Privacy Policy
Please review this
Privacy Policy carefully. This Privacy Policy will inform you about the
information we may collect from you, how we use or store it, the choices you
have regarding our use of it, your ability to review and correct it and how to
opt out from any of our services and/or from receiving any promotional
material. The data we may collect may be personal information about you or by
which you can be identified e.g. your full name, address (email and/or postal),
mobile number/MSISDN (mobile station integrated services digital network
number), date of birth, gender etc. (“Personal
Information”). We may aggregate personal information and remove any
identifying elements in order to analyse patterns and improve our marketing and
promotional efforts, to analyse service use, to improve our content and service
offerings, and to customize our Web App (as defined below) content, layout and
services, we may gather certain usage information like the number and frequency
of visitors to our Web App (as defined below). This information may include your URL/internet protocol address, mobile
device location, browser type, pages of service accessed. We only use such data
in the aggregate. This aggregate data helps us to determine how often our
customers use our Web App (as defined below) and do research and demographic
analysis of our customers as well as their interests and behaviour, so that we
can better understand and provide you with the best service.
This Privacy Policy is supplemental to the terms and conditions for our service
found at URL: spacegames.fun which form an integral part of this
Privacy Policy.
Who We Are
Atheer Telecom Iraq Limited, a company duly registered
in Iraq having its
principal place of business at 27/35/915 Al-Jadriya
, Baghdad, Iraq (the “Company”). The
Company provides contents which is accessible on your mobile handset via the
internet through our web application (‘spacegames.fun (Net Media Mobile-2616870
Ontario Inc).
Privacy Commitment
We understand and recognise the importance of safeguarding the Personal Information
received from our customers and so we have formulated this Privacy Policy to
reflect our commitment to maintaining the confidentiality of the Personal Information
received from you via your selected Service.
We respect your
privacy, and we will handle your data in an ethical manner. We will also ensure
that we are compliant with mandatory data protection and privacy laws,
including, the governing laws in Iraq.
Information Collected and Used
You may obtain confirmation from us about the existence or non-existence of
Personal Data and obtain such confirmation in an intelligible form.
Generally, you can
access our Service without telling us who you are or revealing any of the Personal
Information, although we may collect certain data about your visit to the
Service to help us improve the Service quality. Before you are able to fully
access any of the contents, the Web App or use the Service you will be required
to subscribe to the Service via the Web App.
We may gather the Personal Information to allow us to process your subscription
to the Service, process any requests or payments you may make, administer your
contract, process refunds, communicate with you, award prizes, and, subject to
your consent, provide marketing or promotional materials and we may also
collect the Personal Information so you can access the online Service, monitor
your usage of our Service, and/or participation in online activities including
reviews, testimonials or competitions, if any, or for other purposes outlined
below.
You may at any time withdraw your consent to
us collecting some of the Personal Information or any other data you provided
but this could limit your access to part of the Service.
Every time you visit the Service our system automatically recognises the mobile
device type used to communicate with us (where possible). Individual users will
remain anonymous unless you tell us who you are.
Children and Minors
We do not knowingly collect or solicit Personal Information or other data from
children and minors. Anyone under the age of 18 (eighteen) will not be
knowingly allowed to register for the Service.
If you are under 18 (eighteen), please do not attempt to register for the
Service (or any part of it) or send any Personal Information or other data to
us. If you are a parent or guardian and you are aware that your child has
provided us with Personal Information, please contact us immediately. In the
event that we become aware or informed that we have collected Personal Information
from anyone under the age of 18 (eighteen) without verification of parental
consent, we will promptly delete such Personal
Information from our servers.
Information to Third Parties
We will not rent,
sell or share your Personal Information with other organisations
or non-affiliated companies for commercial purposes unless you have expressly
consented to this.
However, by law or for regulatory reasons, we may have to reveal any Personal Information
to certain third parties if required to investigate or deal with any complaints
relating to you or your use of the Service. Your Personal Information may be
revealed to other businesses within our group of companies and to reputable
third parties who will help process your subscription to the Service if
necessary such as our supply and service agents and data processors.
If all or part of our business is sold,
(whether by sale of shares or assets) or integrated with another business, your
Personal Information may be disclosed to our advisers and any prospective
purchasers and their advisers and will be passed on to the new owners of the
business. Following completion of any such sale or transfer your Personal Information
shall be disclosed to and transferred to such new owner or third party.
We do ask our third parties to confirm that their privacy practices are
consistent with ours to ensure maximum protection of your privacy. A complete list of
the companies responsible for the data processing can be requested directly
from the Company.
Linking to third party sites
If our Service, Web App and/or Content contain a link to any websites outside
of our control these websites are not under our control and we are not
responsible for those websites or the conduct of companies who own or control
those websites. Your use of those other websites is subject to any terms of use
and/or privacy policies on those websites.
Your Consent
You agree to us collecting, using and processing your Personal Information as
set out in this Privacy Policy.
Transfers
Presently, we can
confirm that any Personal Information collected from you is stored on secure
servers which are located or hosted in IRAQ. However, due to the global nature
of the internet infrastructure and our business, the Personal Information you
provide you provide may be transferred in transit to countries outside IRAQ to
our affiliates and subsidiaries. The laws governing data protection in these
countries or jurisdictions may differ from the laws in IRAQ. We will comply
with all mandatory data protection and privacy laws in the IRAQ and take all
steps reasonably necessary to ensure that similar and/or comparable standards
for data protection are maintained by any our affiliates and subsidiaries which
are recipients of your Personal Information. By your voluntary submission of
information to us, you are consenting to the disclosure, transfer and use of
your Personal Information outside of the IRAQ for the purposes described in
this Privacy Policy.
We will provide
you with the exact information about the countries of the data importers upon
your request.
Your Right to Opt-Out.
You have the right
to cancel any of the Services at any time using any of the following ways: a)
clicking on “unsubscribe” option in the footer of the Web App portal and
following the instructions or b) send “013” to 4086 or by calling the customer care team
using the contact details noted below at the bottom of the Agreement;
Updating Your Information
If you wish to access, correct, update or receive a copy your Personal Information
please use the contact details listed in the Contact Information section below.
Withdrawal of Consent
You may at any time withdraw your consent or object (in whole or in part) to us
collecting and further processing your Personal Information in accordance with
this Privacy Policy by giving us written notice to us, please see the Contact
Information section below. Upon receipt of the withdrawal notice we shall cease
(and cause our third parties to cease) collecting, using or disclosing the Personal
Information as the case may be unless such collection, use or disclosure, as
the case may be, without your consent is required or authorised under applicable
data protection laws or other written law.
If you consented
to receiving marketing information from us, but now no longer wish to receive
marketing information from us SMS 0 to 2027 to stop receiving promotional and marketing offers from
us.
Cookies
Our Service uses ‘cookies’ to distinguish you from other users of our Service.
A cookie is a small amount of data or parcels of text that is sent to your
browser from a web server and stored on your mobile device’s hard drive, if you
consented to this. Generally, a 'cookie' being a file in your web browser
enables the website to recognise your mobile device when you visit the
website.
Cookies help us to
enhance your experience when you access our Service and also allows us to
improve it. We may obtain information about your general internet usage by using
such cookie files which are stored on the browser of your mobile device type.
Cookies contain information that is transferred to your mobile device type.
They enable us to:
• estimate our audience size and usage pattern.
• store information about your preferences, and so allow us
to customise our site according to your individual interests.
• speed up your searches.
• recognise you when you return to our site.
• provide a more convenient browsing experience for you.
You may refuse to accept all cookies, reject all cookies, or modify your
browser to alert you of any new cookies by activating these settings on your
browser. However, if you select any of these settings you may be unable to
access certain parts of the Service. Unless you have adjusted your browser
setting so that it will refuse cookies, our system will issue cookies when you
access our Service. Please note that our advertisers may also use cookies, over
which we have no control.
To reject cookies or alter the access in any way, you can follow the
instructions below to do so. Please always check for updated software
instruction versions as to how to control cookies.
iPhone
1. Turn on your iPhone
2. Tap on "Settings."
3. Scroll down and select "Safari."
4. Swipe to the bottom and tap on "Clear
Cookies."
5. When it asks you to confirm, tap on "Clear
Cookies"
6. Delete any saved passwords
Android
1. Turn on your Android
2. Tap on your preferred "Browser."
3. Press the "Menu" button
4. Tap "More" and then "Settings."
5. Select "Privacy Settings" and tap on "Clear
All Cookie Data."
6. When it asks you to confirm, click "Yes"
You can also discover independent information about cookies by researching the
internet or carrying out online searches.
Security
Statement
The security internal procedures are designed to cover the storage, access and
disclosure of your Personal Information. We are committed to online security.
We maintain security measures to protect the sensitive data via the Service and
to prevent unauthorised access of customer information that is transmitted to
our databases. We cannot however guarantee the security of any data sent over
the internet. Details of our security policy and measures can be found below.
This Security Statement explains how we store and safeguard the data we collect
about you, and procedures that we have in place to safeguard your privacy
generally.
We always use industry-standard encryption technologies when transferring and
receiving customer data exchanged with our Service. We have appropriate
security measures in place in our physical facilities to protect against the
loss, misuse or alteration of data that we have collected from you on our
Service. Unfortunately, however, no data transmission over the internet
can be guaranteed to be 100% secure.
To prevent unauthorised access, maintain accuracy of our records and data to
ensure proper use of data, we have put in place appropriate physical,
electronic and managerial procedures to protect, secure and safeguard your Personal
Information that we collect or on through our website.
The following provisions and arrangements are in place:
1. We have a management and corporate commitment to data
security within the organisation and provide clear direction, guidance and
responsibilities and procedures in this respect.
2. We have a designated or nominated compliance officer who
deals with security of your Personal
Information together with relevant compliance with the applicable data
protection laws.
3. All employees are briefed on the importance of personal
data and security and confidentiality of data obtained. Employees may attend
training programmes and are provided with updates or practical guidance under
the applicable data protection laws.
4. We control physical security in relation to your Personal Information
that is contained at our facilities and restrict access to the site, buildings,
computer rooms, office desk, technology areas, equipment and other facilities
where unauthorised access by people could compromise our security.
5. All proprietary or confidential information, including
your Personal Information, is contained or stored on computer and any that is
contained and stored on manual files are locked up and secure.
6. We may seek to control access to your Personal Information, including existing procedures for authorising and
authenticating users as well as software controls for restricting access and
techniques for protecting data such as encryption. Encryption is used in
connection with our payment facilities for customers, which ensures that any
communications between your computer and ourselves is unreadable by anyone
else.
7. We monitor and log access so as to assist in detection and
investigation of security breaches and any attempted breaches where they
occur.
8. We maintain a business continuity plan as a contingency
plan which identifies our business functions and assets (including your Personal
Information) which would need to be maintained in the event of disaster and set
out the procedures for protecting and restoring them if necessary.
9. In respect of detection and investigation of breaches
where they occur, we have in place relevant controls which should alert us to a
breach in security. We endeavour to investigate every notified breach of
security.
10. The Personal Information held by us are currently stored
on a relevant technology system, mass email programme data base, individual
account contact manager’s systems together with the training booking spread
sheet, invoicing spread sheet, Excel spread sheets, paper form.
11. Our security measures are reviewed and updated from time
to time.
Changes to Our Privacy Policy
From time to time it may be necessary for us to review and revise our Privacy
Policy. If we intend to change our Privacy Policy in a manner that directly
affects the use, storage and/or disclosure of your Personal Information, then
we will seek your consent to such changes before they become applicable to you.
In all other circumstances, we reserve the right to change our Privacy Policy
at any time and we may notify you about changes to this Privacy Policy by
posting an updated version of the policy on our Web App
‘Service URL’. By continuing
to access or use the Service after we have posted an updated Privacy Policy or
have provided you with notice of any material modifications of the same you are
agreeing to be bound by the modified Privacy Policy. If the modified Privacy
Policy is not acceptable to you your only recourse is to cease using the
Service.
Contact Information
If you have any questions, comments or concerns about concern about how
we handle your Personal Information, please contact us using the details below:
Helpline:
107
Email: [email protected]
You can unsubscribe at any time by:
a) SMS “013” to 4086, b)
clicking on “unsubscribe” option in the footer of the Web App portal and
following the instructions or c) by
calling our customer care team 107
Update: last update September 2019