Gala Privacy Policy

Last updated: June 22, 2021

We have created this Privacy Policy to let You know what Personal Information We collect when You use the Services (defined below), why We collect this Personal Information and how We use the collected Personal Information. Your use of the Services is governed by the Terms of Service and the defined terms used in this Privacy Policy shall have the same meaning as specified in the Terms of Service.

1. ABOUT THIS PRIVACY POLICY (the “Privacy Policy” or the “Policy”)

1.1. The Terms of Service represents an agreement between you (“You” or “Your”) and Gala Sports Technology Limited (“Gala”, “We”, “Us” or “Our”). This Policy, however, sets out the ways that We use the personal information which we may gather in providing you with games, software, updates, add-ons (including virtual goods and virtual currency) and services that are offered to you by us as well as any Gala website which you access to avail of any of the above (collectively, the “Services”). We are not a “business” as defined under the California Consumer Privacy Act (the “CCPA”), and therefore, we are not required to comply with the CCPA requirements at this time.

1.2. References to Gala in these Terms shall include any Gala affiliates which shall include subsidiaries, parent companies and any other entities under common ownership. Where you receive or participate in a Service provided directly by Gala, Gala is the data controller of your personal data.

1.3. Our Services may be accessed through one or more third party websites, services or platforms (such as Facebook or the App Store). In addition, payments are processed through third party payment processors (for example, through a third-party service or platform which you are using to access the Services, such as Google’s or Apple’s app store). Our Services may also contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your personal information, we recommend that you carefully review the privacy policies of other websites and services that you access.

1.4. This Privacy Policy should be read in conjunction with Our Terms of Service and any additional applicable terms brought to your attention when You access the Services. Where you access and use the Services, you will also be bound by our Terms of Service.

1.5. We reserve the right to amend this Privacy Policy at any time and You shall be notified of any such amendment via the platform through which You access the Services and/or by Us publishing the modified Privacy Policy on any platform through which You access the Services. We recommend that You revisit this Privacy Policy on a regular basis. For the avoidance of doubt, Your continued use of the Services will be governed by the then-current Privacy Policy.

1.6. If You have any questions regarding the Privacy Policy, visit our Support Centre at www.galasports.net.

2. HOW WE COLLECT INFORMATION

- Online identification information (including user ID, system account, system language, IP address, and password)

- In-game property information tied to your user ID (including dealing records, balances, coupons, game exchange codes and payment currency)

- Personal in-game records and log information tied to your user ID (including in-game usage records, order records, and operation logs);

- Device information (including device model, device MAC address, operating system type, language, time zone and device settings);

- Networks (including connection type (WIFI/cellular) and network operators)

- Unique device identifier (such as IMEI/android ID/IDFA/OPENUDID/GUID, and basic information of personal devices including IMSI information of the SIM card);

- If a user chooses to sign up the game with his/her email account, we will record it as his/her user ID. (sign-up approach is optional, users can register with self-customized ID, email address or link to his/her social network account or store account).

2.1. Depending on the nature of the Services which You use, We may, in accordance with this Privacy Policy, collect information and/or personal data, including but not limited to, email address, or mobile phone number and certain usage information set forth below.

2.2. We will also collect:

The information set out in sections 2.1 and 2.2 is collectively the “Personal Information” insofar as it is information which is capable of identifying You.

2.3. You can control the amount of Personal Information that is collected, stored and used by Us by altering Your privacy settings on the mobile device, platform or service through which you access the Services. In addition, you can choose a random user ID instead of using your email address. You can find out more about these settings, and how to control them, on the mobile device, platform or service from which You access the Services.

2.4. We may collect, store and use in accordance with this Privacy Policy certain Personal Information where: (i) You provide such Personal Information directly to Us; (ii) We collect through the use of the Services, or (ii) You authorized through Your use of a third party platform or service, which may, with your permission, provide this Personal Information to Us through its application programming interface. We may also receive Personal Information from Our third-party service providers. We will have access to any Personal Information You provide to such third-party service providers. We will use that Personal Information to provide you with the Services and as otherwise set out in this Privacy Policy.

2.5. By accessing or using the Services via Your mobile phone, or other mobile device, You are authorizing Us to collect its unique device identifier and IP address. We may also associate your user ID with Your mobile phone or other mobile device, device type, mobile phone number, country, and any other information You choose to provide.

2.6. We receive and store the information that You provide, including Your mobile telephone number, when You sign up to and consent to having text messages sent directly to Your mobile phone. These text messages notify You of in-game activity within the Services and may allow You to access the Services from Your mobile device.

2.7. Should You purchase a license to use Virtual Items through a third party platform, and that purchase is processed by or on behalf of a third party (e.g. Apple Inc. where You have made a purchase on an iOS device), We may receive payment information which You provide to that third party but only in order to allow us to provide you with the license to use Virtual Items. Any purchases which You make through a third party in this manner may be subject to their policies and it is Your sole responsibility to ensure Your compliance with those policies. We do not collect, nor do we have access to any of your credit card or financial account information. That data is collected and processed by third party payment service providers (for example, the platform through which you are accessing the Services).

2.8. We do not allow third parties to collect Personal Information about Your online activities over time and across different internet websites, online or cloud computing services, online applications, or mobile applications when you use the Services.

3. HOW WE USE INFORMATION

3.1. We use information held about you in some of the following ways:

- To provide you with the Services.

- To ensure that content from Our Services is presented in the most effective manner for you and for your computer or other device from which you access the Services.

- To provide you with information or services that you request from Us or which We feel may interest you, but only if you have consented to be contacted for such purposes.

- To perform Our obligations under any contracts entered into with you.

- To allow you to participate in interactive features of Our Services if you choose to participate.

- To notify you about changes to Our Services.

- To provide you with support and other administrative services.

- To prevent fraud and provide safe and secure Services.

- To comply with our own legal obligations.

3.2. Where you access the Services as an App or through a third party platform such as Facebook, we may from time to time send you “push notifications” provided that you have allowed us to do so in accordance with the settings on your mobile device. You can manage push notifications within the settings of your mobile device.

3.3. Please remember that using the Services may reveal information relating to you which is publicly available on the platform that you are using to access the Services (for example, your screen name, your profile picture and the content of your publicly available communications to other users).

3.4. We are not responsible for the activities of other users or other third parties to whom you knowingly choose to provide your Personal Information (whether via Our Services or otherwise).

3.5. If your account on our Services is closed, we are obliged to store the Personal Information which is saved in our database for a period of time to allow us to comply with applicable laws. Please note that it is not possible to delete Your Personal Information prior to the expiry of applicable statutory retention periods and in order for us to comply with our legal obligations.

3.6. We may disclose Your Personal Information, and the contents of all Your online communications, if required to do so by law, or if We believe in good faith that such action is necessary to: (i) comply with any applicable laws or regulations or any legal process served on Us, the Services or in circumstances where We are under a substantially similar legal obligation; (ii) protect and defend Our rights or property; (iii) act to protect the personal safety of users of the Services or the public; or (iv) if, in Our sole determination, You are found to have cheated or attempted to defraud Us or any other user of the Services in any way, or if We suspect You of any fraudulent activity.

3.7. We may further provide Your Personal Information to any third parties and data processors providing services to Us, including but not limited to email delivery, customer service, hosting and marketing services, and by helping us to administer and provide the Services. We take measures to ensure that Our arrangements with third party service providers and data processors protect the privacy of Your Personal Information and that such third parties do not use Your Personal Information for any other purpose than to provide services to Us.

3.8. We will not actively share Your Personal Information with third party advertisers for their direct marketing purposes. We may, however, share (i) aggregated information (information about You and other users collectively, but not specifically identifiable to You); (ii) anonymous information; and (iii) certain technical information to develop and deliver targeted advertising in the Services and on the websites of third parties. Our collection, use, and disclosure of anonymous or aggregated information are not subject to any of the restrictions in this Privacy Policy.

3.9. The Services support and may encourage interaction among users. Access to your username may allow other users to view the public information associated with your related account and to communicate with you through the related social network communication channels.

3.11. You may contact Us by visiting our Support Centre at www.galasports.net if You: (i) want to confirm the accuracy of the Personal Information We have collected about You; (ii) would like to update Your Personal Information; and/or (iii) have any complaint regarding Our use of Your Personal Information. If requested, We will (x) update Your Personal Information, provided that You provide evidence as We may reasonably require for such changes, or (y) mark any Personal Information to prohibit future use for marketing purposes.

3.12. For the avoidance of doubt, nothing in this Privacy Policy shall prevent Us from retaining Your Personal Information where We are required to do so by law. If You have sent or posted content on the Service, We may not be able to delete it.

4. COOKIES AND AUTOMATED INFORMATION COLLECTION

4.1. By accessing or using the Services You authorize Us to collect certain technical information in order to (i) analyze usage of the Services; (ii) provide a more personalized experience; and (iii) manage advertising. We, and our third party service providers, may use server log files or web log files and tracking technologies to collect and analyze certain types of technical information, including but not limited to, cookies, IP addresses, device type, device identifiers, browser types, browser language, URLs, domain names, landing pages, game state, the date and time of usage of the Service, and other similar information for our internal business purposes.

4.2. Currently, the Services do not have any active Google Analytics cookies. However, in the future, the Services may activate and use Google Analytics or other Google cookies, including its Remarketing feature based on Display Advertising (www.google.com/analytics/) for online advertising and for website analytics purposes – meaning that We use them to see how many visitors come to Our website, the pages that generate interest and the links that visitors most often click on (amongst other things). Google Analytics uses cookies – small text files that are placed on your computer that store certain limited information about you. The cookies we use do not enable any visitor to Our website to be individually identified and will only be used for online advertising and website analytics purposes. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager, or by visiting https://tools.google.com/dlpage/gaoptout/.

Generally, the Services do not use third-party cookies, but only cookies which allow us to collect information regarding Your use of the Services. In order to see more details about cookies generally, click here.

5. REQUIRED ADDITIONAL NOTICES.

5.1 Notice to California residents. We do not disclose your Personal Information to any third party for such third party’s direct marketing purposes without you expressly consenting or opting-in to this disclosure prior to us providing such third party your Personal Information. You do not have to consent or opt-in to this disclosure to use our Service. Thus, under California Civil Code Sections 1798.80-1798.84, upon your request, we have no obligation to provide you further information. Provided, however, you can contact us at the email address below to withdraw your consent or opt-out of such disclosures. Any inquiries regarding the Terms of Service or, specifically, this Privacy Policy can be directed to the contact identified below.

5.2 Notice to Nevada Residents. Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to service@galasports.com.

5.3 Protection of Minors. In compliance with the Children's Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, the Services does not collect information from children under thirteen (13) years of age, and we do not intentionally collect information from persons under thirteen (13) years of age. If you are a parent or guardian and you are aware that a child under 13 has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under 13 without verification of parental consent, we take steps to remove that information from our servers. The Services provided by Gala (including the game Football Master Chain Eleven) may only be used by a person over the age of 16 or a person between the age of 13 and 16 where that person’s parent or guardian has reviewed and consents to the Terms on their behalf. Any person who provides Personal Information to Gala through any part of the Services represents to Gala that they are 16 years of age or older or that they are between 13 years of age and 16 years of age and their parent or guardian has reviewed the Terms and this Policy and has consented on their behalf.

6. SAFETY MEASURES TO PROTECT YOUR INFORMATION

6.1. We take reasonable measures to protect the Personal Information that we collect from or about you (including your personally identifiable information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

7. INTERNATIONAL TRANSFERS

7.1. Your Personal Information collected by Us may be stored and processed in any country in which We or Our affiliates, suppliers, ESPs or agents maintain facilities. By using the Service, You acknowledge that your Personal Information may be transferred outside of Your country.

8. MERGERS AND OTHER EVENTS REQUIRING TRANSFER

8.1. If We should ever file for bankruptcy, or become insolvent, or be acquired by a third party, merge with a third party, sell all or part of Our assets, or transfer substantially all or part of Our relevant assets to a third party, We may share Your Personal Information to potential and subsequent business and merger partners.

9. YOUR RIGHTS

9.1. The following applies only to the processing of Your Personal Information by Gala in the provision of the Services. You can contact Our Help center at www.galasports.net to request that We provide you with access to your Personal Information or that We update or delete your Personal Information from Our database. We may retain an archived copy of your records if required to do so by law or for legitimate business purposes (for example, where deletion of your Personal Information from our database may severely disrupt or disable your use of Services).

10. DO NOT TRACK SIGNALS

10.1 Because there is no consensus on how companies like ours should interpret “Do Not Track” signals, We do not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. You can learn more about Do Not Track here: http://www.allaboutdnt.com/.

11. CONTACT US

For any questions regarding this Privacy Policy, please contact Our Help center at www.galasports.net or via email at service@galasports.com