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DEVAR Mobile Application Privacy Policy

Effective date August 30, 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 the DEVAR Mobile Application (the "Application"). DEVAR is the operator of the Application and the controller of the information collected on it.

The Privacy Policy describes what information is collected from our users, including children, when the Application is downloaded; how such information is used and stored; in what cases such information can be disclosed to third parties; how users, parents and guardians can control the use and disclosure of collected information; and how information is protected. The Application is intended for a younger audience, including users under the age of 13. If you are under 18 years old, please review this Privacy Policy with a parent or guardian. By accessing the Application, you agree to comply with this Privacy Policy. If you do not agree with this Policy, please do not use the Application.

The ESRB certification seal found in the Application 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 Application 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 Application 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 WHERE AND FOR HOW LONG WE STORE YOUR INFORMATION
V HOW WE HANDLE CHILDREN’S INFORMATION
VI YOUR CALIFORNIA PRIVACY RIGHTS
VII YOUR PRIVACY RIGHTS
VIII SECURITY
IX CHANGES TO THIS PRIVACY POLICY
X CONTACT US

I INFORMATION AND DATA WE COLLECT

We collect information you provide directly via the Application, as well as certain technical information automatically.

A. INFORMATION YOU GIVE US

The Application provides two opportunities for you to provide us with personal information: (i) to obtain customer support; and (ii) to ask characters questions.

To obtain customer support, you may utilize the chat support function in the Application. To utilize this function, you will be required to provide us with your first name and an email address. We will then give you the ability to live chat with a customer service representative on the Application. After we have resolved your request for support, we will send you an email that will include the customer service representative’s response to your support request. We then immediately delete your email. Your email address will not be used for any other purpose other than to respond to your support request. The live support chat within the Application will also be moderated so that if you disclose any personal information during the chat, we will delete the record of that chat.

Within the Application, there are various characters with which you can interact. We allow you to ask characters questions, either by typing the question or by using the microphone on your mobile device to record you asking the question. The audio file containing your question is then converted into a text file. We utilize the text file to search for an answer to your question. A text file of the answer is then sent to the Application and is converted into an audio file. This allows the character to answer your question audibly. After your question has been answered, your audio file is immediately deleted, and it is not used for any other purpose.

You will notice that there are other opportunities for you to provide information within the Application. Specifically, you can provide your first name and birthday in the profile section. You can also take pictures and record videos, including pictures and videos that contain your image and/or voice. However, this information is stored solely on your mobile device, and it is not shared with us or any third parties. In addition, you can make purchases within the Application; however, those purchases are processed by third-party application stores (e.g., the Google Play Store) and subject to their privacy policies. We do not collect any personal information from you in connection with these transactions.

B. INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect technical data that you need to use the Application, as well as additional technical data that we need to maintain and analyze the functionality of the Application, and to personalize the content of the Application. This includes:

  • Your Internet Protocol (IP) address;
  • The time zone, and the start and end time of the session;
  • The user agent (UA) string, platform, and SDK version; and
  • Technical information about the device (for example, the model and name of the device, the name and version of the operating system, the name of the CPU, free disk space allocated for the application, the screen resolution, and application API-key).

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II HOW WE USE YOUR INFORMATION

We use the information we collect about you and your device, including personal information, for the following legitimate business purposes:

  • To improve, operate, manage, and provide you with the Application;
  • To enable you to utilize speech-to-text functionality;
  • To perform services requested by you, such as to respond to your support requests; and
  • To perform analytics.

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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 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. This includes FASTVPS EESTI OÜ, which provides us with a virtual server located in Estonia that hosts the Application and on which we store your information. It also includes Google, which provides a software solution to convert your speech to text after which your voice recording is immediately deleted;
  • 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 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 Users

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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V HOW WE HANDLE CHILDREN’S INFORMATION

As stated above, the Application is intended for a younger audience, including users under the age of 13. We encourage parents and guardians to review this Privacy Policy with their children.

We are committed to complying with the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect users under the age of 13 online. Accordingly, we do not collection personal information from children under 13 years old, except when permitted by COPPA. Specifically, we collect the following personal information from children under 13 years old, without providing direct notice to and obtaining consent from a parent or guardian:

  • Email addresses: We collect a child’s email address pursuant to the one-time contact exception in COPPA, which allows us to respond to a child’s support request. After we have responded to the child’s support request, we delete the child’s email address, and it is not used for any other purpose;
  • Audio files: We collect audio files containing a child’s voice pursuant to the speech-to-text exception to COPPA, which allows us to collect the audio file for the sole purpose of converting the child’s speech to text. After the conversion to text, the audio file is deleted; and
  • Persistent identifiers: We collect persistent identifiers for the purpose of supporting the internal operations of the Application, as permitted by COPPA.

We collect this information pursuant to our legitimate business interests, as permitted by the European Union’s General Data Protection Regulation.

Moreover, we do not collect more personal information than is reasonably necessary to utilize the Application.

If you have any questions about our information collection and use practices; would like to review, correct or delete your child’s personal information; or would like us to discontinue the further collection or use of your child’s personal information, please contact us using the contact details provided under the “Contact Us” heading below

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VI YOUR CALIFORNIA PRIVACY RIGHTS

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:

  • Email addresses: We collect a child’s email address pursuant to the one-time contact exception in COPPA, which allows us to respond to a child’s support request. After we have responded to the child’s support request, we delete the child’s email address, and it is not used for any other purpose;
  • Audio files: We collect audio files containing a child’s voice pursuant to the speech-to-text exception to COPPA, which allows us to collect the audio file for the sole purpose of converting the child’s speech to text. After the conversion to text, the audio file is deleted; and
  • Persistent identifiers: We collect persistent identifiers for the purpose of supporting the internal operations of the Application, as permitted by COPPA.

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VII YOUR PRIVACY RIGHTS

You have the following data protection rights:

  • 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 SECURITY

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 Application when you first use the Application 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.

Please periodically check this page for any modifications, changes or amendments.

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IX CHANGES TO THIS PRIVACY POLICY

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 Application. 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 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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