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DEVAR Website Privacy Policy

Effective date September 11, 2018

Welcome to the world of DEVAR!

DEVAR Entertainment LLC (collectively, “DEVAR” or “we”) respects the privacy rights of our online visitors and, therefore, have adopted this privacy policy (the "Privacy Policy") to describe our privacy practices for our website, www.devar.org (the "Website"), only. DEVAR is the operator of the Website and the controller of the information collected on it. This Privacy Policy does not apply to any information collected outside of the Website (unless otherwise stated at the time of collection).

The Privacy Policy describes what information is collected from our users while on the Website; how such information is used and stored; in what cases such information can be disclosed to third parties; how users can control the use and disclosure of collected information; and how information is protected.

By using the Website, you warrant that you have read and reviewed this Privacy Policy and our Terms & Conditions, and you agree to by them. If you do not agree, please do not use the Website.

The ESRB certification seal found on the Website confirm DEVAR is a valid licensee, and participating member, of ESRB's Privacy Certified Program. To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the Website reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of the Privacy Certified program, we are subject to audits of the Website and other enforcement and accountability mechanisms administered independently by the ESRB.

TABLE OF CONTENTS

We have appointed a personal data protection officer (hereinafter referred to as the "authorized person"), who is responsible for all matters related to this privacy policy. If you have any questions about this policy, please contact our authorized representative at the address below.

I INFORMATION AND DATA WE COLLECT
II HOW WE USE YOUR INFORMATION
III WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
IV LINKS TO OTHER SITES AND SOCIAL NETWORK PLUGINS
V WHERE AND FOR HOW LONG WE STORE YOUR INFORMATION
VI HOW WE HANDLE CHILDREN’S INFORMATION
VII IF YOU ARE IN CALIFORNIA
VIII YOUR PRIVACY RIGHTS
IX SECURITY
X CHANGES TO THIS PRIVACY POLICY
XI CONTACT US

I INFORMATION AND DATA WE COLLECT

We collect information you provide directly via the Website, as well as certain technical information automatically. Some of the information we collect may identify you personally.

A. INFORMATION YOU GIVE US

The Website provides the option for you to contact us, whether it be to ask us a question, request customer support, or otherwise. To contact us, you will be required to provide us with an email address, and you will be given the opportunity to write a message to us, in which you may choose to include additional personal information. Moreover, you will have the option to provide us with your first name.

B. INFORMATION WE COLLECT AUTOMATICALLY

The Website utilizes first- and third-party cookies and other similar tracking technologies, such as pixel tags, to automatically collect certain information such as:

  • Your Internet Protocol (IP) address;
  • Country-level location information;
  • Device information; and
  • Browser data, such as the type of browser, date and time of visit, web page of origin (referral site) and exit, and possibly the number of clicks.

A “cookie” is a small file that is saved on your computer or mobile device, which uniquely identifies your browser and provides information to the cookie sender. Pixel tags are small blocks of code on a webpage that allow websites to do things like read and place cookies. These trackers help us to improve your user experience and allow us to analyze Website traffic and use. In addition, they are used for promotional and advertising purposes, including for interest-based advertising.

As of the Effective Date of this Privacy Policy, the following cookies are utilized by the Website for analytics and advertising:

Cookie Type Third-Party Privacy Policy Industry Opt-Out Options Company-Specific Opt-Out Options
DoubleClick Advertising http://www.google.com/policies/technologies/ads/ DAA:http://optout.aboutads .info/#!/
NAI:http://optout.networkadvertising.org/#!/
https://support.google.com/ads/answer/2662922?hl=en
Twitter Advertising Advertising https://help.twitter.com/en/rules-and-policies/twitter-cookies# n/a
Twitter Conversion Tracking Advertising n/a
Twitter Analytics Analytics n/a
Google Analytics & GA Audiences Analytics https://support.google.com/dfp_premium/answer/2839090?hl=en n/a https://tools.google.com/dlpage/gaoptout

In addition to the opt-out options referenced in the above chart, you may be able to disable cookies in your browser settings or set your browser to alert you when cookies are being used. If you disable cookies, it may slow down or prevent access to some parts of the Website. For further information and support, you can also visit the specific help page of the web browser you are using:

Some web browsers may transmit “do not track” signals. We currently do not take action in response to these signals.

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II HOW WE USE YOUR INFORMATION

We process your personal information to further our legitimate business interests and as necessitated by contractual obligations, which may include:

  • To improve, operate, manage, and provide you with the Website;
  • To perform services requested by you, such as to respond to your support requests;
  • To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • To prevent fraud, breach of policies or terms, and threats of harm;
  • To monitor and analyze trends, usage and activities;
  • For internal research and demographic studies, so we can constantly improve the Website and services;
  • To provide and measure the effectiveness of our promotions and advertising; and
  • To fulfill other purposes that may be disclosed to you and for which you provide affirmative consent.

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III WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We do not share your personal information with third parties, other than:

  • With related entities, including parent companies, subsidiary companies, and affiliates, but only if they agree to handle your personal information in accordance with the terms of this Privacy Policy;
  • With third-party vendors, consultants and service providers who are working on our behalf and need access to your information to carry out their work for us;
  • When we believe it is necessary or appropriate to (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) protect the rights and property of Devar; and (iii) protect the safety of Devar, our users or any third party; and
  • In connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company.

We may also share aggregated information or de-identified information with third parties, at our discretion. Such information cannot be used to identify you personally.

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IV LINKS TO OTHER SITES AND SOCIAL NETWORK PLUGINS

The Website contains links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site, and this Privacy Policy will no longer apply. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

This Website also incorporates plugins and/or buttons for social networks to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard the privacy of users. Cookies may be set, however, if you make voluntary use of the plugin. Please note that if you browse while being logged into the social network then you have already consented to the use of cookies conveyed through this Website at the time that you registered with the particular social network.

The collection and use of information obtained by means of the plugin are governed by the respective privacy policies of the social networks, which can be found below:

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V WHERE AND FOR HOW LONG WE STORE YOUR INFORMATION

Your personal information is stored as long as it is necessary for the purposes for which it was collected or as otherwise set forth in this Privacy Policy.

  • For EU User

Personal data collected from data subjects located in the European Economic Area (EEA) is stored in Estonia. It is not transferred outside the EEA.

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VI HOW WE HANDLE CHILDREN’S INFORMATION

The Website is intended for users 18 years and older. It is not intended for users under 18 years old. We do not knowingly collect personal information from children under 16 years old (“Children” or “Child”). However, we do collect information, including personal information, for all users of the Website, as explained in Section 1 above.

Parents, if you believe we might have unintentionally collected personal information from your Child, please immediately Contact Us using the information provided below in Section XI. If we confirm we have collected personal information from a Child, we will delete that information from our systems.

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VII IF YOU ARE IN CALIFORNIA

If you are a resident of California, section 1798.83 of the California Civil Code allows you to request information about the disclosure of your personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes. However, you may make such a request by contacting us at:

  • DEVAR Entertainment LLC
  • Attn.: Anna Belova, Data Protection Officer
  • Telephone No.: +1-646-630-9263
  • 525 Route 73 North, Suite 104
  • Marlton, New Jersey 08053
  • Email: privatepolicy@devar.org

If you are a resident of the European Economic Area, you also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and this Privacy Policy.

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VIII YOUR PRIVACY RIGHTS

You have the following data protection rights:

  • If you wish to access, correct, update, or request deletion of your personal information, you can do so by contacting us using the contact details provided under the “Contact Us” heading below; and
  • You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information by contacting us using the contact details provided under the “Contact Us” heading below.

If you are a resident of the European Economic Area, you also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and this Privacy Policy.

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IX SECURITY

We take reasonable steps to help protect the security and integrity of any personal information you provide to us. Nevertheless, transmission via the internet is not completely secure, and we cannot guarantee the security of your personal information through the Website. If we learn that your personal information has been compromised by a data breach, we will notify you consistent with applicable laws.

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X CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, revise or otherwise modify this Privacy Policy at any time and in any way (for example, in response to changes in legal, technical or business events). When we make changes to this Privacy Policy, we will update the Effective date above. If we make any material changes in the way we collect, use or share your personal information, we will publish a new privacy policy on this page and we will make a warning in the Website when you first use the Website after such policy changes are made. If we make any material changes that retroactively impact the way in which we use or disclose personal information already collected from you, we will seek your consent before those changes become effective.

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XI CONTACT US

If you have any questions or wish to send us comments about this Privacy Policy, or the processing of your personal information, please contact us at:

  • In the U.S.:
  • DEVAR Entertainment LLC
  • Attn.: Anna Belova, Data Protection Officer
  • 525 Route 73 North, Suite 104
  • Marlton, New Jersey 08053
  • Telephone: +1-646-630-9263
  • Email: privatepolicy@devar.org

  • In the EU:
  • Devar Entertainment Ltd
  • Attn.: Elena Iraclius
  • Spyrou Kyprianou, 20, CHAPO CENTRAL,
  • 3rd Floor, P.C.1075 Nicosia, Cyprus
  • Telephone: +44 203 769 98 36
  • Email: privatepolicy@devar.org

DEVAR is a licensee of the ESRB's Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at:

  • ESRB
  • Attn.: Privacy Certified Program
  • 420 Lexington Avenue, Suite 2240
  • New York, NY 10170
  • privacy@esrb.org

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