Privacy Policy

Privacy Notice

Last Updated: May, 2024

Prior versions of this Privacy Notice can be found at https://app.gitbook.com/o/uhUPxZIBNFyQHh106vfM/s/5yCzf5Hi5CkTzDlTaBKO/~/changes/16/important-information/privacy-policy/archive

Introduction

OwnPlay Inc. ("Ownplay", "we", "our" or "us") operates the website: http://cityversetycoon.com, its subdomains, and its related features ("Website", collectively – the "Services"). "You" means any adult user of the Website and/or Services.

This Privacy Notice ("Notice") was designed to help you understand the information we collect, store, use, and share, as well as your ability to control certain uses of the collected information. This Notice applies whenever you visit or interact with our Services, is integrated into and forms a part of Ownplay's Terms of Use and is incorporated therewith by reference. Please note that parts of this Notice may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

If you are an individual located in the European Union ("EU Individual"), some additional terms and rights may apply to you, as detailed herein. Our designated representative in the EU and the United Kingdom ("UK"), for privacy and data protections matters pursuant to applicable law, is the Prighter Group ("Prighter"). Prighter provides a way to exercise your privacy-related rights, as further detailed herein (e.g. requests to access or erase Personal Data). You may contact us via our representative, Prighter, or otherwise exercise your EU/UK data subject rights at https://prighter.com/q/14862971837. Alternatively, you may contact us directly as stated in section ‎13 below. Ownplay Inc. is the data controller in respect of the processing activities outlined in this Notice. Our registered office is 9109 TOPRIDGE DR, Austin TEXAS 78750.

Table of Contents

1. OUR ROLE; WHAT TYPES OF DATA WE COLLECT?

2. HOW WE COLLECT DATA?

3. TRACKING TECHNOLOGIES

4. WITH WHOM WE SHARE YOUR DATA?

5. YOUR RIGHTS

6. TRANSFER OF PERSONAL DATA

7. SECURITY

8. THIRD PARTY SERVICES

9. MINORS

10. RETENTION

11. UPDATES TO THIS NOTICE

12. GOVERNING LAW

13. CONTACT US

1. OUR ROLE; WHAT TYPES OF DATA WE COLLECT?

Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a "controller") and a party that processes personal data solely on the controller's behalf and according to the controller's instructions (called a "processor"). We are the controller in respect of the processing described in this Privacy Notice. We collect personal data from you, meaning any information which potentially allows your identification directly or indirectly, including unique identifiers like IP addresses or cookie IDs. This section sets out how and when we collect and process personal data about you.

(a) Account Information. If you choose to register an account with our Services, you will be asked to provide your full name, email address, phone number and username. We may also ask you to connect your Digital Wallet. If you choose to log in, access or otherwise connect to the Services through a social networking service or a single sign on service (such as Facebook, Twitter, Instagram, etc.), we 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. For the purpose of this Notice a Digital Wallet means an electronic wallet which allows the performance of transactions registered over the blockchain

How we use this information: We use your registration information to allow you to access to our Services, save your preferences, protect the security of our Services, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our Services. We also use your contact details to send you informational newsletters about our products and Services. In addition, we may use your registration information to send you promotional materials relating to our products and Services. For more information about our marketing activities and how you can control your preferences, see the section on Marketing and Advertising below.

Legal basis: When we process your registration data to provide you with our Services, we do so to perform a contract with you, in this case our Terms of Use. When we process your registration data to maintain our Services, including to prevent fraud, protect the security of and/or address issues with our Services, we do so on the basis of our legitimate interest to maintain our assets. When we use your contact details to send you newsletters/promotional materials, we do so based on our legitimate interest to market our products and services.

(b) Activity and System Data (Cookies). When you visit our Website or use our Services, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you've visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Tracking Technologies section below.

How we use this information: We mainly use this data to generate analytics data about the use of our Website so we can maintain and improve the Website and develop new products or services. We also use statistical data to prevent fraud and protect the security of our Website.

Legal basis: We process this data based our legitimate interests to develop and improve our products and Services, and to prevent fraud. When we collect your activity data to advertise to you, we do so on the basis of our legitimate interest to market our own products and services.

(c) Geolocation Information. If you consent, we collect your (geo)location when you use our Services.

How we use this information: We use your location to provide you with location-based services for analytics purposes, such as user matching, connecting users to the app.

Legal basis: We process your location based on your consent. You may withdraw your consent at any point by changing your device settings.

(d) Communication Information. When you send us an email or contact us via the support in our Services, we collect the personal data you provide us. This includes your name, email address and any other information you choose to provide.

How we use this information: To respond to your message and to provide you with informational newsletters about our products and services, and provide you with promotional materials we think may be of interest to you.

Legal basis: We process this personal data based on the performance of a contract with you. Processing your personal data to share our newsletters/promotional materials with you is based on our legitimate interest to promote our products and services.

(e) Payment Information. We collect from our third party payment processors certain information about your payment instruments.

How we use this information: For the purposes of filling order and transaction, connecting your payment method to your account on the Services, billing, and sending invoices.

Legal basis: We process this data based on the performance of our contractual obligations and our legitimate interests. Our legitimate interests in this case are provision of our Services, and compliance with legal obligations we are subject to.

2. HOW WE COLLECT DATA?

We may collect the data directly from you when you provide it to us, automatically as you navigate through the Website (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies), and from third parties, for example, our business partners.

3. TRACKING TECHNOLOGIES

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behavior, 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.

(a) What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

i. Strictly Necessary Tracking Technologies. These Tracking Technologies are automatically placed on your computer or device when you access our Services or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;

ii. Tracking and Advertising Tracking Technologies. These Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers, publishers and ad networks. Publishers, advertisers, and third party ad networks also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy /cookie policies and principles, which we do not control;

iii. 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; and

iv. 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).

(b) Third Party Cookies

We store Tracking Technologies on your device when you visit or access our Services, these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services – these are called "Third Party Tracking Technologies". A list of all third party cookies can be found in our cookies policy.

(c) How to Adjust Your Preferences

Both types of Tracking Technologies can be stored either for the duration of your visit on our Services or for repeat visits.

You can manage and control your Tracking Technologies preferences by:

· Accessing our privacy policy setting screen from the game menu

· changing your browser settings to send a "Do-Not-Track" signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.

Below is a list of useful links that can provide you with more information on how to manage your cookies:

· Google Chrome

· Mozilla Firefox

· Safari (Desktop)

· Safari (Mobile)

· Opera

· Android Browser

· Microsoft Edge

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

· The Interactive Advertising Bureau (US)

· The Interactive Advertising Bureau (EU)

· European Interactive Digital Advertising Alliance (EU)

4. WITH WHOM WE SHARE YOUR DATA?

(a) Service Providers. Our service providers work on our behalf and need access to certain Personal Data in order to provide their services to us. These companies include, but are not limited to, hosting services, analytics services, identity verification providers, etc.

(b) Third Party Advertisers. When you click on an ad, whether or not it's on our Website, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify your device by using certain technologies, like cookies. We share personal data with advertisers who collect data through our site with your consent. Advertisers are able to combine the personal data they collect independently with personal data we allow them to collect through our site.

(c) Third Party Integrations. The Services allow you to integrate with certain third party' services, in order to connect your third party account to our Services. In which case you will be bound by the terms and conditions and privacy notices of said third parties. Please make sure that you read and accept them in advance.

(d) Law Enforcement Related Disclosure. We disclose your personal data to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it 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 consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose your personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

(e) Auditors and Advisers. We share your personal data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputed etc.

(f) Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.

Category of Personal Data	Personal Data	Categories of Third Parties
Identifiers	A real name, alias, postal address, internet protocol address, email address, account name, social security number, insurance policy number, driver’s license number, passport number, state identification card number, signature, bank account number, telephone number, credit card number and any other unique personal identifier including online identifier.	a/c/d/e
Commercial data	Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.	a/b/d
Internet or other electronic network activity data	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	a/b/d
Geolocation data	Physical location or movements, including the location of your device location or movement.	a/b/d
Inferences drawn from other personal data	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	a/d
Sensitive personal data (under the relevant applicable laws)	Social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, contents of a mail, email, and text messages unless the business is the intended recipient of the communication, genetic data, and biometric data.	a/d/e

In the 12 preceding months, we have collected personal data from the following categories of sources:

(a) Consumer directly;

(b) Advertising networks;

(c) Internet service providers;

(d) Data analytics providers;

(e) Operating systems;

(f) Social Networks.

5. YOUR RIGHTS

Depending on the jurisdiction in which you reside, you have certain rights under relevant applicable laws regarding the collection and processing of your personal data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise your rights. We may ask for reasonable evidence to verify your identity before we can comply with any request.

(a) Rights of Access. You may have the right to know to what personal data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.

(b) Right to Correct. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated personal data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.

(c) Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.

(d) Right of Deletion ("Right to Be Forgotten"). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.

(e) Right to Restrict Processing. If you are located in the EU, you may have the right to request that we cease to conduct certain personal data processes. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.

(f) Withdrawal of Consent. To the extent we process personal data on the basis of your consent, you have the right to withdraw your given consent, however, this won't affect processing we have done from before you withdrew your consent.

(g) Right to Opt-Out of the Sale or share of personal data. In the event that we sell or share your personal data for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your personal data. After you opt-out, we may continue sharing some personal data with our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services is working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

(h) Right to Non-Discrimination. You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

(i) Right to Lodge a Complaint with Your Local Data Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

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. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal data or an authorized agent. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data 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 data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

6. TRANSFER OF PERSONAL DATA

We operate globally, thus any information that we collect, disclose or share, including your personal data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area and United States, for the purposes detailed in this Notice. Furthermore, some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.

If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area ("EEA"), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:

(a) When we transfer your personal data to Israel, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.

(b) Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.

7. SECURITY

The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. The measures we take include:

(a) Technical Measures. Our data is stored in Google Data Centres, thereby using the electronic safeguards of Google.

(b) Access Control. We limit access to your personal data only to authorized personnel who have a need to know, including operators and account managers, customer support staff, and certain software developers. We review these permissions regularly and revoke an employee's access immediately after his/her termination.

(c) Personnel. We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.

(d) Database Backup. Our databases are backed up using Google's resources.

8. THIRD PARTY SERVICES

You may have access to third party services through our Services. Please note that all use of third party services is at your own risk and subject to such third party's terms and privacy policies. We do not take any responsibility for the performance of other services.

9. MINORS

We do not knowingly sell or share personal information of users under the age of 16. We do not knowingly collect or solicit personal data from Minors (as determined under the applicable laws where the individual resides; "Minors"). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. In the event that we have collected personal data from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, then please contact us immediately through the contact details available below.

10. RETENTION

(a) We retain your personal data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

(b) When deciding how long to store personal data, we consider the amount, nature, sensitivity, and type of information that is collected, the potential risk of harm from unauthorized access, and the purpose for which it is collected, as well as applicable legal requirements.

(c) Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business's retention policy.

(d) In some circumstances, we may store your personal data even after we're finished using it if required to do so by law (e.g. to fulfill tax or audit requirements), or to keep accurate records of our interactions in case there is a prospect of litigation relating to your personal data. In such cases, we will maintain the same security measures as described above.

(e) Please contact us if you would like details about the retention periods for each type of personal data we process.

11. UPDATES TO THIS NOTICE

We may update this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Notice.

12. GOVERNING LAW

This Notice, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its conflict of law principles. All such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

13. CONTACT US

If you have any further questions, please contact us by email at: [e-mail].

Address: 8911 N. Capital of Texas Hwy, suite 4200

Austin, TX 78759