Privacy Policy

Effective date: 16/02/2022

1. Who is responsible for processing your data and how to contact us

This Privacy Policy applies to all of our games, websites, and related services, collectively referred to here as our Services. Your continued use of the Services after the effective date will be subject to the new Privacy Policy. Your use of our Services, and any dispute over privacy, is subject to this Privacy Policy. Please read the following to learn more about how we use your personal data.

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), VOKI CYPRUS LTD (referred to as “VOKI,” “we,” “us,” or “our”) will be the data controller responsible for any personal data we process.

The data controller: VOKI CYPRUS LTD

Email: hello@vokigames.com

Address: 20 SPYROU KYPRIANOU, CHAPO CENTRAL, 1ST FLOOR, NICOSIA, 1075, CYPRUS

2. What personal data do we collect and why?

We may source, use and otherwise process your personal data in different ways. In each case, we are committed to protecting your personal data.

In each of the sections listed below, we describe how we gather your personal data and what we do with it.

2.1 Individual Customers

We collect personal data related to current, prospective, and former customers (“users”) of our Services.

A – Sources of personal data

We may obtain your personal data from the following sources:

1. a) from you directly (through the game, website, or online forms); and/or
2. b) from other entities, service providers that assist us in providing you with necessary services (including data analytics providers, operating systems, and internet services providers), or from your social network accounts that you used to sign in to our online services (for example, Facebook, Google).

B – Personal data that we collect and process

We may collect the following categories of personal data relating to our users:

• Contact information (such as name or nickname or email you submit as part of your registration for our Services or log-in or via social networks);
• Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
• Data about your device, such as manufacturer, operating system, CPU, RAM, browser type, language, current time;
• Broad location data (e.g. country or city-level location);
• Usage data, such as data we collect with cookies and similar technologies;
• Data (such as your nickname, email, profile picture) we receive if you link another provider’s tool with the Service (such as Facebook, Google, etc.);
• Data for advertising and analytics purposes, so we can provide you a better Service;
• Other data you choose to share with us.

C – Why do we collect your personal data, and what are our lawful bases for doing so?

We may use your personal data to	Our lawful basis for doing so is
Send you marketing communications via email	Consent
Study the behavior of the website visitors	Consent
Study location information, types of devices used, etc.	Consent

If you object to us using your personal data for the above purposes, including direct marketing, please let us know via the email address provided in section 1.

When we use your email to communicate marketing information to you, we will seek your prior consent if required by law.

We do not knowingly collect or solicit personal data about anyone under the age of 16.  We do not direct or target interest-based advertising to any person under the age of 16 knowingly. It is against company policy to allow such persons to use our Services. If you are under 16, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. If we learn that we have collected personal data about a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us so we can delete the user’s data.

D – How long do we keep your personal data?

We will process your personal data only for the purposes in which it was collected for, as long as necessary in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a more extended period or the data is necessary for the establishment, exercise or defense of legal claims.

2.2 Representatives of our existing or prospective employees, business partners, and vendors

We may collect personal data related to employees, directors, authorized signatories, or other individuals associated with VOKI’s existing or prospective corporate customers, business partners, and vendors.

A – Sources of personal data

We may obtain your personal data from the following sources:

1. a) from you directly;
2. b) from a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor;
3. c) during networking events that we have either hosted, or sponsored, or attended, including from entities conducting network events; and/or
4. d) from publicly available sources and social media networks (for example, your company website or social media sites, such as LinkedIn).

B – Personal data that we collect and process

We may collect personal data related to employees, directors, authorized signatories, or other individuals associated with our existing or prospective corporate customers, business partners, and vendors:

1. a) name;
2. b) business address;
3. c) business email address;
4. d) business telephone number; and/or
5. e) job title.

C – Why do we collect your personal data, and what are our lawful bases for doing so?

We may use your personal data to	Our lawful basis for doing so is	Our legitimate interests in doing so are
Establish and manage our relationship	Legitimate interest	Management reporting Security
Let you know about our products, services, and events that may be of interest to you by email or other forms of electronic communication	Legitimate interest	Understand the market in which we operate Promote our projects and vacancies

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the in-game Help & Support, or contact us at the email address provided in section 1. When we use your email to communicate marketing information to you, we will seek your prior consent if required by law.

D – How long do we keep your personal data?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you unless we have a legal right or obligation to retain the data for a more extended period or the data is necessary for the establishment, exercise or defense of legal claims.

2.3 Website visitors

We may obtain your personal data from the following sources:

1. a) from you directly (for example, at the time of subscribing to any services offered on our website, including but not limited to email mailing lists, interactive services, posting material); and/or
2. b) from your device or browser through internet service providers, operating systems and platforms, and data analytics providers.

If you contact us, we may keep a record of that correspondence.

B – Personal data that we collect and process

1. a) browser type;
2. b) information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
3. c) cookie data (for more information, please see our Cookie Notice);
4. d) preferences regarding online marketing; and/or
5. e) IP address.

C – Why do we collect your personal data, and what are our lawful bases for doing so?

We may use your personal data to	Our lawful basis for doing so is	Our legitimate interests in doing so are
Provide our website services to you	Legitimate interest	Website management
Learn about our website(s) visitors’ browsing patterns, and the performance of our website(s) which includes verifying or maintaining the quality of and improving our website, products, and services	Legitimate interest	Promote our products and services Account management Understand the market in which we operate Management reporting (including at an intra-group level) Account Management Website management: Understand the market in which we operate  Management reporting”
Security (including ensuring the confidentiality of personal data, preventing unauthorized access and modifications to our systems and otherwise maintaining the security of personal data)	Legitimate interest	Website management
Perform advertising or marketing services, including letting you know about our products, services, and events that may be of interest to you by email or other forms of electronic communication	Legitimate interest	Promote our products and services

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in section 1.

When we use cookies or similar technologies, we will seek your prior consent if required by law.

When we use your email to communicate marketing information to you, we will seek your prior consent if required by law.

D – How long do we keep your personal data?

We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.

3. Who do we share your personal data with

Our Partner Organisations and Service Providers

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

1. a) technical support providers who assist with our website and IT infrastructure;
2. b) software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
3. c) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
4. d) providers that help us generate and collate reviews in relation to our goods and services;
5. e) our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you;
6. f) service providers that assist us in providing our services.

Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

5. Your rights under the GDPR

You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data.

We do not carry out any decision-making based solely on automated processing, including profiling.

If you give us your consent to use your data, e.g., so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdraw your consent.

You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in the section labeled above: “Why do we collect your personal data?”

If you would like to exercise any of your rights as aforementioned, you may find our contacts above.