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Suggested text: Our website address is: https://seanear.com.

Seanear Privacy Policy
Effective Date: Oct. 19, 2023

Last Update: May, 11, 2024

Seanear Limited (“Seanear”, “us”, “our” or “we”) provides this Privacy Policy (this “Policy”) to describe the ways we collect, store, use, and manage the information, including personal information, and data that our users (“users” or “you”) provide or we collect in connection with the Seanear website available at https://seanear.com and any Seanear game provided on a mobile platform (each a “Service,” collectively, the “Services”). Please note that the scope of this Policy is limited to information and data collected or received by Seanear through your use of the Services. Seanear is not responsible for the actions of individuals with no relationship to Seanear or third party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

Information and Data We Collect from You

Personal Data Collected Directly from You
Seanear processes your personal data in order to provide the Services by downloading, accessing and/or playing our games or using our other Services. Most of this data comes directly from you. We collect the following information you provide in connection with our Services:
• Information collected via our customer support channels: when you interact with us via our customer support provider, we ask you to provide your username and email, and any information you choose to provide to allow us to assist you like Game ID, team/club name, device brand and model, advertising ID, transaction records or device language.
• Feedback and ratings you provide relating to our Services.
We use this data to provide our games and Services to you, including optimizing our Services, customization of in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy.

Information we collect automatically through the Services
We collect several different types of information for various purposes to provide and improve our Service to you, including:
• Log Information: We log information about your use of the Services, including the type of device you use, the features you use, access times and your location based on your Internet Protocol (“IP”).
• Device Information: We collect information about the device you use to access the Services, including information about the device manufacture, device model, device’s OS, time zone of device, language of device.
• Device identifiers: We collect online identifiers of the device you use to access the Services, including IDFA, Google Ads ID, Google Play Account ID.
• Usage Information: We collect information relating to your use of the Services, including your game progress, scores, achievements and interactions with other players.
• Consumption information: We collect information about your consumption habits relating to your use of the Services, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

Information we collect from third-parties
If you log into the Services using a third-party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third-party site or platform provided that you have given the third-party site in question such consent.
You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:
• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
• Google Play Games: https://policies.google.com/privacy
If you log into the Services using a third-party site or platform, you represent and warrant that your access and use of such features in connection with the Services will comply with the applicable terms and policies of such site or platform; and that you are over the minimum age limit that is prescribed for such third-party site or platform by the legislation in the individual jurisdictions.Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
• To provide and maintain the Services and the game experience;
• To enable us to provide our games (Services), to ensure that your purchases are activated in the games, and to provide you with player support if you need it;
• To enable us to optimize our Services for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
• To communicate with you regarding App-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
• To personalize and improve the Services and provide tailored content and features;
• To respond to your comments and inquiries and provide customer support services;
• To gather analysis or valuable information so that we can improve our Services;
• To monitor and analyze trends, usage and activities in connection with the Services;
• To detect, prevent and address technical issues and bugs;
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• To enable players to communicate with each other in games or on our social media accounts;
• To serve advertising;
• To provide and deliver the products and services you request and send you related information.
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

How We Use Your Information

Seanear’s primary goals in using your information are to create your account, provide Services to you, troubleshoot, improve and optimize our Services, contact you, conduct research and create reports for internal use. We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:

Create game accounts and allow users to play our games;
Identify and suggest connections with other Seanear users;
Operate and improve our Services;
Understand you and your preferences to enhance your experience and enjoyment using our Services;
Respond to your comments and questions and provide customer service;
Provide and deliver products and services you request;
Deliver advertising and marketing and promotional information to you;
Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by Seanear and our selected partners;
Conduct and administer contests promoted by Seanear;
Enable you to communicate with other users; and
Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.
Use of Your Information by Others
Third Party Services. Our Services may contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below.

The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

Advertising. To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads to you. Such mobile device data includes the following:

Device make, model and operating system;
Device properties related to screen size & orientation, audio volume and battery;
Carrier;
Operating system;
Name and properties of mobile application through which a consumer interacts with the Services;
Country, time zone and locale settings (country and preferred language);
Network connection type and speed;
IP Address;
Internet browser user-agent used to access the Services; and
Identifier for advertisers (IDFA).
The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:

DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon
You may also limit data collection by third parties by using your mobile device settings. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, please not that if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices.

How We May Store and Disclose Your Information to Third Parties

Seanear does not share your personal information except as approved by you or as described herein.
Your Information is kept for as long as necessary in order to provide you with the Services or otherwise fulfill the purposes as described above unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.

We may share information we collect or derive with third parties for the following purposes:

With service providers that perform services on our behalf, including the ones referenced above under “Third Party Services”;
With our affiliates;
For analytics and research purposes;
In response to subpoenas, court orders, or other legal processes;
To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
As part of a business transfer such as a merger, acquisition, or at bankruptcy;
We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties; and
We may use analytics services provided by third parties, including Google Analytics. These service providers may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes. To learn more about how Google analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/.
Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact Seanear at the address provided in the “Contact Seanear Studios” section herein and request to access the personal data that Seanear holds about you. Seanear may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide Seanear with the necessary information to correct it.

Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

Right to Make Complaint: if you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at developer@Seanear.com. We will look into your request and make good faith efforts to resolve any concern you may have.

Security Safeguards.

Seanear takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Data Retention.

Seanear retains your personal data for as long as needed to provide you Services, unless we are required by law to delete or if Seanear accepts your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Our Policy Regarding Children.

We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information 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. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.

Transfer of Personal Data Outside Your Country.

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.

Lawful Basis for Processing.

On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.

On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.

EEA Policy

If you are based in the EEA, Switzerland, or are a legal resident of California in the U.S., you have certain rights in relation to your Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights… For EEA, United Kingdom, Switzerland, and Brazil-based, you will find more information below on when which rights can apply. To exercise your rights, please follow the procedure set out below, use our web form (and choose: Type of issue ‘Related to my account’ > ‘I have data related question’), or email us at game@seanear.com
• Access: You have the right to access information and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets or give you Information about other individuals.
• Erasure: You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case. Note that where the Information is held by a third-party data controller, such as an advertising partner or a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.
• Objection and withdrawal of consent: You have the right to withdraw your consent where you previously provided such consent; or object to our processing of your Information where we process such Information based on our legitimate interests (see above under How we use your personal Information).
• Portability: You have the right to receive a copy of the Information we process based on consent or contract in a structured, commonly used, and machine-readable format or to request that such Information is transferred to a third-party.
• Correction: You have the right to correct any Information held about you that is inaccurate.
• Restriction: You have a right, in certain circumstances, to stop us from processing Information other than for storage purposes.

Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.

If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.

Changes to This Policy. We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if Seanear needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

Privacy Shield Framework
Seanear transfers certain personal data to the U.S. and participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Seanear is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework visit the U.S. Department of Commerce’s Privacy Shield List, available at: https://www.privacyshield.gov/list.

Seanear is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Seanear complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Seanear is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Seanear may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Seanear commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: bd@seanear.com. We will attempt to answer your questions and satisfy your concerns in a timely and complete manner. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If your complaint is still not resolved through these channels, under certain conditions, more fully described on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Contact Seanear
bd@seanear.com; game@seanear.com