Privacy policy

Joyteractive Limited (“Joyteractive”, “we”, “us” or “our”) is a company with a registered address at 75 Prodromou Avenue, Oneworld Parkview House, Floor 4, 2063 Nicosia, Cyprus. We develop and publish applications and games for mobile devices.

When you use Joyteractives “Cryptogram Word Brain Puzzle” app, or other apps provided on a mobile platform or our corporate website available at https://joyteractive.com (each being, our “Platform”, collectively, the “Platforms”), we may collect, store and process some data, including personal data. This privacy policy (“Privacy Policy”) sets out the main principles on which the data collected from you, or that you provide to us, will be processed by us. This Privacy Policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them. 

California residents may have different or additional rights. Please see the section titled Privacy Notice for California Residents.

If you have any questions related to this Privacy Policy or our practices around privacy and data protection in general, please don’t hesitate to contact us.

BY USING THE PLATFORMS, YOU PROMISE US THAT YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY. If you do not agree, or are unable to make this promise, you must not use the Platforms. In such case, you must (a) delete your account using the functionality found in “Settings” in the App, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) delete the App from your devices.

1. WHAT DATA DO WE COLLECT AND PROCESS?

When you visit our Platforms, you may provide us with the following types of data, and we may collect and process such data in accordance with this Privacy Policy, as follows:

Contact Data	This may include your name and your email address. This information will be collected by us if you communicate with us, for example if you use the links on our Platforms to communicate with us via email.
Account Data	If you create an account on our Platforms to benefit from our Platforms, you may need to provide your name, email address, phone number and your photograph. If you use Facebook or Google to login to our Platforms, Facebook [or Google] will share data with us including but not limited to your profile data, language, location and publicly available information about you and your friends.
Correspondence Data	This includes the information you provide when you request support through our Platforms, contact us via the email address provided in this Privacy Policy and elsewhere on our website and your views, opinions and feedback which you choose to provide in relation to the Platforms and our services, including any comment facilities and message boards.
Session Data	This includes your IP address, your device’s unique identifier details, browser details including version, device operating system, geo-location, time zone setting and time/date of access requests, the amount of data transmitted and the requesting provider. We may also capture other information about visits to our Platforms such as pages viewed and traffic patterns.
Cookie Data	Cookies are small files which are downloaded to your device when accessing our Platforms. Most web browsers automatically accept cookies. Please refer to paragraph 4 below for further details about our use of cookies.
Preference data	This includes any information you choose to provide us, such as your musical preferences relating to genres and artists.
Payment data	Our Platforms include purchases directly in the application (including subscriptions)  and/or purchases directly through our website. If you want to make a purchase in the application, you may do this with the help of payment system provided by Google Play (managed by Google) or AppStore (managed by Apple) and integrated into the apps. The in-app payment system is managed by the Google Play/AppStore administration or its authorized partner. Under no circumstances do we collect or process any information related to your payment instruments, such as bank card number, its validity term or your name as written on it. When you purchase directly through our website, including subscription, you authorize us to have our payment processor collect this information. We do not store such information on our servers.

1. HOW DO WE USE DATA?

When you use our Platforms, we can collect and process some of your data for different legitimate purposes. You will find below explanations regarding the reasons why we may collect data and the legal bases we rely on in each case.

Data we use:	Purpose:	Lawful Basis:
Contact Data	To respond to communications that you send to us	Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise legitimate interests so that we can respond to your query
	To market products and services to you only where you have requested that we do so, or otherwise provided your explicit consent (either via our website, by emailing us or by accepting push notifications on your device)	Consent
	Customer relationship management (“CRM”) purposes	Necessary for the performance of a contract
	To enable social functionality, such as giving you the option to follow your contacts on the Platforms.	Consent
Account Data	To enable you to personalize your use of our services; To enable you to save and maintain your profile and administer your account with us; and To enable us to identify you.	Necessary for the performance of a contract
Correspondence Data	To help address issues you raise with us and to improve the Platforms and our services.	Legitimate interests
User Content	To enable you to use our Platforms and services	Necessary for the performance of a contract
	To share the User Content with other users of the Platform by making it available on the Platform.	Legitimate interests
Session Data	To administer, maintain and improve the Platforms and our services, including identifying you or your device across our Platforms. To identify and respond to potential risks to the security of our Platforms (for example spammers, phishing attempts, screen scraping and other actions which may violate our Terms of Use).	Legitimate interests
Preference Data	To infer your interests, including serving and suggesting content that you might like, and tailoring advertising to you based on such preferences.	Legitimate interests

III. DATA RETENTION

1. By using our Platforms, you consent for us to store your personal data in line with legal, regulatory, financial and good-practice requirements.
2. The period for which we may retain your personal data will depend on the type of personal data collected, the purposes for which it was collected, applicable limitation periods for the exercise of legal rights and whether any legal or regulatory obligations require the retention of the personal data                                                                         IV. COOKIES AND TRACKERS
   We use cookies and other software development kits (“SDKs”) and third-party libraries. Our Platforms uses the following categories of cookies:

Strictly necessary cookies	These are cookies that are required for the operation of our Platforms. They include, for example, cookies that enable you to load webpages.
Analytical/performance cookies	These cookies allow us to recognize and count the number of visitors to our Platforms and to see how visitors move around our Platforms. This helps us to improve the way our Platforms works, for example, by ensuring that visitors are finding what they are looking for easily.
Functionality cookies	These are used to recognize you when you return to our Platforms. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Tracking ID	Every iOS and Google Android device has a unique Tracking ID, for iOS devices, called an Identifier for Advertising (IDFA) and for Android devices, called a Google Advertising ID (AAID). These Tracking IDs enable app providers and advertisers to track user activity and target ads at those users.

     1. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

2. You may block cookies by updating the relevant settings on your device or browser to allow you to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our Platforms.                                                        
   
   V.WHO DO WE SHARE YOUR DATA WITH?

Joyteractive does not share your personal data except as consented by you or as described herein. We may need to share your personal data with selected third parties in the following circumstances:

Third party service providers	This may include providers of certain systems and services that we use to host, administer and maintain our Platforms, including for example the servers used to host our Platforms, email service providers, payment processors, fraud prevention vendors, analytics, customer service providers and other service providers.
Third party service providers for marketing purposes	If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms.

A list of these third-party service providers and business partners their privacy policies is available at joyteractive.com The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to check those privacy policies to learn more about their data collection and use practices.

To comply with legal or regulatory requests	If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.
Prospective buyers or sellers	If Joyteractive, or its owners, buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Joyteractive (or substantially all of its assets) is acquired by a third party, your personal data held by Joyteractive, or within such assets, may be transferred to such third party.

       VI. INTERNATIONAL TRANSFERS

1. We will not transfer your personal data outside of the EU, except as set out in paragraph 5 above, for example if we utilise cloud-based platforms to store personal data, which may involve use of geographically distributed data centres.
2. In the case of these extra-EU transfers, where the transfers are not to countries that provide an adequate level of protection, we will put in place appropriate safeguards to cover transfers of personal data including, for example, signing standard contractual clauses, relying on a Privacy Shield certification and/or data protection clauses adopted by the European Commission.
3. If there are any other circumstances which would require us to transfer personal data outside of the Cyprus, we will seek your consent to transfer your personal data outside of the Cyprus.

VII. THIRD PARTY WEBSITES

Our Platforms may contain links to third party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any data to those websites.

VIII. SECURITY

1. We take data security seriously. We implement and maintain appropriate technical and organizational measures including resilient security systems and protocols to protect the personal data we store.
2. We have put procedures in place to deal with any suspected data security breach and will notify you and applicable regulator of a suspected breach where the breach may cause a risk to you.
3. Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal data to you.
   
   IX. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you have the following legal rights:

a.	To access personal data we hold on you;
b.	To request us to make any changes to your personal data if it is inaccurate or incomplete;
c.	To request your personal data is erased where we do not have a compelling reason to continue to process such personal data in certain circumstances;
d.	To receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the personal data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
e.	To object to, or restrict, our processing of your personal data in certain circumstances;
f.	If we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
g.	If we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
h.	To object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;
i.	If we are processing your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us;

To exercise your rights, please contact our data protection officer at contact@joyteractive.com  or write to us at the address set forth in the “Contact” section.

     X. OUR POLICIES CONCERNING CHILDREN

Our Platforms are not intended for children (under the age of 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data or target interest based advertising to children and we do not knowingly allow children to register for or use the Platforms. Children should not use our Platforms or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If you believe that we might have information from or about a child, please contact us contact@joyteractive.com

1. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 6th, 2022
This Privacy Notice for California Residents supplements the information contained in Joyteractive Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. This Privacy Notice for California Residents describes the types of information we may collect from you or that you may provide when you use Joyteractive app(s) or our corporate website available at https://Joyteractive.com (the “Platform(s)”).

INFORMATION WE COLLECT

(1) This Privacy Notice for California Residents applies to information we collect:
In this Platform;
In email, text, and other electronic messages between you and this Platform;
Where such collected Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).
In particular, the Platform has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories	NO
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

(2) Joyteractive obtains the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions in the Platform.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the Platform and of the fulfillment of your orders.

(3) This Privacy Notice for California Residents does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Joyteractive or any third Party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or in the Platform.

(4) Information We Collect Through Automatic Data Collection Technologies:
As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service.

(5) The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.

USE OF PERSONAL INFORMATION

(1) How We Use Your Personal Information
We use information to provide the Platform functionality, fulfill your requests, improve the Platform quality, engage in research and analysis relating to the Platform, personalize your experience, track usage of the Platform, market the Platform, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Platform, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.
We also use information that we collect about you or that you provide to us, including any Personal Information:

To present our Platform and its contents to you.

To provide you with information, products, or services that you request from us.

To fulfill any other purpose for which you provide it.

To provide you with notices about your account, including expiration and renewal notices.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Platform or any products or services we offer or provide though it.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information, including integrated third party products.

To provide, support, personalize, and develop our Platform, products, and services.

To create, maintain, customize, and secure your account with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA

Joyteractive will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

(2) Sales of Personal Information
In the preceding twelve (12) months, Joyteractive has not sold Personal Information.

(3) Sharing Personal Information
Joyteractive may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:

Subsidiaries and affiliates.

Contractors and service providers.

Data aggregators.

Third parties with whom we partner to offer products and services to you.

(4) We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply any agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Joyteractive, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
In the preceding 12 months, Joyteractive has disclosed the following categories of personal information for a business purpose:
Identifiers, Biometric information, Commercial information, Internet or other similar network activity, Sensory data, Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:

Subsidiaries and affiliates.

Contractors and service providers.

Data aggregators.

Third parties with whom we partner to offer products and services to you.

YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

(1) Access to Specific Information and Data Portability Rights
You have the right to request that Joyteractive disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

The categories of Personal Information we collected about you.

The categories of sources for the Personal Information we collected about you.

Our business or commercial purpose for collecting that Personal Information.

The categories of third parties with whom we share that Personal Information.

The specific pieces of Personal Information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and

disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

(2) Deletion Request Rights
You have the right to request that Joyteractive delete any of your Personal Information that we collected from you and retained, subject to certain exceptions including regulatory data retention requirements. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(3) Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:

75 Prodromou Avenue, 2063 Nicosia, Cyprus

Joyteractive LIMITED or contact@Joyteractive.com

Attn: Data Protection Officer

75 Prodromou Avenue, 2063 Nicosia, Cyprus

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

(4) Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@Joyteractive.com or write us at:
Joyteractive LIMITED

Attn: Data Protection Officer

75 Prodromou Avenue, 2063 Nicosia, Cyprus

CHANGES TO OUR PRIVACY NOTICE
Joyteractive reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice in the Platform and update the notice’s effective date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.

XII. CONTACT

Joyteractive’s Data Protection Officer
You may contact Joyteractive’s Data Protection Officer at contact@joyteractive.com or the address below for further information.
75 Prodromou Avenue, 2063 Nicosia, Cyprus

Joyteractive’s EU Representative
You may contact Joyteractive’s EU representative at the address below.
75 Prodromou Avenue, 2063 Nicosia, Cyprus

XIII. CHANGES TO THIS PRIVACY POLICY

1. Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.