This Privacy Policy (hereinafter “the Policy”) establish how the User’s personal data is collected, processed, stored and transferred to third parties by Lori Group Ltd. (hereinafter “Lori Group”) in connection with the use of the application “Lady Bell” (hereinafter “the Application).

 

  1. General provisions
    1. This Policy applies to all users of the Application.
    2. The Policy is an integral part of the License agreement (hereinafter “the License”) and, by installing the Application on a mobile device, the User agrees to the terms of this Policy. If the User disagrees with any term of the Policy, he (she) shall stop using the Application.
    3. Lori Group may periodically amend or update this Policy. The Policy contains a reference to a current version with recent updates or amendments. A new version of the Policy enters into force when published, unless the text of a new Policy provides differently. A current version of this Policy is always available at the Application. All previous versions of the Policy are stored in archive and can be provided to the User, if requested.

 

  1. Personal data of the User.
    1. Lori Group collects, processes and stores the following personal data about the User:
      1. Personal data that the User shall provide to register and personal data that is collected by the Application in an automatic manner: data of a public social media profile (if registration is made through a social media profile), metadata, operating system language, device ID and other.
      2. Personal data that is provided by the User on his (her) sole discretion: avatar or profile picture, biography, social media links and other.
    2. The goal of collection, processing and storing of personal data is to ensure effective operation of the Application and identification of users, to develop and to test new game features and functionalities, to detect technical flaws and bugs, to monitor statistical data (for example, number of users), to carry out marketing research and to make emailing, and to offer new services. Lori Group is free to use personal data of the User for any other goals related to the functionality of the Application.
    3. In order to optimize the Application and to assure its proper run, Lori Group may transfer user personal data to Lori Group’s partners and service providers that provide external services for the Application (for example, payment service providers). By accepting the License, the User expresses his (her) consent with such transfer (including a cross-border one). Lori Group commits not to transfer the User’s personal data to a third party that is not connected to the functioning of the Application. Lori Group is not liable for any data protection infringements committed by its partners or service providers, if applicable law does not envisage such liability.
    4. Lori Group is not liable for any possible infringements connected to collection, processing and storing of personal data by third parties (for example, when the User follows the link posted by users in the Application).
    5. Lori Group can use, transfer, exploit and enjoy other rights in relation to copyrights made available by the User through the Application. Such copyrights may contain personal information (for example, facial image in a picture). By making available such copyrights through the Application, the User gives a full and unconditional consent to Lori Group to use such personal data, images and other personal information embedded into such copyright objects. By making available such copyrights, the User also guarantees that the consent of all personal data subjects is received, if their personal data is embedded into such copyright objects. It is the User’s responsibility to seek consent of all such personal data subjects before posting or making available such copyrights through the Application. Lori Group cannot be liable for any non-received consent of such personal data subjects.
    6. Lori Group has no capacity to verify personal data provided by the User. Lori Group presumes that all personal information and data provided by the User or collected by Lori Group is authentic and up-to-date. Lori Group cannot be held liable for provision of incorrect, non-authentic or not up-to-date personal data by the User and any possible consequences deriving hereof.

 

  1. Rights and obligations of the User
    1. The User has a right to:
      1. request from Lori Group any information about what personal data is collected, processed and stored about him (her);
      2. rectify or amend his (her) personal data by editing his (her) User Account;
      3. delete the personal data, which is provided by the User on his (her) sole discretion (see para. 2.1.2.);
      4. delete the personal, data which provision (see para. 2.1.1.) is mandatory by deleting the User Account. If the User Account is deleted, the Application can no longer be used.
      5.  ask Lori Group to deleting personal data that is incorrect, incomplete, unlawfully obtained or collected not in connection with the goals specified in para. 2.2, or that is no longer relevant, if such deletion cannot be done independently in accordance with para. 3.1.3. and 3.1.4.
    2. The User is obliged:
      1. to provide only such personal data that is authentic and up-to-date;
      2. not to collect and use personal data of other users for any purposes;
      3. to comply with applicable law on data protection.

 

  1. Confidentiality of personal data
    1. Lori Group does not transfer personal data of users to third parties except of the cases envisaged by this Policy and (or) applicable law.
    2. The Application does not have privacy and confidentiality settings and, by installing and using the Application, the User agrees that his (her) personal data can be in some part available to other users (for example, name and avatar).
    3. Lori Group may disclose the User’s personal data when it is required for national security protection reasons, law enforcement and other legitimate demands of the authorized authority in accordance with a legal procedure established under applicable law. Lori Group may also restore and transfer such personal data that has been previously deleted or changed when requested by the authorized authority and in accordance with a legal procedure established under applicable law (for example, with a court order).
    4. Lori Group may disclose the User’s personal data in order to protect its own business interests, interests of other users and public. By accepting the License, the User agrees to such disclosures.

 

  1. Retention and transfer of personal data
    1. Lori Group retains only such personal data that is required to provide an access to the Application, to support the Application operation, and to assure that the goals of processing specified in para. 2.2 are followed and fulfilled.
    2. Lori Group will take all necessary and adequate measures (technical, organizational and legal) to protect the User’s personal data from unauthorized access, destruction, modification, alteration, copying, distribution and other unauthorized actions of third parties.
    3. Lori Group may fix an exact term for retention of the User’s personal data, if such term is prescribed by applicable law or if it is required for the goals of processing specified in para. 2.2.
    4. By installing and using the Application, the User expresses his (her) consent for transferring of his (her) personal data to the country where Lori Group’s servers are located (Germany) or any other country where Lori Group has or will have its servers and other equipment. The User also consents to transfer of his (her) personal data to countries where the data protection regime might be lower that in a country of his (her) domicile, residence or citizenship.

 

  1. Warranties
    1. Lori Group takes all possible measures to maintain confidentiality of the User’s personal data with due regard to provisions of para. 4.  Nevertheless, Lori Group cannot guarantee full security of any personal data that the User provides to Lori Group or that is collected about the User in the scope of his (her) use of the Application. Lori Group cannot also guarantee that personal data will not be disclosed, published, changed or destroyed. To the maximum extent permitted by applicable law, Lori Group is not liable for any such disclosures, publications, changes and destructions.
    2. Lori Group will take all possible measures to amend, rectify or delete personal data that is incorrect, inadequate or not up-to-date.
    3. Lori Group guarantees that it will provide the User any information about what personal data is collected, processed and stored about him (her).

 

  1. Miscellaneous
    1. Lori Group does not purposefully direct its activities to a territory of any country. In spite of the fact that the Application may be initially downloaded and installed only in some jurisdictions, it is expected that it will be accessible to a broader range of users from other countries. The fact that the Application can be downloaded and installed in particular jurisdiction does not mean that Lori Group purposefully directs its activities to such jurisdiction.
    2.   If any term of this Policy is determined to be invalid by a court or other competent authority, its invalidity does not lead to invalidity of the Policy and its other terms. If any term of this Policy or the whole Policy is determined to be invalid by a court of one country, such invalidly does not lead to invalidity in other countries.
    3. The terms of this Policy are regulated by the English law (the applicable law). All disputes arising out of this Policy shall be resolved by the London Court of International Arbitration (London, the United Kingdom).