Privacy Policy
INTRODUCTION
Venturevate Limited (C 74415) with registered office at No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta (“we“, “us“, and/or “Venturevate”) is committed to protecting data subjects’ privacy in accordance with the General Data Protection Regulation (”GDPR”) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) (“DPA”) (together, “Data Protection Laws”).
This Privacy Policy was prepared for the purposes of the app created by www.islandbebe.com available on both Google Play Store and Apple App Store, which app is called Nina U Ninu (the “App”). This Privacy Policy explains what personal data we collect from you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Kindly note that notwithstanding the fact that the game/s available on the App is/are aimed at minors, personal data of minors under the age of sixteen (16) years will not be collected. Only personal data regarding a minor’s parent/legal guardian may be collected.
Information we Collect
The personal data which we may collect about you is given to us only if you choose to. If you send us an email, then the personal data processed will depend on what you send us within the email.
How and Why we use your Information
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collect it.
The tables below set this out in detail, showing what we do, and why we do it.
| How we use your Name + surname
+ contact details (email address) |
Why? |
| To provide you with service and support messages by email | This is required to reply to any queries you may have. |
| Knowing what you, and other users, like | To ensure we are providing users with what they want, and learn what can improved for future updates of the App. |
The Legal Basis for Processing
For all of the uses of your personal data (as described above), we ensure that there is a legal basis under applicable data protection laws for us to use such personal data.
This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you. We also use consent as a legal basis in order to process your query when you contact us, provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
- to carry out research and analysis of your data as this helps us understand our clients better, who they are and how they interact with us; and
- to improve and ensure the security of the App (for example, for statistical, testing and analytical purposes, troubleshooting).
Retention Periods
We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Generally we will keep personal data until such time as you ask us to stop communications with you, unless we need to keep the data for longer;– we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute.
We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for about 10 years in order to comply with tax/VAT reporting requirements);
You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us on [email protected].
Children Under 16
We will not accept any personal data from persons under the age of 16. We shall only accept the personal data of parents/guardians.
Sharing your Information
We do not, and will not, sell any of your personal data to any third party – including your name, email address or any other information you may provide to us.
However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:
- Companies in the Venturevate Limited group to which the App belongs, as sometimes different entities within our group are responsible for different activities. Related entities and subsidiaries use the information collected to help us improve the content and functionality of our App; to better understand our customers and markets; and to improve our products and services. Members of the group vary from time to time.
- Professional service providers, such as marketing agencies, and advertising partners.
- Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.
We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.
If we ever have to share data with entities that are outside of the EU/EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.
YOUR RIGHTS
Before addressing any request you submit to us, we may first need to verify your identity. In all cases we will try to act on your requests as soon as reasonably practicable.
Your various rights at law include:
Your Right of Access
You may, at any time request us to confirm whether we are processing personal data that concerns You and, if we are, you shall have the right to access that personal data.
Your Right to request the Correction of inaccurate personal data we hold about you
You have the right to ask us to correct inaccurate personal data and to complete incomplete personal data concerning you. We may seek to verify the accuracy of the data before correcting it.
Your Right to Erasure (The Right to be Forgotten)
You have the right to ask us to delete your personal data, however, this is not an absolute right.
Despite a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
Your Right to Data Restriction
You have the right to ask us to restrict (that is, store but not process further) your personal data but only where:
- The accuracy of your personal data is contested (see the right to data correction above), for a period enabling us to verify the accuracy of the personal data; or
- The processing is unlawful, and you oppose the erasure of your personal data; or
- we no longer need the personal data for the purposes for which they were collected but You need the personal data for the establishment, exercise or defence of legal claims; or
- You exercised your right to object and verification of our legitimate grounds to override your objection is pending.
Following your request for restriction, except for storing your personal data, we may only process your personal data:
- Where we have your consent; or
- For the establishment, exercise, and/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.
Your Right to Data Portability
You have the right to move, copy or transfer your personal data from one organisation to another. If you wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). we can provide the personal data to you directly or, if you request, to another organisation.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
Your Right to Withdraw Consent (when we rely on consent)
Your Right to Object to Certain Processing
You have a right to object to our use of your personal data including where we use it for our legitimate interests or where we use your personal data to carry out profiling using automated means.
Your Right to lodge a Complaint
You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. The Data Protection Supervisory Authority in Malta is the Office of the Information and Data Protection Commissioner (IDPC). The IDPC’s website can be accessed at https://idpc.org.mt/en/Pages/Home.aspx
We kindly ask that you please attempt to resolve any issues you may have with us first. we may be contacted by email on [email protected], and by post at Venturevate Limited, No. 8 Regent House, Office 25, Bisazza Street, Sliema, Malta.
Nevertheless, you have a right to contact the appropriate Data Protection Supervisory Authority at any time.
WHAT WE MAY REQUIRE FROM YOU
As one of the security measures we implement, before being in the position to help you exercise your rights as described above, we may need to verify your identity to ensure that we do not disclose to or share any personal data with any unauthorised individuals.
TIME LIMIT FOR A RESPONSE
We try to reply to all legitimate requests within one month from receiving them. In some cases (for example, if the matter is particularly complex or if You send us multiple requests), it may take us longer than a month. In such cases, we will notify You accordingly and keep You updated.
SECURITY
We value your trust when you choose to provide us with your personal data. we are striving to use commercially acceptable means of protecting it. Remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. You are advised to review this page periodically for any changes. we shall notify you of any changes by posting the new Privacy Policy. These changes are effective immediately.
HOW TO CONTACT US
We are always happy to hear from you!
If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal data, please contact us:
By email on: [email protected]
By post at: Venturevate Limited, No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta