Privacy Policy | Gameram

PRIVACY POLICY
LAST UPDATED: April 3, 2025

1. WHO WE ARE

We are Gameram LTD, a legal entity located at Leoforos Ellados 58, office 303, Tamiel Centre, 8021 Paphos, Cyprus (“Gameram” “we”, “us”, “our”). Gameram acts as a data controller. It means we determine the purposes and means of the processing of personal data.

This Privacy Policy sets out how we collect and use your personal data when you: (1)use our mobile and web (available at: https://web.gameram.com/auth) application Gameram (the “Platform”), (2) visit (use) our website located at: https://gameram.com (hereinafter – the “Website”), (3) communicate with us and as otherwise described in this Privacy Policy.

This Privacy Policy should be read alongside, and in addition to our Terms of Use accessible online at https://gameram.com/tou (hereinafter – the “Terms”). In case of any contradictions between this Privacy Policy and the Terms in connection to the personal data processing, this Privacy Policy will prevail.

2. THIS PRIVACY POLICY

By making available the Platform we, acting reasonably and in good faith, believe that you:

a) have all necessary rights to register on and use the Platform;

b) provide true information about yourself to the extent necessary for use of the Platform;

c) understand that by the posting your personal data, if there is such technical possibility in the Platform and where it is accessible by other users of the Platform, you have manifestly made this information public, and this information may become available to other Platform users and internet users, be copied and disseminated by them;

d) are aware of and accept this Privacy Policy.

We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

3. HOW DO WE COLLECT PERSONAL DATA?

We process personal data in the following ways:

a) when you provide us with personal data.

You provide us with your personal data in order to realize the purposes of the processing. For example, in order to create an account on the Platform, we need the personal data we receive from you.

b) when personal data is collected automatically.

There are tools that allow us to collect technical personal data about you when you use Platform. For certain purposes (e.g. to enable you to technically use the Platform, to track and fix bugs on the Platform), we automatically collect your personal data where there is a legal basis to do so.

4. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW DO WE PROCESS IT

We process your personal data only when it is necessary to achieve the purpose of the personal data processing and only to the extent necessary to achieve the purpose of the processing. Furthermore, we keep your personal data for a limited period of time and once the processing period has expired, we delete all existing copies of your personal data.

Below we have provided you with a full description of the data processing purposes of the users of the Platform, what personal data we process, legal basis of data processing and information about the retention period.

Registration an Account on the Platform

Processed Personal Data

E-mail or Apple account (Apple_id, e-mail) or Google account (Google_id, e-mail) (depending on the registration method),
UserName (in this box you can put any Name(s) including official one),
Date of birth,
Profile picture (optional),
Registration date (created by the system),
Main language,
UserID (the unique ID is created in the system on registration)
Phone number (only for Accounts created before 19.10.2021).

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use an Account and 3 years after.

Filling in, changing the profile on the Platform to use the full functionality of the Platform (searching for like-minded people based on common interests, etc.)

Processed Personal Data

Name,
Phone number,
Age and gender,
Language preferences,
Gaming platform (mobile, pc, console),
List of games, player ID in certain game and/ or nickname in certain game (player ID and nickname are optional),
Other personal data which you provide in the free text field.

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use an Account and 3 years after.

Providing functionality of the Platform to you (posting information in any Platform forums and/or chat rooms, etc.)

Processed Personal Data

List of games, player ID in certain game and/ or nickname in certain game,
Tribe participation info, list (names) of tribe where you participate,
Media files on your device (at the moment of access the files),
Other personal data personal data which you provide in personal messages, tribe messages, comments, posts).

If you have given us access to your microphone (for audio calls, or record of audio messages) or your photo gallery (for posting content on the Platform) in your device settings, we will have access to your microphone and media files from your device for as long as you use the Platform or until you change those settings on your device.

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use an Account and 3 years after.

Customize content that is age-appropriate for your interests

Processed Personal Data

Date of birth
Legal basis for the processing
Legitimate interest
our interest in improving the quality of our Platform and making user experience more relevant to their interests;
your interest in using an user-friendly Platform that is relevant to your interests.

Data retention period

As long as you use an Account and 3 years after.

Maintaining the correct operation of the Platform, tracking errors (data needed for the Platform to function properly)

Processed Personal Data

To fulfill this purpose, we engage third parties who collect your personal data.

Data kept at FireBase (Google) and Signoz: information about the device, including information about the device manufacture, device udid, device name, device model, device’s OS, device time zone, languages of device, device OS version, device region, network type, screen resolution;

Data kept at Gameram: language of device, device region, device OS, device model, device name, device id, device time zone, User IP.

Legal basis for the processing

Legitimate interest:

your interest is in using our Platform free from any bugs;
our interest is in keep the Platform up and running.

Data retention period

Depending on the type of personal data but no longer than 3 years from the last time you logged into your Account.

Sending technical notifications, updates, security alerts, support messages, and administrative messages

Processed Personal Data

E-mail,
FCM-token (it is a certain device identifier which is used for PUSH notices sending on your device), is connected with UserID,
Phone number.

Legal basis for the processing

Legitimate interest:

your interest is in using our Platform free from any bugs;
our interest is in keep the Platform up and running.

Data retention period

As long as you use an Account and 3 years after.

Analyzing Platform usage, manage and administer the Platform and improving its features, improve the content of our Platform, optimizing your user experience

Processed Personal Data

User media content,
User behaviour data (it’s information relating to use of the Platform (Platform actions and achievements, badges), the time and date of use, the type of device, the features the you use, ect.),
Backend logs (it’s a short text records showing the history of what happened in the system, including business operations (registration, login, leaving a comment, creating a post, etc),
API requests made by you.

Legal basis for the processing

Legitimate interest

your interest our Platform is the best fit for your needs;
our interest to understand our audience in order to attract new visitors to our Platform.

Data retention period

Logs are kept for 15 days; other personal data is used for 2 weeks.

Providing the user with the ads, including personalized, via third-party advertising platforms

Processed Personal Data

E-mail,
Device data (device name, device model and operating system),
Username,
userID,
OS version,
Application version at your device,
Application language at your device,
Information about other registered accounts and e-mails,
Screenshots and videos of the screen (showing the problem),
Other data you provide us in the correspondence.

Legal basis for the processing

Legitimate interest

your interest in providing you with an answer to a question / solution to a problem;
our interest in improving the quality of Platform provided.

Data retention period

Until the matter you have requested is resolved, but usually not more than 3 months.

Providing the functionality of the paid version of the Platform (“Gameram Plus”)

Processed Personal Data

Purchase history from Apple and Google

Please note that we don’t process or have access to your personal data related to making payments (bank card details, payment card expiration date, the security code, others). Your personal data related to making a payment is processed by the third-party payment providers we engage to process and make your payment.

And such processing is governed by their terms of service and privacy policies. We strongly recommend that you review the terms of service and privacy policies of these third parties to learn more about how they handle your personal data.

Legal basis for the processing

Contract (Terms)

Data retention period

As long as you use an Account and some period of time after due to the legal requirements.

Using the “Share with Friends” feature to share the user's

gaming experience with friends (contacts)

Processed Personal Data

Mobile number

Legal basis for the processing

Legitimate interest

our interest promoting our Platform and improving the quality of the Platform;
your interest in inviting your friends, socializing and sharing the Platform.

Data retention period

5 years from the date of requesting the presentation.

Conducting market research about your experience using our Platform

Processed Personal Data

We do not directly collect personal data that can directly identify you, but from time to time the questionnaire may ask for information related to you. We anonymize this information and use it for analytical and statistical purposes.

Legal basis for the processing

Legitimate interest

our interest in analyzing user experience and improving the quality of our Platform;
your interest in using an user-friendly Platform that is relevant to users’ interests.

Data retention period

3 years from the date of market research.

Your personal data may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims. We will not delete personal data if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable law.

Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this personal data on the Platform.

5. DATA SHARING

Your username and other information that you provide or post while using the Platform can be available to all users of the Platform. We take technical and organizational measures to ensure that your personal data is safe. Please note, that by posting your personal data in publicly accessible areas (resources accessible by other users of the Platform), you have manifestly made this information public, and it may become available to other users of the Platform and Internet users and be copied and/ or disseminated by such users. Please keep in mind that once other users have gained access to or copied your data, neither you nor we are able to delete or remove such data from possession of those other users.

We may share your personal data with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to our affiliated entities, as well as our partners, in order to provide the Platform to you, to administer the Platform, for example, if you choose to share your data across other social media platforms, or to personalize, adjust and improve our Platform or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal data to third parties.

The transfer of personal data with the third parties (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure manner and if required under applicable law in application of an agreement between us and each recipient. We will make best of us to ensure that each recipient knows the directive principles of personal data protection and submit to them in application of the law and/or of a particular contract.

In case we share your data with selected third parties, including our third party contractors and application developers, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use the services or applications they offer. The developers use the information provided to them in order to provide you with additional Platform, including technical support, if applicable. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.

We share your personal data in such cases:

(i) to our affiliates or in case of general conduct of business.

We may share your personal data with our affiliates and keep some of your personal data in our business records for the accounting and compliance purposes. As such, we may also disclose your personal data to a third party if we decide to transfer a business to that third party, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal data may be transferred to our successor or assignee.

(ii) to tax authorities.

We reserve the right to disclose your personal data to tax authorities in case it is necessary because of your participation in public tournaments or promotional activities.

(iii) to third parties as required by law.

We reserve the right to disclose your personal data as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defense of our rights and interests. We also reserve the right to disclose your personal data if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

(iv) to accomplish the purposes set forth above.

In an effort to provide an exceptional experience, we work closely with a select group of trusted partners and service providers. These partners play an important role in supporting various aspects of our business, thereby enhancing the quality of the Website and Platform. When selecting the partners with whom we share your personal data, we take a cautious approach, ensuring that we only work with companies that take strict measures to protect personal data from unauthorized access, disclosure, or misuse.

Although we carefully screen our partners, it is important to recognize that we cannot guarantee absolute compliance with data protection legislation in all cases. We encourage you to review the privacy policies of these third parties to gain an understanding of their practices in processing your personal data.

a. Third parties that help us to show the ads:

Digital Sail FZE (DIGITAL SAIL CYPRUS LTD) (EU)

Applovin (AppLovin Corporation) (USA)

AppLovin Corporation is an active participant of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation.

b. Third parties that help us in analytical purposes, a/b tests handling, error tracking:

Google Firebase, Google Analytics and Google Bigquery (Google Cloud EMEA Limited) (EU)

Google Firebase Privacy Policy: https://firebase.google.com/support/privacy

Google’s Privacy Policy: https://policies.google.com/privacy

c. Storage server providers

AWS (Amazon Web Services, Inc.) (USA)

Privacy Notice: https://aws.amazon.com/privacy/?nc1=h_ls

Data Privacy Center: https://aws.amazon.com/compliance/data-privacy/

Amazon Web Services, Inc. is an active participant of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation.

SigNoz (SigNoz, Inc.) (USA)

ClickHouse (ClickHouse, Inc.) (USA)

ClickHouse, Inc. is an active participant of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation.

Google Firebase (Google LLC) (USA)

Google LLC is an active participant of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation.

d. Other third-parties:

GetStream that provides chat functionality to integrate in our system (P2P chats, group chats, audio calls, audio messages, AI moderation of the chats) (Stream.io, Inc.) (USA)

Stream.io, Inc. is an active participant of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation.

Signoz that tracks bugs and performance (technical monitoring) (SigNoz, Inc.) (USA)

Ansvery that provides the support moderation (UAB “Ansvery”) (EU)

Browserstack is a cloud service for testing mobile/web applications and websites on different browsers, platforms, and devices (BrowserStack Inc.) (USA)

SurveyMonkey is an application for survey (SurveyMonkey Europe UC) (EU)

Privacy Notice: https://www.surveymonkey.com/mp/legal/privacy/

Please note that we may occasionally engage other third-party service providers. The list of such contractors could be subject to changes, but each time before transferring your personal data to new counterparties, we:

assess the level of adequacy of personal data protection by such third-party service providers;
enter into a Data Processing Addendum with such third-party service providers.

6. ADVERTISEMENT

Our Platform may contain software components operated by our selected advertising partners, which may collect and share some of your information with such partners in the course of normal use of the Platform or, for example, after you interact with their advertisements provided within the Platform. In such a case the processing of your information will be governed by privacy terms of such partners which are listed in section 5 of this Privacy Policy. When you begin using the Platform, we seek your consent to such use as set out above.

Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender, location (country, city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.

An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

7. PRIVACY SETTINGS

The Platform or Website may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party’s privacy policies which will govern your data privacy rights.

In case you intend to connect your Google account to the Platform using Google API, you may review and, if necessary, adjust your Google privacy settings before linking or connecting them to our Website or Platform. You can find more information on Google’s privacy at https://policies.google.com/.

We bear no liability for the actions of third parties which, as the result of your use of the internet or the Platform, obtain access to your information in accordance with the confidentiality level selected by you.

We bear no liability for the consequences of use of the information which, due to the Platform nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Platform.

8. INTERNATIONAL TRANSFERS

We may transfer and maintain on our servers or databases some of your personal data outside the European Economic Area (EEA) to the USA.

Most of the companies to which we transfer personal data are members of the EU-US Data Privacy Framework and ensures an adequate level of protection as required under EU data protection legislation. Otherwise, we endeavor to ensure that appropriate safeguards are in place to ensure the secure transfer of personal data into the USA.

9. RETENTION PERIODS

We will retain your personal data for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal data during the term that is required and/or permissible under applicable/relevant law.

The specific data retention periods for each purpose are specified in the section “Personal data we collect about you and how do we process it”. But please note that under certain circumstances, we may be required to retain your personal data for a longer period of time in accordance with applicable law or regulatory requirements. This may include but is not limited to, situations involving legal proceedings, investigations, or government inquiries. We will only retain your personal data for as long as necessary to comply with these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.

You may delete your personal data by removing the data from your Account; alternatively, you can delete your Account. If you want to delete the Account, see our instructions via link https://www.gameram.com/guides/deletion.

You may request to remove your Account and data on our Platform by contacting the Platform support (see section 11 for details).

We may remove your Account, personal data or the information you post as provided by the Terms.

10. YOUR RIGHTS

As a data subject, you have the following rights in relation to your personal data under EU legislation:

(a) Right to access your personal data.

You can request access to the personal data we hold about you

You can exercise this right in two ways (depending on the way you provide us personal data):

1. by yourself by following these steps:

open the Platform;
go to the “Profile” section of the Platform;
open the settings section in the upper right corner;
click on “contact support” and write that you want to exercise your right of access.

2. by contacting us at e-mail indicated in the Privacy Policy.

Upon receiving your request, we will provide you with a copy of the personal data we process in the form in which you have requested the provision of this information. Please note that in some cases we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal the decision.

(b) Right to rectify your personal data.

You can request that we update or correct your personal data, if the data is inaccurate or incomplete.

You can exercise this right in two ways (depending on the way you provide us personal data):

1. by yourself by following these steps:

log in to your Account on the Platform;
go to the “Profile” section of the Platform;
locate personal data you wish to correct and edit it;
save the changes to update your data instantly.

2. by contacting us at e-mail indicated in the Privacy Policy.

Upon receiving your request for rectification, we will review the accuracy and completeness of your personal data and make any necessary corrections or updates.

You can request the restriction of processing of your personal data in certain circumstances, such as when the processing is unlawful, when we no longer need the personal data, or when you have objected to the processing.

You can exercise this right by contacting us at the e-mail indicated in the Privacy Policy.

Upon receiving your restriction to processing we will not process your personal data (except for storage) unless it is based on consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

(d) Right to request that your personal data is erased (or, as we all know, the “right to be forgotten”):

You can request the deletion or destruction of your personal data in certain circumstances, such as:

the personal data are no longer required in relation to the purposes for which it was gathered or processed in another way;
you withdraw your consent concerning processing subject to consent;
you objects to the processing; etc.

You can exercise this right by contacting us at the e-mail indicated in the Privacy Policy or you can delete your Account on your own by following instruction via link https://www.gameram.com/guides/deletion.

Upon receiving your request for erasure, we will assess whether the conditions for erasure are met and, if so, promptly delete or anonymize your personal data from our systems and notify any third parties to whom the data have been disclosed.

(e) Right to object to processing of your personal data.

This right enables you to object to the processing of your personal data in certain circumstances, such as where the processing is based on legitimate interests or for direct marketing purposes.

You can exercise this right by contacting us at the e-mail indicated in the Privacy Policy.

Upon receiving your objection to processing, we will assess the validity of your objection and, if valid, cease processing your personal data for the purposes to which you have objected.

(f) Right to data portability.

You can request us a copy of your personal data in a structured, commonly used, and machine-readable format if it is technically possible to do so and to transmit those data to another controller.

You can exercise this right by contacting us at the e-mail indicated in the Privacy Policy.

Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.

(g) Right to lodge a complaint with a supervisory authority.

If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

Since we are registered under the law of Cyprus, the personal data authority overseeing us regarding the personal data processing is Commissioner for Personal Data Protection. You always have the right to make a data protection related complaint at any time to a supervisory authority. You may also contact your local data protection authority. A list of local data protection authorities is available here.

(h) For processing based upon your consent, the right withdraw that consent at any time.

You have the right to withdraw your consent to the processing of your personal data at any time. This means that if we are processing your personal data based on your consent, you have the right to revoke that consent.

You can exercise this right by contacting us at the e-mail indicated in the Privacy Policy.

Upon receiving your request to withdraw consent if we do not have any other legal basis for processing your personal data, we will stop processing it.

Please note that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us using the provided contact information.

We will review your request as soon as possible, but not more than within one (1) month. Please keep in mind that this period may be extended for an additional two (2) months, if necessary, based on the complexity and number of your requests. In that case, we will tell you about the extension within one (1) month of receipt of your request and explain the reasons for the delay.

In case you provided the Platform with the access to your Google account (for example if you registered on the Platform using Google account) you can revoke that the access of the Platform to your Google account via the Google security settings page at https://security.google.com/settings/security/permissions.

11. AUTOMATED DECISION-MAKING

We do not engage in any automated decision-making or profiling using your personal data. All decisions that may significantly affect you are made with human involvement. We believe in preserving human judgement in matters that concern our customers.

12. SECURITY MEASURES

We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

Access to the Platform is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

If you forget your login details, you can request us to send you an e-mail, which will contain a restoration code.

To reduce the probability of third parties gaining unauthorized access, if you login to your Account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your Account. You will then need to contact Platform support and provide certain additional information to verify your credentials and gain access to your Account.

13. CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal data to anyone under the age of 16 (or the age of 13 (in the USA) or knowingly allow such persons to use our Website or the Platform. If you are under the age of 16 (or the age of 13 in the USA), please do not provide any personal data to us. If we learn that we have collected personal data about a child under the age of 16 (or the age of 13 in the USA), we will delete that personal data as soon as possible. If you believe that we might have any personal data from or about a child under the age of 16 (or the age of 13 in the USA), please contact us at the e-mail indicated in this Privacy Policy.

14. CHANGES TO THIS POLICY

From time to time, we may change and/or update this Privacy Policy due to the implementation of new technologies, laws’ requirements or for other purposes. If this Privacy Policy changes in any way, we will post an updated version on this page and, where appropriate, notify you. We recommend you regularly review this page to ensure that you are always aware of our data protection practices and any changes to such. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your personal data, we will request your consent or your renewed consent (in case it was obtained previously).

15. CONTACT US

If you have any questions, please send your inquiries to service support at support@gameram.com or in writing to Leoforos Ellados 58, office 303, Tamiel Centre, 8020 Paphos, Cyprus (Gameram LTD). So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you as soon as possible, but usually within 30 days from receipt of request.

All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

If you have any questions or concerns about your privacy, you may contact our data protection officer by writing at dpo@gameram.com or Leoforos Ellados 58, Tamiel Centre, Office 303, 8020, Paphos, Cyprus (Gameram LTD).

PRIVACY POLICY LAST UPDATED: April 3, 2025

PRIVACY POLICY
LAST UPDATED: April 3, 2025