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RAVONA WORLD PRIVACY POLICY

VERSION: 4.0

PUBLISHED: 23 January 2025

At Ravona World, we are committed to protecting and respecting your privacy while maintaining the trust and confidence of our users. This Privacy Policy (“Privacy Policy”) explains what personal information we collect, why we collect it, and how we protect it.

This Privacy Policy describes how Ravona World collects, uses, stores, and discloses information from users (each a “User”) through **www.ravonaworld.com**, including any subdomains, subpages, successor sites, or applications linked to our website (the “Website”). It applies to the Website and to all products and services made available through it.

This policy applies to information we collect:

Through the Website;
In email, text, or other electronic messages between you and the Website;
Through mobile and desktop applications you download from this Website or in other ways that provide a dedicated non-browser-based interaction between you and the Website;
When you interact with our advertising and applications on third-party websites and services, where such applications or advertising include links to this policy.

This Privacy Policy does not apply to information:

That we may collect offline or by any other means; or
That any third party may collect, including via any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this Privacy Policy carefully to understand how we handle your personal information. If you do not agree with our practices, you should not use the Website. By accessing or using the Website, you consent to this Privacy Policy.

We may update this Privacy Policy from time to time (see “Changes to This Privacy Policy” below). Your continued use of the Website after any updates are posted will be treated as acceptance of those changes, so we recommend reviewing this policy periodically.

DATA CONTROLLER

This Privacy Policy is issued on behalf of Ravona World. When we mention “Ravona World”, “we”, “us”, or “our” in this Privacy Policy, we are referring to the relevant Ravona World entity responsible for processing your data.

TYPE OF INFORMATION WE COLLECT AND HOW LONG WE RETAIN IT

We collect both personal information (as defined below) and anonymous information, and may combine these to create aggregate information (see “Definitions”).

Examples of information we may collect include:

Contact details such as first name and surname, email address, residential address, and mobile or other phone numbers;
Personal information such as gender, age or age range, or your image;
Account login credentials, including username, password, and any profile images;
Information you provide when you make in-app purchases, engage with our services, or contact customer support (for example, your name, email, and virtual item transaction history);
Information sent bilaterally or in small groups via text message, live chat, posts, or similar methods of communication;
Information obtained from third parties, such as site or platform providers (including Facebook), about your use of or interest in our services;
Location data, including location obtained from a mobile or other device interacting with our Website, or associated with your IP address, where permitted by law;
Activity, technical, and device information about your use of our Website, such as the content you view, the time and duration of visits, usage frequency, how you first heard about the Website, your preferences, and your interaction with content, as well as hardware model, device type, unique device identifiers, operating system version, browser type, and IP address;
Government-issued identification, where necessary to verify your account for security, compliance, or age-verification purposes.

How long we retain data – We keep your information for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or allowed by law. For UK residents, the table below summarizes the categories of personal information (as defined under UK law) collected or processed in the last 12 months and our intended retention periods.

Category – Examples – Collected – Retention Period / Rationale

A. Identifiers

Name, alias, postal address, email address, phone number, account name, IP address, government-issued identifiers (e.g., passport number, driver’s license number)

Collected: YES

Retention: 3 years – retained for account management, legal obligations, and operational purposes

B. Personal information

Employment history, education, insurance policy numbers, health or medical information

Collected: YES

Retention: 3 years – retained for contractual purposes and legal obligations

C. Special category data

Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sexual orientation, sex/gender

Collected: YES

Retention: 3 years – processed only where lawful (explicit consent, legal obligation, or legitimate interest)

D. Commercial information

Records of personal property, products or services received, considered, or used; browsing and consumption preferences

Collected: YES

Retention: 3 years – used for marketing analysis, customer relationship management, and service improvement

E. Biometric or genetic information

Fingerprints, facial recognition templates, iris scans, DNA data

Collected: NO

Retention: Not collected

F. Online activity and interaction

Website browsing history, search history, interactions with advertisements, app usage

Collected: YES

Retention: 3 years – to improve services and user experience on the Website

G. Location data

GPS, device location, or movement patterns

Collected: YES

Retention: 3 years – to provide location-based services or to optimize logistics and eligibility checks

H. Sensory data

Audio, video, thermal, olfactory, or similar data

Collected: NO

Retention: Not collected

I. Employment/professional data

Job history, performance evaluations, qualifications

Collected: NO

Retention: Not collected

J. Educational data

Student records, grades, transcripts, schedules

Collected: NO

Retention: Not collected

K. Inferences/profiles

Preferences, characteristics, psychological trends, behaviour patterns

Collected: NO

Retention: 3 years – used solely for improving services and personalization, where applicable

HOW WE COLLECT YOUR INFORMATION / SOURCES OF INFORMATION

We collect information you provide to us in various ways, including when you:

Visit or browse our Website;
Register an account on the Website;
Engage with or receive products and services through the Website;
Respond to surveys or fill out forms;
Take part in other activities, features, or resources we make available.

In addition to collecting information via the Website, we may collect information:

By telephone, video calls, or written correspondence (including email, live chat, mail, text message, or social media).

All telephone or video calls between Users and Ravona World representatives may be recorded for training, quality control, and compliance purposes. By continuing with any such call, you consent to the recording.

We also collect information about how you use our products and services through various technologies when you visit our Website or use our applications on third-party sites or platforms (whether or not you are logged in), including cookies, flash cookies, pixels, tags, and application program interfaces (“APIs”). See “Personal Data Collected via Technology” below for more details.

Analytics tools are also used to gather information when you visit our Website or interact with our services on third-party sites or platforms.

We may further use trusted third-party sources to update or supplement the information you provide or that we collect (for example, to verify postal addresses or validate identity information).

HOW WE USE COLLECTED INFORMATION

The Data Controller is responsible for processing and may use your information for the purposes described in this Privacy Policy. Other entities within Ravona World may access your information where they act on behalf of the Data Controller as data processors.

In summary, we use the information collected to operate our Website, provide our products and services, respond to your questions, and comply with applicable regulatory and legal requirements.

Subject to applicable law and any choices you may have, Ravona World may use Users’ information for the following purposes:

To provide and manage services you request – including processing your registration, creating and maintaining your account, and performing checks to guard against fraud or misuse.
To improve customer service and our services – information you provide helps us to respond more efficiently to your requests; feedback may be used to enhance our products and services.
To process in-app purchases or virtual currency transactions securely – including using information you provide to help keep your account safe and ensure seamless transaction processing.
To personalize your experience – we may aggregate and analyze information to understand how Users as a group use our Website and services.
To communicate with you about our services – for example, via email, live chat, mail, or social media, including promotions, contests, surveys, new features, and other relevant updates. Provision of your telephone details may be treated as consent to receive text messages by automated systems where permitted by law. Consent for direct marketing is not a condition of purchase.
To send important notices – such as communications about in-game purchases, account activity, or legal notices regarding changes to our terms, conditions, or policies. You acknowledge that you may not opt out of receiving these essential service communications.
To comply with legal and security obligations – including using gameplay data and account information to ensure a safe, secure, and responsible environment.
To offer alternative dispute resolution services – where necessary, we may share relevant information with a third-party dispute resolution partner if internal resolution has not been successful.

We do not use automated decision-making processes within the scope of European data protection laws.

PERSONAL DATA COLLECTED VIA TECHNOLOGY

When you interact with our Website, we aim to make that experience smooth and useful. We and our partners use common industry technologies such as cookies and similar identifiers.

These technologies are small files or pieces of code placed on your computer, tablet, mobile phone, or other device when you visit a website. They allow us to store or read certain information relevant to your interaction with the Website.

Examples include:

Cookies – Small text files stored in your browser that help remember preferences and settings. Most browsers allow you to block or delete cookies, but some features of the Website may not function correctly if you do so. Unless you have set your browser to refuse cookies, our systems will place cookies when your browser accesses our Website.

Pixel tags / web beacons – Small pieces of code embedded on web pages that help us understand user engagement (e.g., whether a page was visited or an ad was clicked). We may also use web beacons in emails to know whether messages were opened, acted upon, or forwarded.

Mobile device identifiers – We may use or share advertising identifiers associated with your mobile device or tablet (such as Apple IDFA or Google Advertising ID) with advertisers for internet-based advertising.

Event tagging – Event tagging (including tools like Facebook App Events) helps track actions on the Website such as installs, purchases, or other interactions. This allows us to measure performance and build audiences for targeting.

Behavioral advertising – We may partner with third parties to display ads on our Website or manage our ads on other sites. These partners may use cookies or similar technologies to gather information about your browsing activities to serve ads based on your interests. We do not control how these third parties use their tracking technologies. For questions about specific ads or targeted content, you should contact the relevant third party directly.

YOUR RIGHTS OVER YOUR INFORMATION

General rights

Depending on your location and applicable law, you may have several rights regarding the personal information we hold about you. To exercise these rights, please contact our Data Protection Officer.

These rights may include:

The right to access the personal information we hold about you;
The right to object to certain types of processing;
The right to correct inaccurate or incomplete information;
The right to obtain a portable copy of personal information you have provided;
The right to withdraw consent where processing is based on your consent;
In some cases, the right to request deletion of your personal information.

We will not treat you unfairly or discriminate against you for exercising your rights. However, these rights are not absolute and may be subject to legal or contractual obligations.

We may also update, correct, or delete incomplete or inaccurate information at our discretion, in line with our internal policies.

Right to complain to a supervisory authority – You may lodge a complaint with a relevant data protection authority if you believe our processing of your personal information violates applicable laws.

Rights in direct advertising

If we process your personal information for direct marketing, you have the right to object at any time to such processing, including any related profiling.

You may opt out of receiving marketing communications by following the unsubscribe instructions in our messages or by contacting Customer Support. Once you object to processing for direct marketing, we will stop using your information for that purpose.

Data deletion request – To protect user privacy and security, we require all users to verify their identity before we process any request to delete account data. This helps ensure that deletion requests are made by the rightful account holder.

If you wish to request data deletion, you may be asked to complete a verification process, which may include identity confirmation via email, phone, or other secure methods. For more information, please contact our customer support team.

Opt-Out Preference Signals – Under UK GDPR, you may limit or prevent the collection of non-essential data from your device while using our Website. You can:

Adjust your browser or device settings to block cookies or other tracking technologies;
Enable Global Privacy Control or similar signals in your browser or browser extensions to express your privacy preferences.

Please note that by blocking or deleting cookies and similar technologies, certain features or full functionality of the Website may not be available.

If you wish to opt out of interest-based advertising, you can do so by following the relevant opt-out link provided on the Website (where available). Users in other jurisdictions (such as the EU) should consult the applicable regional opt-out mechanisms. We will respect opt-out signals on each browser where they are implemented.

UK Data Subject Rights

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, UK residents have the following rights regarding the processing of their personal data:

Right to Access (Subject Access Request) – To request details of the personal data we hold about you, including processing purposes, categories of data, recipients, and retention periods.
Right to Rectification – To ask us to correct inaccurate or incomplete personal information we hold.
Right to Erasure (Right to be Forgotten) – To request deletion of personal data, subject to certain legal or contractual retention obligations.
Right to Restriction of Processing – To request that we limit processing in certain circumstances, e.g., if you dispute accuracy or object to processing.
Right to Object – To object to processing, including for direct marketing, profiling, or where we rely on legitimate interests.
Right to Data Portability – Where applicable, to request a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another controller.

How to Submit a Request – To exercise your rights, you (or a legally authorized representative):

Must provide sufficient information to allow us to verify your identity (e.g., full name, email address, and any other details we may reasonably require);
Should clearly describe your request, specifying which rights you wish to exercise (access, correction, deletion, restriction, objection, portability, etc.).

We will respond within one month of receiving your request, in line with UK GDPR. If your request is complex or numerous, we may extend this period by up to two additional months, and we will inform you of the reason for the extension.

How to exercise your rights

To exercise any of these rights, please email us at **[email protected]**. We may need to verify your identity and place of residence before processing your request.

Please:

Provide enough information to allow us to confirm that you are the person whose data we hold (for example, sending the request from the registered account email or confirming login details);
Provide sufficient detail so we can understand, evaluate, and respond to your request.

Each request that meets these criteria will be considered a “Valid Request.” We will only use the personal information provided in a Valid Request to verify your identity and fulfil the request. You do not need an account to submit a Valid Request.

Authorized Representatives – Under UK GDPR, you may appoint someone (an “Authorized Representative”) to exercise your rights on your behalf. You must provide written authorization confirming their authority, and we may request a copy of this when they submit a request for you.

We generally do not charge a fee for Valid Requests. However, if a request is excessive, repetitive, or manifestly unfounded, we may charge a fee or refuse to act in accordance with applicable law. If a fee is applicable, we will notify you in advance.

Registered Users may also update certain account information (including personal information) directly by logging into their account settings.

We will not discriminate against you for exercising your rights. We will not deny services, charge different prices, or provide lower-quality services solely because you exercised your privacy rights. We may, however, offer different service tiers or benefits in accordance with applicable data privacy laws, where differences are related to the value of personal information provided.

In some jurisdictions, you may have the right to appeal our response to your request. You can appeal by emailing **[email protected]**. We will respond within 45 days or as required by law. If you disagree with our assessment, we will explain any further options available to you, including how to escalate the complaint to a data protection authority.

HOW WE PROTECT YOUR INFORMATION

We maintain physical, electronic, and operational safeguards designed to protect the information we collect. We adopt appropriate data collection, storage, and processing practices and implement security measures to protect against unauthorized access, use, alteration, disclosure, or destruction of your personal information, including usernames, passwords, and data stored on our Website.

Our security practices are reviewed regularly and updated in line with technological developments.

The security of your information also depends on you. Where you have a password to access certain parts of the Website, you are responsible for keeping it confidential. Please do not share your password with anyone.

Unfortunately, transmission of information over the internet is not completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security during transmission. Any transfer of personal information is done at your own risk. We are not responsible for circumvention of privacy settings or security measures on the Website.

SHARING YOUR INFORMATION

We do not sell, trade, or rent Users’ personal identification information. However, there are situations in which we share your personal data with:

Other companies within Ravona World;
Third parties that provide services on our behalf;
Other third parties where required by law or in connection with significant business transactions.

Sharing with other Ravona World entities

We may share information with other companies in the Ravona World group for the purposes described in this Privacy Policy. See “Transfers” below for more details on international transfers.

Sharing with third parties

We only share personal information with third parties in limited circumstances, including:

When you instruct or give consent for us to share your information;
When providing products and services, including notifying you of important changes or developments to those products and services;
With service providers that support our operations, such as companies assisting with technology services, data storage and combination, processing in-app purchases, or providing marketing and advertising services related to our products. These partners may only use your personal information to perform services on our behalf or as otherwise required by law. Where a service provider uses personal data for its own purposes, it will act as an independent data controller where permitted by law;
In response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or as required by a regulatory body or under applicable law;
In connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ravona World assets;
Where we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ravona World, our Users, or others;
When instructing and authorizing a financial institution holding a User’s account to disclose information requested by a regulator;
To enforce our terms and conditions, protect our rights and property, detect fraud or other illegal activities, and comply with applicable law and legal processes;
For account verification and fraud prevention.

Account verification and biometric data

We may request your image to assist in verifying your identity. We may use third-party facial recognition technology providers (including, but not limited to, Sumsub) to compare the photo you provide with the photo in your identity document. These providers may process biometric data and share verification results with us.

Biometric information collected by third-party providers is stored by them in accordance with their own privacy policies. We retain such data only for as long as needed to fulfil the initial purpose or for up to 3 years from your last interaction with us, unless a longer retention period is required by law.

Categories of information we may share

In the preceding twelve (12) months, we have disclosed personal information for legitimate business purposes to the categories of third parties outlined below. Under UK GDPR, such disclosures are made only when necessary for the performance of our services, identity verification, or other lawful purposes. We do not sell personal information.

Personal Information Category – Category of Third-Party Recipients – Purpose of Disclosure

A: Identifiers

Third-party service providers (e.g., Sumsub) – To complete in-app purchases, verify identity, and ensure eligibility for services

B: Contact and Account Information

Third-party service providers (e.g., Sumsub) – To facilitate transactions and verify identity

C: Protected characteristics

Third-party identity verification providers (e.g., Sumsub) – To verify identity where legally required

D: Commercial information

Third-party service providers – To process in-app purchases and related transactions

E: Biometric information