Riverano Ltd. - Privacy policy

Last modified: 09/05/2024.

Introduction

Riverano Ltd. ( “Company”, “we”, “our” or “us”) develops and operates sweepstakes games for mobile environments, ("Apps"), as well as our website www.sweepspot.com, its subdomains and its related features (“Website”, and together with the Apps – the “Services”).

Company is dedicated to protecting your privacy rights and making our practices regarding your Personal Information more transparent and fair. This Privacy Policy b( “Policy”) is designed to help you understand how we collect, store, use and share your Personal Information. This Policy applies whenever you visit our Website, install or interact with our Apps, or otherwise access or use any of our Services.

Specifically, this Policy describes –

1. What types of data we collect?
2. Tracking Technologies
3. Why we collect your Personal Information?
4. With whom we share your data?
5. Marketing and advertising
6. Your rights
7. Security
8. Minors
9. Updates to this Policy
10. Contact us

You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the full range or with the best experience of using our Services.

This Policy is integrated into and forms part of the Company's Terms of Use which are currently available at: www.sweepspot.com

What types of data we collect?

We collect Personal Information about you, meaning any information which potentially allows your identification with reasonable means (for example, email address or name, collectively " Personal Information"). This section sets out how and when we collect and process Personal Data about you.
1. Account Information. If you choose to register an account with our Services, we collect your full name, email address, password, phone number, birthdate and user nickname, as well as voluntary information, such as your profile picture. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access. In addition, we may collect certain information as required under various gambling regulations, as well as Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements, such as your source of funds.
2. Payment Information. When you decide to deposit money in our Apps, you will be required to provide us with your billing information. The information you will need to submit depends on which billing method you choose, including your bank account, ACH information, and other payment account information. For example, if you pay with a credit card, we will collect your card information.
3. Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include gameplay recordings, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), as well as other information which relates to your activity in the Services.
4. Communication Information. When you send us an email or contact us via the support in our Apps or Website, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
5. Player Behaviour and Game Play Information. We also process your information on sweepstakes entries, participation history, prize claim, session duration, and behavioural monitoring, session duration.

Tracking Technologies


When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (" Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services performance, perform analytics, customize your experience, and offer you, for example, tailored content and advertisements that better correspond with your interests.

Tracking Technologies may be placed by us or by third parties such as analytics providers, who run content on our Services.

We use the following categories of Tracking Technologies:
1. 
   
   (a) Strictly Necessary Tracking Technologies - these Tracking Technologies are automatically placed when you access our Services and are essential to enable you to navigate around and use the features of our Services.
   
   (b) Functionality Tracking Technologies - these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
   
   (c) Performance Tracking Technologies - these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2. (d) Marketing Tracking Technologies - these Tracking Technologies are used to deliver tailored offers to you, based on your derived interests, as well as to perform email marketing campaigns.. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.


You can manage your Tracking Technology preferences through your device or browser settings. Disabling some cookies may affect the functionality of the Services.



Why we collect your Personal Information?





This section explains for what purposes we use your Personal Information.




Purpose and Scope of Collected Data
Provision of our Services; support.We use your Personal Information, such as your name and email address, for consumer services purposes. This includes, for example, responding to your inquiries.
Payments. We collect from our third-party payment processors certain information about your payment instruments for the purpose of connecting your payment instrument to your account on our Services, and sending you statements, invoices, and payment reminders.
Improve our Services. We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services.
Marketing. We may use Tracking Technologies (which may collect Personal Information) in order to provide you with personalized marketing when you visit our Services, including personalized and non-personalized messaging, as part of your current interaction with us or collect your Personal Information to send you direct marketing communications (e.g., email).
Integrity. We may process certain information about you and your use usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.
Compliance with applicable laws. We process your Personal Information in order to comply with our legal obligation under applicable laws, including your location data.


Providing users with a fair, balanced, and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity. When you create an account, play our games, or otherwise interact with our Services, we may use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyse data about the game binary or your computer to detect cheating and may be provided by us or by third party service providers.



With whom we share your data?


We do not sell or share your Personal Information with third parties for cross-context behavioural advertising. However, note that we may disclose your Personal Information described below:
(a) Affiliated companies: We may disclose Personal Information internally within our affiliated companies and subsidiaries, for the purposes described in this Policy.

(b) Payment processors: We disclose your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Information so that they may perform these tasks on our behalf.

(c) Service providers: Our service providers work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the services and cloud storage vendors.

(d) Third Party Integrations: The Services allow you to integrate with certain third party services, such as in order to connect your Facebook or Apple account to our Apps or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third-party services

(e) Compliance with laws and law enforcement entities: We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We may also be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

(f) Auditors and advisers: We may disclose your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.

(g) Mergers and acquisitions: We will transfer, sell or otherwise share your data in case of entering into a business transaction such as merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

Marketing and advertising


We may use your Personal Information ourselves or by using our third-party subcontractors for the purpose of providing you with in-app promotional materials concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or (ii) Company's business partners and affiliates (collectively, “Marketing Affiliates”), which we believe may interest you.

These communications may be delivered through various channels, such as email, in-app notifications. We may also send you SMS upon obtaining you prior explicit consent.

​​You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by following the unsubscribe instructions provided in the message or by contacting us at [email protected]

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you in-app service-related updates and notifications.




Your rights


Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.
1. Rights of access to your Personal Information:
   You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed and access your stored Personal Information, together with supplementary information.
2. Right of data portability:
   You have the right to request us to move, copy and transfer your Personal Information easily from one IT environment to another, in a safe and secure way, without affecting its usability.
3. Right of rectification:
   You have the right to request rectification of your Personal Information in our control in the event that you believe the Personal Information held by Company is inaccurate, incomplete or outdated.
4. Right of deletion/erasure:
   You have the right to request us to erase or delete Personal Information held about you at any time.
5. Right to limit use and disclosure of your sensitive Personal Information:
   You have the right to request to limit the collection of your sensitive Personal Information, to that use which is necessary to perform our Services.
6. Right to opt-out of the sale or share of Personal Information:
   In the event that we sell or share your Personal Information for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Information. After you opt-out, we may continue disclosing some Personal Information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
   
   Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
   
   We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
7. Authorized agent
   (a) You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:
   i. The authorized agent is a natural person or a business entity; and
   ii. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
   
   (b) The request must:
   i. i. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. 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; and
   ii. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
   (c) We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
   
   (d) Making a verifiable consumer request does not require you to create an account with us.



Security

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Information you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.



Minors

We do not knowingly collect or solicit Personal Information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event we learn that we have collected Personal Information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.



Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Revised” heading). For information on how we may amend this Policy, please see Section 2 of the Terms of Use.



Contact Us

If you have any further questions, please contact us by email at: [email protected]