our Service, the time and date of your
use of the Service, and other statistics.

Cookies

Cookies are
files with a small amount of data that are commonly used as anonymous unique
identifiers. These are sent to your browser from the websites that you visit
and are stored on your device’s internal memory.

This Service
does not use these “cookies” explicitly. However, the app may use third party
code and libraries that use “cookies” to collect information about the user and
improve their services.

You have the
option to either accept or refuse these cookies and know when a cookie is being
sent to your device. If you choose to refuse our cookies, you may not be able
to use some portions of this Service.

The Service may make use of cookies or
other local storage where legally required; procced with the collection,
sharing, and use of personal data for personalization of ads. You may also opt
in or opt out for receiving personalised ads through the app by enabling or
disabling the Personalised Ads option through the Settings Menu.

Service Providers

We may employ
third-party companies and individuals due to the following reasons:

  • To facilitate our Service;
  • To provide the Service on our behalf;
  • To perform Service-related services; or
  • To assist us in analyzing how our Service is
    used.

We want to
inform users of this Service that these third parties have access to your
Personal Information. The reason is to perform the tasks assigned to them on
our behalf. However, they are obligated not to disclose or use the information
for any other purpose.

You can review the relevant privacy policy of third party service
providers used by the app by following the links below:

RECIPIENTS OF PERSONAL INFORMATION

We may share your personal
information with the following (as required in accordance with the uses set out
in Annexes 1 and 2):

  • Service providers and advisors: we may share
    your personal information with third party vendors and other service providers
    that perform services for us or on our behalf, which may include providing
    payment, email or chat services, fraud prevention, web hosting, or providing
    analytic services.

  • Social media: where you have connected a social
    media account with our Service, we may post your comments and opinions to our
    social media pages and tag you in those posts.

  • Purchasers and third parties in connection with
    a business transaction: your personal information may be disclosed to third
    parties in connection with a transaction, such as a merger, sale of assets or
    shares, reorganisation, financing, change of control or acquisition of all or a
    portion of our business.

  • Law enforcement, regulators and other parties
    for legal reasons: we may share your personal information with third parties as
    required by law or if we reasonably believe that such action is necessary to
    (i) comply with the law and the reasonable requests of law enforcement; (ii)
    detect and investigate illegal activities and breaches of agreements, including
    our Terms of Service; and/or (iii) exercise or protect the rights, property, or
    personal safety of our users or others.

STORING AND TRANSFERRING YOUR PERSONAL
INFORMATION

Security

We are
striving to use commercially acceptable means of protecting your personal
information. However, we note that no method of transmission over the internet,
or method of electronic storage is 100% secure and reliable.

We will never
send you unsolicited emails or contact you by phone requesting your account ID,
password, credit or debit card information or national identification numbers.

International Transfers of
your Personal Information

As we are
located in the EU, any information we collect from you will initially be
collected and stored in the EU. We will take reasonable steps to ensure that
your personal information is treated securely and in accordance with applicable
law and this privacy policy.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL
INFORMATION

In accordance with applicable
privacy law, you have the following rights in respect of your personal
information that we hold:

Right of access

You have the
right to obtain:

  • confirmation of whether, and where, we are
    processing your personal information;
  • information about the categories of personal
    information we are processing, the purposes for which we process your personal
    information and information as to how we determine applicable retention
    periods;
  • information about the categories of recipients
    with whom we may share your personal information; and
  • a copy of the personal information we hold about
    you.

Right of portability

You have the
right, in certain circumstances, to receive a copy of the personal information
you have provided to us in a structured, commonly used, machine-readable format
that supports re-use.

Right to rectification

You have the
right to obtain rectification of any inaccurate or incomplete personal
information we hold about you without undue delay.

Right to erasure

You have the
right, in some circumstances, to require us to erase your personal information
without undue delay if the continued processing of that personal information is
not justified.

You can
initiate the erasure of your all personal information (including game progress)
by requesting to delete your account through Game Settings from the Main Menu.

Right to restriction  

You have the
right, in some circumstances, to require us to limit the purposes for which we
process your personal information if the continued processing of the personal
information in this way is not justified, such as where the accuracy of the
personal information is contested by you.

Right to object

You have a
right to object to any processing based on our legitimate interests where there
are grounds relating to your particular situation. There may be compelling
reasons for continuing to process your personal information, and we will assess
and inform you if that is the case.  You
can object to marketing activities for any reason.

You may also review and edit the
personal information you have submitted to us by logging into your account on
the app.

You also have the right to lodge
a complaint to your national data protection authority.

If you wish to exercise one of
these rights, please contact us using the contact details at the end of this
privacy policy.

LINKS TO THIRD PARTY SITES

Our Service may, from time to
time, contain links to and from third party websites, including those of other
users, our partner networks, advertisers, partner merchants, news publications,
retailers and affiliates. If you follow a link to any of these websites, please
note that these websites have their own privacy policies and that we do not
accept any responsibility or liability for their policies. Please check the
individual policies before you submit any information to those websites.

OUR POLICY TOWARDS CHILDREN

Our Service is not directed at
persons under 18 and we do not knowingly collect personal information from
children under 18. If you become aware that your child has provided us with
personal information, without your consent, then please contact us using the
details below so that we can take steps to remove such information and
terminate any account your child has created with us.

CHANGES TO THIS POLICY

We may update this privacy policy
from time to time and so you should review this page periodically. When we
change this privacy policy in a material way, we will update the “last
modified” date at the end of this privacy policy. Changes to this privacy
policy are effective when they are posted on this page.

NOTICE TO YOU

If we need to provide you with
information about something, whether for legal, marketing or other business
related purposes, we will select what we believe is the best way to get in
contact with you. We will usually do this through email or by placing a notice
on our Service. The fact that we may send notices to you will not stop you from
being able to opt out of certain types of contact as described in this privacy
policy.

CONTACTING US

Please contact info@fortunesoftrivia.com
if you have any questions, comments and requests regarding this Privacy Policy.

Our Privacy Policy is available
at https://fortunesoftrivia.com/privacy-policy/.

This privacy policy was last
modified on January 1st, 2020.

ANNEX 1

PERSONAL INFORMATION WE MAY COLLECT

Category of personal information How we may use it Legal basis for the processing
Contact information such as your name, phone number, address and
e-mail address.
We may use this information for account
authentication.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We may use this information to communicate
with you, including sending service-related communications, such as notifying
you when you have won a quiz.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We use this information to deal with enquiries
and complaints made by or about you relating to the Service.
The processing is necessary for our legitimate
interests, namely administering the Service, and for communicating with you
effectively to respond to your queries or complaints.
Profile information, such as   your username, profile picture and other users you have invited
to use our Service.
We use this information to operate, maintain
and provide to you the features and functionality of the Service.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We use this information to promote our
Service, such as inviting new users to our Service or tagging you in comments
on our social media pages.
The processing is necessary for our legitimate
interests, namely promoting our Service.
Tax number or other government identifier. We may collect numbers assigned to you by
tax authorities in your jurisdiction, such as your social security number or
national insurance number.
We use this information to comply with our
reporting obligations to tax authorities in the event that you win a prize
while using our Service.
The processing is necessary for your
legitimate interests, namely compliance with your legal obligations to report
winnings to tax authorities.
Chat, comments and opinions.  When you contact us directly, e.g. by email, phone, or
when you participate in a chat on our Service, we will record your comments
and opinions.
We use this information to operate, maintain
and provide to you the features and functionality of the Service.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We use this information to address your
questions, issues and concerns.
The processing is necessary for our legitimate
interests, namely communicating with users and responding to queries,
complaints and concerns.
We use this information to develop new
products and features available through our Service or otherwise improve our
Service.
The processing is necessary for our legitimate
interests, namely developing and improving our Service.
Information   about your use of our Service, such as the number of quizzes you have participated in on our
Service, your replies to the trivia questions on our Service, the prize money
you have won when using the Service other information deriving from analysis
of your interaction with our Service.
We use this information to operate, maintain
and provide to you the features and functionality of the Service, including
paying you any prize money you may win when you use the Service.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We use this information to develop new
products and features available through our Service or otherwise improve our
Service.
The processing is necessary for our legitimate
interests, namely developing and improving our Service or certain features of
our Service.
Address book contacts. Where you give us permission to do so, we
may collect the phone numbers and names of the contacts on your device.
We use this information to connect you with
people in your address book that are using our Service and to allow you to
invite other people in your address book to our Service.
We will only process this information to the
extent you have given us consent to do so.
Information received from third parties, such
as social networks. 
If you connect
a social network to our Service, or interact with our Service through a
social network, we may receive information from the social network such as
your name, profile information, and any other information you permit the
social network to share with third parties. The data we receive is dependent
on your privacy settings with the social network.
We use this information to allow you to log in
to the Service.
The processing is necessary for the
performance of a contract and to take steps prior to entering into a
contract.
We use this information to tailor how the
Service is presented to you.
The processing is necessary for our legitimate
interests, namely tailoring our Service to the user.
We use this information to promote our
Service, such as tagging you in comments on our social media pages.
The processing is necessary for our legitimate
interests, namely promoting our Service.
Precise location information. When you use certain functionalities of the
Service, we may ask you to provide your precise location.
We use this information to provide you certain
functionalities of the Service, such as the ability to interact with people
using our Service near you.
We will only process this information to the
extent you have given us consent to do so.
Approximate location information. Other than information you choose to provide
to us, we do not collect information about your precise location. Your
device’s IP address may help us determine an approximate location.
We use information you provide to us about
your location to inform and plan our marketing strategy.
The processing is necessary for our legitimate
interest, namely informing our direct marketing strategy.
All personal information set out above. We will use all the personal information we
collect to operate, maintain and provide to you the features and
functionality of the Service, to communicate with you, to monitor and improve
our Service and business, and to help us develop new products and services.
The processing is necessary for our legitimate
interests, namely to administer and improve the Service.

ANNEX 2

PERSONAL INFORMATION THAT MAY BE COLLECTED AUTOMATICALLY

Category of personal information How we use it Legal basis for the processing
Information about how you access and use the
Service
 . For example,
the website from which you came and the website to which you are going when
you leave our website, how frequently you access the Service, the time you
access our Service and how long you use it for, the approximate location that
you access the Service from, whether you access the Service from multiple devices,
and other actions you take on the Service.
We use information about how you use and
connect to our Service to present our Service to you on your device.
The processing is necessary for our legitimate
interests, namely to tailor our Service to the user.
We use this information to determine products
and services that may be of interest to you for marketing purposes
The processing is necessary for our legitimate
interests, namely to inform our direct marketing.
We use this information to monitor and improve
our Service and business, resolve issues and to inform the development of new
products and services.
The processing is necessary for our legitimate
interests, namely to monitor and resolve issues with our Service and to
improve our Service generally.
Log files and information about your device. We also collect information about the
computer, tablet, smartphone or other electronic device you use to connect to
our Service. This information can include details about the type of device,
unique device identifying numbers, operating systems, browsers and
applications connected to our Service through the device, your Internet
service provider or mobile network, your IP address and your device’s
telephone number (if it has one).
We use information about how you use and
connect to our Service to present our Service to you on your device.
The processing is necessary for our legitimate
interests, namely to tailor our Service to the user.
We use this information to determine products
and services that may be of interest to you for marketing purposes
The processing is necessary for our legitimate
interests, namely to inform our direct marketing.
We use this information to monitor and improve
our Service and business, resolve issues and to inform the development of new
products and services.
The processing is necessary for our legitimate
interests, namely to monitor and resolve issues with our Service and to
improve our Service generally.