Privacy Policy

Last Updated: Jan 5th, 2024

This Privacy Policy explains how We collect, store, use, and disclose information. This Privacy Policy applies to Our Website and Our corporate activities, collectively referred to as Our services ("Services"). By using Our Services or providing information to us, you consent to us collecting, storing, using, and disclosing information as described in this Privacy Policy.

For the purposes of this Privacy Policy:

  • "Company" (referred to as either the Company, We, Us or Our in this Agreement) refers to SEA Games Digital OÜ, Sepapaja 6, Tallinn, Estonia.
  • "Device" means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • "Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • "User" (referred to as either the You, Your) means you - a person who uses Our Services.
  • "Website" means website:
  • "GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Your acceptance of this privacy policy

By accessing or using Our Services, you agree to be bound by the Privacy Policy. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding Our privacy practices with respect to the Services. If you do not agree to all provisions of this Privacy Policy, you may not access or use the Services. Further, you acknowledge that this Privacy Policy is part of Our Terms of Service at and is incorporated therein by reference.

Principles of Personal Data processing

We are committed to protecting the privacy and security of Personal Data entrusted to Us by Users. In order to ensure transparency and compliance with applicable data protection laws and regulations, we adhere to the following principles of personal data processing:

  • Lawfulness, Fairness, and Transparency: We process personal data in a lawful, fair, and transparent manner. We ensure that Users are aware of the purposes for which their personal data is collected, used, and disclosed. We also inform Users about their rights and provide them with clear and easily understandable information about our data processing practices.
  • Purpose Limitation: We collect Personal Data for specified, explicit, and legitimate purposes, and we do not process personal data in a manner that is incompatible with those purposes. We only collect and use personal data to the extent necessary to fulfill the stated purposes and in accordance with the consent obtained, contractual obligations, compliance with legal obligations or legitimate interests pursued by the Company.
  • Data Minimization: We only collect and process Personal Data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. We strive to minimize the amount of Personal Data we collect and retain, ensuring that the data is accurate, up-to-date, and necessary for the intended purposes.
  • Accuracy: We take reasonable steps to ensure the accuracy of Personal Data and keep it up-to-date. We rely on Users to provide accurate and complete information, and we provide mechanisms for them to update or correct their Personal Data when necessary.
  • Storage Limitation: We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. When Personal Data is no longer needed, we securely delete or anonymize it to prevent unauthorized access or use.
  • Integrity and Confidentiality: We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, accidental loss, alteration, or disclosure. We maintain the confidentiality, integrity, and availability of Personal Data through physical, technical, and administrative safeguards.
  • Accountability: We take responsibility for our data processing activities and have implemented measures to ensure compliance with applicable data protection laws. We maintain records of our data processing activities, conduct regular assessments of our privacy practices, and provide training to our employees on privacy and data protection.

It is important to note that these principles guide Our approach to Personal Data processing, and We continuously review and update Our practices to ensure ongoing compliance with evolving legal and regulatory requirements.

Types of collected personal information while using Our Service

We may ask You to provide Us with certain personally identifiable information that can be used to contact, identify You, creating and maintaining your account. Information you may provide includes Your name, email, mobile number, Facebook or Apple username, birth date, place of birth, and time of birth, address and login or account name. If you purchase Our Services or products, you may provide Your credit or debit card information. Company uses third parties to process payments – We do not collect or store credit card information. If you provide Your phone number, We may send a few kinds of transactional text messages directly relating to Your use of Your Services, like confirming Your account and resetting Your password. By providing Your mobile phone number, you expressly consent to receive this type of transactional text messages from us at that number. Third-party data and message fees may apply.

Cookies and information collected automatically from devices

When you access Our Services, We may automatically collect information that is linked to Your computer, phone, or other device, including information related to Your behavior and activity while interacting with us, such as Your IP address, operating system and version, local time zone, date, time, and activity of Your request, device type (e.g. desktop, laptop, tablet, phone, etc.), device manufacturer, screen size, and language preference. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, the Company uses cookies and similar technologies (as SDK) in order to track the interaction of Users with the Website. This section explains the different types of cookies that may be set when the User uses the Website, helping to understand and manage them as he/she wishes. A cookie is a small file that is stored locally at the User's technical device as soon as the Website is visited. Cookies function by saving particular sets of data, such as, for example, the User's language selection. Should the User visit the Website again later, a cookie will transmit this data back. The cookies don't store personal information like the User's name or address. Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that We immediately become aware of your identity. The use of cookies primarily serves the purpose of making Your use of our Website more pleasant for You. Below is information about how the Company uses Users' cookies:

  • Necessary cookies. These cookies are strictly necessary to provide the User with Services.
  • Authentication cookies. These persistent cookies help the Company to identify the User so that the User could log into the Website automatically.
  • Analytics cookies. These cookies help the Company to understand how the Website is being used, and help us customize and improve the Services.
  • Advertising cookies. These cookies are used to make advertising messages more relevant to the User. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the User's interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
  • Social networking cookies. These cookies are used to enable the User to connect the User's account to third party social networks.

Within the scope of the GDPR, the data processed by cookies for the aforementioned purposes is justified in order to protect Our legitimate interests and those of third parties pursuant to Article 6 (1)(f). Most browsers and devices automatically accept cookies. However, You can configure Your browser or device so that no cookies are stored on or a message always appears before a new cookie is created. However, the complete deactivation of cookies can lead to the fact that You cannot use all functions of the Website.

Basis and purposes of the data processing

In general, We use the information We collect to provide you with the best possible Services, and continually improve them over time. We use following legal bases when processing Your Personal Data (each legal basis is followed by respective purposes for the processing of Your Personal Data):

  • Processing necessary for the performance of the contract between You and Us or in order to take steps at your request prior to entering into a contract with Us:
    • To verify Your identity;
    • To provide a personalized experience, and implement the preferences that You request;
    • To send You administrative or account-related information;
    • To enhance security, prevent fraud, monitor and verify identity or service access, combat spam or other malware or security risks;
    • To maintain operation, performance and administration of the Services;
    • To manage User's accounts (e.g. by way of continuous updating of User data);
    • To process Your support requests;
    • For quality control and staff training.
  • Processing necessary for compliance with legal obligations:
    • To monitor and prevent fraud, misuse (e.g. for illegal purposes).
    • To provide information to relevant authorities when explicitly stipulated in applicable law.
  • Processing necessary to protect Our legitimate interests:
    • To analyze and improve quality and the general user experience;
    • To process inquiries from authorities and lawyers in the course of legal prosecution and enforcement of legal claims in the context of legal proceedings;
    • To resolve disputes, collect fees, and troubleshoot problems;
    • To conduct market research, business management and continuing development of the Services;
    • To process statistical data, performance data and market research data;
    • To prevent and investigate potentially prohibited or illegal activities;
    • To enforce our agreements with third parties;
    • For direct marketing and advertising purposes.
  • Processing based on Your consent:
    • For the use of all functions App (e.g. telephone permission to read SMS confirmation, camera to scan barcodes, microphone for commands, etc.);
    • Direct marketing and advertising (e.g. User satisfaction surveys, newsletters, sweepstakes and other advertising communications).

How We share information

Company does not sell Your personal information to third parties, nor do We disclose personal information to third parties for direct marketing purposes. We take Your privacy seriously, and may disclose Personal Data only as follows:

  • To business partners. Business partners are third parties whose services Company uses to operate and improve Our own Services, who supply software applications, provide data storage, customer support, web hosting, account management, authentication and other technologies for the Website or manage marketing and advertising activities on other platforms and web pages. We will only provide these third parties with access to information that is reasonably necessary to perform their work or to comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website. We may also share aggregated or de-identified information, which cannot be used to identify you. We may also request data processing services for processing of personal data in a third country. Providing these services, the data processor shall abide by the present Privacy Policy, relevant legislations in force, and the provisions of the existing contracts of the Company.

The list of authorized business partners is following:

  • Apple Distribution International Ltd. (Hollyhill Industrial Estate, Hollyhill Cork, IRELAND)
  • Amazon Inc. (440 Terry Avenue North, Seattle, WA 98109, USA)
  • Amazon Web Services Emea Société À Responsabilité Limitée (38 Avenue John F. Kennedy, L-1855 Luxembourg)
  • Adapty Tech Inc. (2093 Philadelphia Pike #9181 Claymont, DE 19703, USA)
  • Functional Software, Inc. (45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA).
  • Amplitude, Inc. (201 Third Street, Suite 200, San Francisco, CA 94103, USA)
  • AppsFlyer LTD (14 Maskit St,6th Floor,POB 12371 Herzliya 4673314 Israel)
  • Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland).
  • Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).
  • Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
  • OneSignal, Inc. (2194 Esperanca Avenue, Santa Clara, CA 95054, USA).
  • We may share information about you for legal, safety, and security reasons. We may share information about you if We reasonably believe that disclosing the information is needed to:
    • comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
    • investigate, remedy, or enforce potential Terms of Service violations.
    • protect the rights, property, or safety of us, Our users, or others.
    • detect and resolve any fraud or security concerns.
  • We may share information about you as part of a merger or acquisition. If the Company gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of Our business to another company, We may share Your information with that company before and after the transaction closes.

We store personal information about You on our servers in the EU. However, as part of Our Business partners is outside EEA, Your personal information may be processed by recipients outside of the EEA (namely in the US), which is not subject to an adequacy decision by the European Commission and which does not provide for the same level of data protection as in the EEA. In this event, We will ensure that the recipient of Your personal information offers an adequate level of protection, for instance by entering into Standard Contractual Clauses for the transfer of data as approved by the European Commission (Article 46 GDPR), your explicit consent to such international data transfers or based on the performance of the contract. This way, if We transfer Personal Data collected from Users located within the EU to a third-party acting as a data processor, such third-party processes Your personal information in a manner consistent with the GDPR.

Protecting Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information. If you are 16 or older, but have not reached your jurisdiction's age of majority (such that you are able to enter a contract), you should only use the Service with permission from your parent or guardian. In accordance with California law, minors under the age of eighteen (18) residing in California may remove, or request and obtain the removal of, content and information that they share on the Websites or the App. To remove or to request and obtain the removal of such content and information, the User must email [email protected]. Users should be aware that removing content and information posted by a minor does not ensure complete or comprehensive erasure of content or information posted on Our Services.

Links to third-party Websites

When you use Our Services, you may be directed to other Websites and applications that are beyond Our control. We may also allow third-party Websites or applications to link to the Services. We are not responsible for the privacy practices of any third parties or the content of linked Websites and applications, but We do encourage you to read the applicable privacy policies and terms and conditions of such parties, Websites, and applications. This Privacy Policy only applies to the Services.

How We secure and retain information

We have implemented reasonable technical and organizational precautions to protect the confidentiality, security and integrity of Your personal information from accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access. We cannot guarantee the security of information transmitted to us over the internet. We will retain Your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Your rights

Depending on Your location, You may have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided in this Privacy Policy.

  • You may access, correct, update or request deletion of your personal information by submitting a request at [email protected].
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information by submitting a request at [email protected].
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you or otherwise following the directions in the emails. You can also make choices about your receipt of marketing communications through the subscription settings in your account.
  • If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time by submitting a request at [email protected]. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a supervisory authority about our collection and use of your personal information.

Changes to this privacy policy

We may update or modify this Privacy Policy from time to time and will alert you that changes have been made by indicating on the Privacy Policy the date it was last updated at the top of this Privacy Policy, prominently posting an announcement of the changes on Our Services, or by sending you a written communication using the contact information you provided us prior to the new policy taking effect. Users are bound by any changes to the Privacy Policy if they use Our Website, App, and Services after notice of such changes has been communicated. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with the Company's current practices.

Privacy Notice for California residents

Privacy Notice for California Residents (this "Privacy Notice") supplements the information contained in the Company's Privacy Policy and applies solely to all Users who reside in the State of California. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. All capitalized terms not herein defined will have the meaning set forth in Company's Privacy Policy. In case on any inconsistencies with Company's Privacy Policy, this Privacy Notice shall prevail.


We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). In particular, we have collected the following categories of personal information from our Users within the last twelve (12) months:
A. Identifiers.
Examples: A unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Commercial information.
Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
C. Internet or other similar network activity.
Examples: Browsing history, search history, information on a User's interaction with an App, Website or advertisement.
D. Geolocation data.
Examples: Physical location or movements.
Personal information does not include:
(i) Publicly available information from government records,
(ii) De-identified or aggregated User information,
(iii) Information excluded from the CCPA's scope, like:
i. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
ii. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
(i) Directly from clients or their agents. For example, from information clients provide to Us related to the Services for which they engage Us.
(ii) Directly from You when you provide it to Us. For example, if you share your name and contact information to ask a question about Website or App.
(iii) Indirectly from You. For example, from observing your actions on Website.
(iv) From third parties, for example, our service providers.


We may use or disclose the personal information we collect for one or more of the following purposes:
(i) To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about Website, app or product we will use that personal information to respond to your inquiry.
(ii) To provide, support, personalize and develop Our Services.
(iii) To process Your requests and respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our responses.
(iv) To notify You about changes to Website, App or any products or Services We offer or provide through it.
(v) To notify You about changes to Our policies and/or User agreements.
(vi) To maintain a record of Our dealings with You.
(vii) To understand and analyze the usage trends and preferences of Users, to improve the Website, the App and other products and to develop new features, and functionality.
(viii) To contact You for administrative and information purposes - this may include providing customer service or sending communications, including changes to our terms of use.
(ix) To engage features of third party social networks.
(x) For testing, research, analytics and product development.
(xi) To help maintain the safety, security, and integrity of Website and App, and our databases, other technology assets and business.
(xii) To diagnose or fix technological problems in relation to Website and App.
(xiii) To carry out our obligations and enforce our rights arising from any contracts entered into between You and Us.
(xiv) To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
(xv) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us is among the assets transferred.
(xvi) As described to you when collecting your personal information or as otherwise set forth in the CCPA.


We may disclose Your personal information to a third party for a business purpose. When We disclose personal information for a business purpose, We enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Commercial Information
Category F: Internet or other similar network activity
Category G: Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
(i) Our affiliates.
(ii) Service providers.
(iii) Third parties to whom You or Your agents authorize us to disclose your personal information in connection with products or services we provide to you.
(iv) Law enforcement bodies and courts.
We share Your personal information for the following general purposes:
(i) Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
(ii) Protecting Our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
(iii) Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
In the preceding twelve (12) months, we have not sold any personal information.


The CCPA provides Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights. You have the right to request that We disclose certain information to You about Our collection and use of Your personal information over the past 12 months. Once we receive and confirm your verifiable User request (see Exercising Access, Data Portability, and Deletion Rights Section), We will disclose to You:
(i) The categories of personal information we collected about You.
(ii) The categories of sources for the personal information We collected about You.
(iii) Our business or commercial purpose for collecting that personal information.
(iv) The categories of third parties with whom we share that personal information.
(v) The specific pieces of personal information we collected about You (also called a data portability request).
(vi) If We disclosed Your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that We delete any of Your personal information that We collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable User request (see Exercising Access, Data Portability, and Deletion Rights Section), We will delete (and direct our service providers to delete) Your personal information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) to:
(i) Complete the transaction for which We collected the personal information, Service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You or otherwise perform Our contract with you.
(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(iii) Debug products to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another User to exercise their free speech rights, or exercise another right provided for by law.
(v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
(vii) Enable solely internal uses that are reasonably aligned with User expectations based on Your relationship with Us.
(viii) Comply with a legal obligation.
(ix) Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
To exercise the access, data portability and deletion rights described above, please submit a verifiable User request to Us by emailing us at [email protected]. Only You, or someone legally authorized to act on Your behalf, may make a verifiable User request related to Your personal information. You may also make a verifiable User request on behalf of Your minor child. You may only make a verifiable User request for access or data portability twice within a 12-month period. The verifiable User request must:
(i) Provide sufficient information that allows Us to reasonably verify You are the person about whom we collected personal information or an authorized representative;
(ii) Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with personal information if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. We will only use personal information provided in a verifiable User request to verify the requestor's identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable User request within forty-five (45) days of its receipt. If We require more time (up to 90 days), We will inform You of the reason and extension period in writing. Any disclosures We provide will only cover the 12-month period preceding the verifiable User request's receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to Your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why we made that decision and provide You with a cost estimate before completing Your request.
Personal Information Sales Opt-Out and Opt-In Rights.
If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of Users we actually know are less than 16 years of age. Users who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a variable notice to [email protected]. Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize personal information sales.


We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:
(i) Deny you Services.
(ii) Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties.
(iii) Provide You a different level or quality of Services.
(iv) Suggest that You may receive a different price or rate for Services or a different level or quality of Services.


We reserve the right to amend this Privacy Notice at Our discretion and at any time. When We make changes to this Privacy Notice, we will post the updated Privacy Notice on Website and update the Privacy Notice's effective date. Your continued use of Services following the posting of changes constitutes Your acceptance of such changes.

Contact Us

If you have any questions about this Privacy Policy and Privacy Notice, You can contact us by email: [email protected]

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