Privacy Policy

This Privacy Policy governs the processing of personal data of users of the Sumalo mobile application (hereinafter, the "Application"), in accordance with Regulation (EU) 2016/679 of April 27 (GDPR) and other applicable data protection regulations.

By accessing and using the Application, you fully and unconditionally accept this Privacy Policy.

1. Data Controller

The data controller for personal data processing is the developer of the Sumalo application.

2. Personal Data Collected

The Application processes only the data strictly necessary for its proper functioning.

2.1 Data Provided by the User

• Email Address: Used as account identifier and contact method.
• Username or Alias: Visible within the Application.

2.2 Technical Data Collected Automatically

• Device Identifier and/or Push Notification Token: Required for sending notifications via Firebase Cloud Messaging.
• Basic Technical Device Information: Operating system and version.

2.3 User Avatars

The avatars used in the Application do not constitute personal data because:

• They are predefined images included in the Application itself.
• They do not allow direct or indirect identification of an individual.
• Users are not permitted to upload personal images.

3. Purpose of Data Processing

Personal data is processed exclusively for the following purposes:

• Management and authentication of user accounts.
• Enabling participation in games, challenges, and game modes.
• Sending push notifications related to Application activity.
• Ensuring security, stability, and proper functioning of the service.
• Compliance with applicable legal obligations.

4. Legal Basis for Processing

• Contract Performance: Use of the Application by the user.
• User Consent: Granted upon registration and use of the Application.
• Legitimate Interest: To ensure security and functionality of the service.

5. Push Notifications

The Application uses push messaging services to inform users about relevant events related to their activity.

A technical device identifier is stored for this purpose. Users may disable notifications at any time through their device settings.

6. Data Sharing and Third-Party Access

Personal data will not be shared with third parties, except in the following cases:

• Technology Service Providers: Strictly necessary for Application functionality (e.g., notification services).
• Legal Compliance: Fulfillment of legal obligations or requirements from competent authorities.

In all cases, such providers act as data processors and comply with current data protection regulations.

7. Data Retention

Personal data will be retained as long as the user's account remains active.

Once account deletion is requested, data will be securely deleted, except for data that must be retained due to legal obligations.

For more information about account deletion, please visit our Account Deletion Information page.

8. User Rights

Users may exercise the following rights at any time:

• Access: Access to their personal data.
• Rectification: Correction of inaccurate data.
• Deletion: Erasure of their data.
• Restriction or Objection: Limitation or objection to processing.

To exercise these rights, contact us via the email address provided in this Policy.

9. Children's Privacy

Personal data from minors is not knowingly collected. If data from a minor is detected, it will be deleted immediately.

10. Information Security

The data controller implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, loss, or destruction.

However, users acknowledge that no system is completely secure.

11. Changes to Privacy Policy

The data controller reserves the right to modify this Privacy Policy at any time. Changes will be communicated to users through the Application.

12. Contact Information

For any inquiries related to this Privacy Policy:

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