Updated: 16 May 2021
Satoshi Hero LTD, (“Satoshi Hero”) operates apps enabling users to play various games for entertainment purposes only with a chance to win prizes subject to certain conditions and limitations (including under applicable laws and regulations) (the “Service”). Satoshi Hero takes our users’ privacy very seriously and Satoshi Hero is committed to protecting our users’ information in full compliance with all applicable laws and regulations and to maintaining the confidence and trust of our users.
Please note that Satoshi Hero will not share any of your personal information or other identifiable information protected under applicable privacy laws and regulations, including, without limitations, the European Union’s GDPR (”GDPR”) (the “Personal Information”) with third parties for direct marketing purposes unless you affirmatively consent to such sharing of information, generally by “opting in” to such option.
Among others, you may opt-in by providing us with your phone number, email address or other communications methods for the purpose of receiving commercial offers or other notifications and updates from time to time.
Collection of Information and Types of Information Collected
Satoshi Hero collects Personal Information only to the extent it is necessary to fulfil any of the Service’s functions and activities.
If you use the Service through a third-party platform (such as Google or Facebook), Satoshi Hero may receive certain Personal information about you from such third-party platforms.
As an example only, Satoshi Hero may collect the following Personal Information from you directly or from third parties: (i) your personal picture; (ii) your username and your password; (iii) your user ID number (e.g. your Facebook ID number); (iv) your e-mail and other contact details you provided to us to the applicable third-party; (v) your contact list; (vi) your location data; (vii) you’re your gender; and (viii) your age and birth date.
Satoshi Hero may also collect the above Personal Information (and additional Personal Information including without limitations, copies of passport or other identification documents, utility bills, letters and other documentation) in case Satoshi Hero is required by applicable law to perform KYC/AML procedures, including without limitations, as a condition to a user redeeming any prizes on Satoshi Hero or performing any other actions from time to time.
Satoshi Hero may also collect certain information about your activities on or through the connected third-party services or through your use of the Service or any publicly available information about you.
Satoshi Hero may also collect information through your use of the Service such as if you (to the extent such features are provided by us from time to time) participate in forums/message boards, etc.
Finally, from time to time Satoshi Hero may use various tracking technologies to collect certain kinds of technical information, including without limitations: (i) the type of mobile or other device you are using; (ii) the type of your operating system, its version and platform type; (iii) your applicable mobile device’s identifiers; (iv) your browser type; (v) domain names, referring pages, pages viewed and other browsing information, etc.
Transfer of Information Internationally
When you use our services, your Personal Information may be sent to other countries including without limitations to the United States or out of the United States to other countries. Satoshi Hero may store Personal Information about users on servers located in the United States and in other countries, including countries in which the level of protection of Personal Information is not as strict as in the United States. When Satoshi Hero transfers your Personal Information internationally, Satoshi Hero will take reasonable steps to ensure that your Personal Information is treated securely, lawfully and in the manner Satoshi Hero describes here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your Personal Information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident. If you are a resident in a jurisdiction, where transfer of your Personal Information to another jurisdiction requires your consent, then you provide us your expressed and unambiguous consent to such transfer for us to provide you with our services.
A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when you access the Service.
Information contained in a cookie may be linked to personal information for purposes such as improving the quality of the service, tailoring recommendations to interests, and making the Service easier to use. Third party advertisers on the service may also use, place or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies.
You may disable cookies at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting a cookie from the websites you visit or limit the type of cookies you allow, however if you do not accept cookies you may not be able to use all features of the Service.
Satoshi Hero and our third-party service providers may also employ other similar technologies including, without limitations:
- web beacons, which allow us to know if a certain page was visited or whether an email was opened;
- tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and
- local shared objects which help us to reduce fraud, remember your preferences and speed up load times.
How Satoshi Hero Uses and Shares Your Information
Marketing and Advertising Practices
Satoshi Hero may contact you in different ways for marketing and advertising purposes provided that you agreed to receive such messages from us and we will provide you the option to indicate that you do not want to continue to receive our marketing and advertising messages (opting out). Among others, we may tell you about new features or services we think you would be interested in or to show you how to use a particular feature.
Satoshi Hero utilizes and is engaged with various advertising platforms and services providers to help deliver relevant advertising and marketing proposals to you. Satoshi Hero and such third parties may use your Personal Information to provide interest-based advertising and marketing proposals to you. You can “opt out” of interest-based advertising and marketing proposals by clicking relevant links inside the messages themselves or contacting us at: firstname.lastname@example.org .
We recommend that you review the privacy policies of our third-party advertising and marketing partners for more information on how they may use your Personal Information and on how to exercise your rights and preferences.
Such third parties include the following:
Satoshi Hero does not actively share personal information with third parties for their direct marketing purposes unless you give us your consent.
Depending on your mobile device and applicable operating system, you may be able to reset your identifiers to limit or prevent such information collection, including through the privacy settings on your mobile device.
Other Third-Party Services Providers
Satoshi Millions may share information with third-party suppliers and partners to perform services on our behalf, like data analytic services, e-mail delivery services, hosting services, customer support and other services, wallet services providers and to help us in our marketing efforts. Satoshi Millions requires such third parties to maintain the confidentiality of the information Satoshi Millions shares with them and not to use your information for anything other than to provide services on our behalf.
Sale or Merger
Other Cases in Which Satoshi Hero May Share Your Information
Accessing and Managing Your Information
Under applicable data protection laws and regulations, including the GDPR, you have the right to:
(i) access your personal data and receive a copy thereof i.e., obtain information on whether Satoshi Hero processes your personal data and specific information about any such processing;
(ii) rectify (amend) your personal data i.e., request to amend inaccurate personal data;
(iii) erase your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under applicable law apply);
(iv) restrict the processing of your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under applicable law apply);
(v) complain to a supervisory authority(ies);
(vi) withdraw your consent.
You may exercise any of your rights in relation to your personal data by written notice to us at: email@example.com .
How Satoshi Hero Protects Your Personal Information
Satoshi Hero has made reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access. While Satoshi Hero takes reasonable precautions against possible security breaches of our Service, no website or Internet transmission is completely secure, and Satoshi Hero cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
How Long Satoshi Hero Keeps Your Information
How long Satoshi Hero retains your Personal Information depends on why Satoshi Hero collected it and how Satoshi Hero uses it. Satoshi Hero will not retain your Personal Information for longer than is necessary for our business purposes or for legal requirements. For instance, Satoshi Hero may retain all or part of your Personal Information for a few years after you have decided to close your account if this is necessary to meet our legal obligations or to exercise legal rights.
To determine the appropriate retention period for Personal Information, Satoshi Hero considers the amount, nature, and sensitivity of the relevant Personal Information, the potential risk of harm from unauthorized use or disclosure of such Personal Information, the purposes for which Satoshi Hero processes your personal information and whether Satoshi Hero can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data. In some circumstances Satoshi Hero may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case Satoshi Hero may use this information indefinitely without further notice to you.
CCPA Notice (California)
Collection, Disclosure or Sale of Personal Information
The Categories of Personal Information that Satoshi Hero Collects
The following are the categories of the Personal Information that Satoshi Hero collects from you:
2. Internet or other electronic network activity information (such as browsing history, interactions with a website or advertisement).
3. Geolocation information.
4. Inferences drawn from the above information about your predicted characteristics and preferences.
5. Other information about you that is linked to the Personal Information above.
Such Personal Information was received from the categories of sources of information set forth below, was collected for all of the purposes set forth below and was sold, used or shared to the third parties listed below:
1. Categories of Sources: Satoshi Hero collects this personal information from the following categories of sources: our users and our partners.
These commercial and business purposes include, without limitation: (i) Providing Satoshi Hero’s products and services, (ii) Other business purposes as identified in the CCPA, which include: advertising or marketing services, auditing related to Satoshi Hero interactions with you, legal compliance, detecting and protecting against security incidents, fraud, and illegal activity, performing services (for us or our service providers) such as account servicing and analytics, internal research for technological improvement, internal operations, activities to maintain and improve Satoshi Hero’s services and other certain one-time uses.
3. Recipients of California Personal Information: To the extent that Satoshi Hero’s use of Personal Information constitutes a “Sale” under the CCPA, Satoshi Hero “sells” Personal Information to its partners.
Satoshi Hero discloses (or might disclose) the categories of Personal Information designated above to the following categories of third parties, for the above commercial and business purposes: Service providers (as defined by the CCPA), government entities (upon request and to the extent Satoshi Hero is obligated to do so), services providers such as fraud protection vendors and data analytics companies, wallet services providers, etc.
Your Rights Regarding Personal Information
If you are a California resident, you may exercise the following rights regarding your Personal Information, subject to certain exceptions and limitations:
- the right to know categories and specific Personal Information Satoshi Hero collects, uses, discloses, and sells about you over the past twelve (12) months, categories of sources from which Satoshi Hero collected your Personal Information, our purposes for collecting or selling your Personal Information, the categories of your Personal Information that Satoshi Hero has either sold or disclosed for a business purpose, and the categories of third parties with which Satoshi Hero has shared Personal Information,
- the right to request that Satoshi Hero delete the Personal Information Satoshi Hero has collected from you or maintain about you,
- the right to opt out of any “sale” of your Personal Information, and
- the right not to be discriminated against for exercising any of your rights under the CCPA.
To exercise any of the above rights, please submit a verifiable consumer request to us at: firstname.lastname@example.org .
Only you or a person registered with the California Secretary of State (which you authorized to act on your behalf), may make a verifiable consumer request related to your Personal Information.
If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent’s power of attorney.
Satoshi Hero may follow up with you to verify your identity before processing your authorized agent’s request. You may also make a verifiable consumer request on behalf of your minor child.
In order for your consumer request to be verifiable, you must:
- provide sufficient information that allows us to reasonably verify you are the person about whom Satoshi Hero collected personal information or an authorized representative. You will need to provide full name, date of birth, address, email address, whether you are a California consumer pursuant to CCPA (if you would like to know the specific pieces of personal information that Satoshi Hero has collected about you, or to delete your personal information), identification that clearly shows your name, date of birth and address (for example, passport or other photo identification), and (we will need advertising ID, or device id + device name in order to identify in our DB).
- describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
Satoshi Hero cannot respond to your request or provide you with Personal Information if Satoshi Hero 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 Satoshi Hero. Satoshi Hero will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Satoshi Hero endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Satoshi Hero requires more time (up to 90 days), Satoshi Hero will inform you of the reason and extension period in writing. If you have an account with Satoshi Hero, Satoshi Hero will deliver our written response to that account. If you do not have an account with Satoshi Hero, Satoshi Hero will deliver our written response by mail or electronically, at your option. Any disclosures Satoshi Hero provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Satoshi Hero provides will also explain the reasons Satoshi Hero cannot comply with a request, if applicable. For data portability requests, Satoshi Hero will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Currently, Satoshi Hero does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Satoshi Hero determines that the request warrants a fee, Satoshi Hero will tell you why Satoshi Hero made that decision and provide you with a cost estimate before completing your request.
Satoshi Hero will not discriminate against you for exercising any of your CCPA rights.
Satoshi Hero intends to fully comply with American and international laws respecting children’s privacy including COPPA. Therefore, Satoshi Hero does not collect or process any information for any persons under the age of 16. If you are under 16 and using the Service, please stop immediately and do not submit any information to Satoshi Hero. In the event that Satoshi Hero has inadvertently collected any information from users under the age of 16, please contact Satoshi Hero immediately.