EPL MANAGER FANTASY FOOTBALL PRIVACY & COOKIE POLICY

(Last updated: 25 Feb 2016)


Your privacy is important to us! We are committed to protecting your Information and providing you with a safe, efficient and customized experience. We have created this Privacy and Cookie Policy to let you know what information we collect when you use and access the Game, why we collect this Information and how we use the collected Information. The defined terms used in this Privacy Policy shall have the same meaning as specified in the Terms of Use.

1. ABOUT THIS PRIVACY AND COOKIE POLICY (this "Privacy Policy")

1.1 This Privacy Policy represents an agreement between you and Heng Saab Co., Ltd., a company registered under the laws of the Kingdom of Cambodia with its registered address at #144, Street 169, Sangkat Veal Vong, Khan 7 Makara, Phnom Penh, Cambodia (the "Company", "we" or "us" as applicable). This Privacy Policy sets out the ways that we use the personal information which we may gather in providing you with the Game, software, updates, add-ons (including Virtual Items) and services that are offered to you by the Company.

1.2 Where and when you use or access the Game run and provided directly by the Company, then the Company is the data controller of your personal data.

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

2. AGREEING TO THIS PRIVACY POLICY

2.1 You agree to this Privacy Policy by accessing and using the Game.

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

2.3 The Company reserves the right to amend this Privacy Policy at any time. We recommend that you revisit this Privacy Policy on a regular basis. You shall also be notified of any such amendment via the respective platform through which you download the mobile applications of the Game (the "Applications"). For the avoidance of doubt, your continued use of the Game shall be interpreted as deemed acceptance of any modifications to this Privacy Policy.

2.4 If you have any questions regarding this Privacy Policy, do not hesitate to write to us via our "Contact us" section.

3. THE INFORMATION WE COLLECT

3.1 Information You Provide to Us.

We may collect:

- Personal information from you when you create your team and/or register your account/profile, including your first name and surname, country of residence, gender, date of birth, email address, mobile phone number, username, if any, and password.

- Transaction information you provide when you request information or purchase a product or a virtual item from us, whether on our Website or through the Applications

- Your Game history with us and your usage of the Game’s features.

- Information you provide in public forums on our Website and the Applications.

- Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information.

- When you participate in one of our surveys we may collect additional information.

- Information provided when you report a problem with any part of the Game.

- Information you provide to us when you use our Website and the Applications, our applications on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account.

- Location information when you visit our Website or the Applications, including location information either provided by a mobile device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information.

3.2 Information Collected via Technology

Information Collected by our Servers. To make the Game more useful to you, our Website automatically tracks certain information about the visits to our Website, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, clickstream data, referring/exist pages, and/or a date/time stamp for your visit. We use this information to analyze trends, administer the Website, gather demographic information about our user base as a whole, and to improve the Game, as well as for product development purposes.

Cookies. Like a typical online game or service, we use cookies to collect information. "Cookies" are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience while playing and using the Game. This type of information is collected to make the Game more useful to you and to tailor your experience with us to meet your special interests and expectations.

Pixel Tags. In addition, we may use "Pixel Tags", also known, among other names, as Web beacons. Pixel tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of web users. In contrast to Cookies, which are stored on a computer’s hard drive or web browser, Pixel Tags are embedded invisibly in web pages. Pixel Tags also allow us to send email messages in a format that users can read, and tell us if emails have been opened to, in part, ensure that we are sending only messages that are of interest to our users.

For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.

Data Collected in Connection with Advertising. We may use third parties to serve ads on the Website and in the Applications. In connection with the delivery of advertising, certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to access the Game. They do this by using Cookies, Pixel Tags, or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Website and the other sites tracked by these third parties. This Policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies.

If you would like more information about this practice and to know your choices about not having this information used by these companies, visit http://www.aboutads.info/choices.

Mobile. We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Application(s), and information about the type of device you use, your device operating system, etc.

Third Party Analytics. We use a number of third party service providers, such as Google Analytics, to help analyze how users use our services. These third party service providers use Cookies to collect information such as how often users visit our Website, what pages they visit, and what other sites they used prior to coming to the Game. We use this information we receive from these companies to improve our Game and your user experience.

Referral Affiliates. We may enter into agreements with companies that refer users to the Game by way of hyperlinks made available on the referring party’s website. We may automatically collect certain information, such as [your IP address, referring website, and your IP address] via the Cookies and Pixel Tags that are provided to us in connection with your use of the referring party’s website. This Privacy Policy does not apply to, and we are not responsible for, Cookies or Pixel Tags provided by third party websites.

Location Information. We may collect your location information including for the purpose of verifying whether you are eligible to participate in our Leagues and tournaments as the case may be.

3.3 Information Collected via Invite-a-Friend (referral) Feature

The Game may enable you to invite your friends to join the Game or a League. We enable users to invite friends either by enabling us to send emails on your behalf or a message via different messenger applications (e.g. Viber, Line, WhatsApp, your mobile phone SMS function, etc.). We also enable you to send invitations via social media sites (such as Facebook, etc.).

We may collect the email addresses and other information you provide in order to facilitate such invitations. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above.

You may be offered the option of importing your contact list or address book contacts, either automatically or manually, into the Game in order to enable you invite your contacts to become users of the Game. Should you opt to import your contact list or address book contacts, you are authorizing Us to store your contact details on our databases for these purposes, unless you expressly revoke this authorization.

You or the third party may contact us at our "Contact us" section to request the removal of this information from our database.

4. HOW WE USE INFORMATION

4.1 General Use. In general, the personal information you submit to us is used either to respond to the requests you make, or to help us serve you better. We use your personal information in the following ways:

- to create and secure your team and account in the Game;

- to identify you as a user in our system and to otherwise administer and operate the Game, including the Applications;

- to improve the quality of experience when you interact with and use the Game, including the Applications;

- to send you administrative email notifications, such as security or support and maintenance advisories;

- to allow you to participate in Leagues;

- to prevent fraud and provide you with secure experience;

- to deliver customized or personalized content, information or advertising;

- to respond to your inquiries and other requests; and

- to send newsletters, surveys, offers and other promotional materials related to the Game or on behalf of third parties and to monitor the effectiveness of our marketing programs.

4.2 Anonymous Data. We may create anonymized data (data that is not reasonably associated with or linked to any data that would reasonably be expected to allow someone to identify you or contact you) from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymized data to analyze request and usage patterns so that we may enhance the content of the Game improve navigation. We reserve the right to use anonymized data for any purpose and disclose anonymized data to third parties for any reason.

5. SHARING YOUR INFORMATION WITH OTHER COMPANIES

We will not share your personal information outside the Company or its direct affiliates except in limited circumstances, including:

- When you allow us to share your personal information with another company, such as:
Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services;
Directing us to share your personal information with third-party sites or platforms, such as social networking sites;
Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices.

- When companies perform services on our behalf, like package/prize delivery and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.

- When we share personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or Game Rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law.

6. YOUR CHOICES REGARDING YOUR INFORMATION

6.1 Message (Email, SMS, Messenger Messages) Communication. We will periodically send you free newsletters, alerts and other messages via different technologies (including email, SMS, Messenger Messages) that contain information about our various products and services, or other products and services we feel may be of interest to you. At any time you can easily indicate your preference to stop receiving further communications from us and you may opt out of receiving further marketing from the Company by letting us know at "Contact us" section or by following the unsubscribe instructions provided in the message you receive, as the case may be. Despite your indicated message preferences, we may send you service related communications, including notices of any updates to our Terms of Use and this Privacy Policy.

6.2 Changing or Deleting Your Personal Information. You may change any of your personal information in your Account/Profile by editing your "personal information" within your Account/Profile or by contacting us at "Contact us" section. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

6.3 Applications. You may stop all collection of information by the Applications by uninstalling the Applications. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

7. HOW WE RESPOND TO DO NOT TRACK SIGNALS

Some web browsers may transmit "do not track" signals to the websites and other online services with which your web browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

8. PROTECTION OF MINORS

The Game provided by the Company may only be used by a person of the Minimum Legal Age in his/her respective jurisdiction. We will use our reasonable efforts to ensure that minors do not participate in the Game.

9. SAFETY MEASURES TO PROTECT YOUR INFORMATION

We take reasonable measures to protect the 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.

10. DISCLAIMER

You expressly agree that the Game are provided on an "as is" basis without warranties of any kind. We are not responsible for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee, nor do we represent, that there will be an error-free performance regarding the privacy of your Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of your Information.

11. INTERNATIONAL TRANSFERS

Your 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 Game, you expressly consent to any transfer of information outside of your country.

12. MERGERS AND OTHER EVENTS REQUIRING TRANSFER

If the Company 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 are entitled to share your Information you have provided through the Game to potential and subsequent business and merger partners. By agreeing to this Privacy Policy, you give your consent to such transfer of this Information.