Privacy Policy

Last Updated: 01/31/2023

In its mission to develop memorable, fun and high-quality products, Aquiris Game Studio ("We" or "Aquiris") undertakes to protect the personal data and privacy of users accessing its website. 

Our Privacy Policy ("Policy") has the purpose of reinforcing Aquiris' institutional commitment to the safety and privacy of the personal data collected during your navigation in our pages, trying to help you understand how we treat and protect the information sent by or obtained from you, according to the applicable data protection laws, including the Brazilian General Data Protection Law (Federal Law no. 13.709/2018 – LGPD), General Data Protection Regulation (GDPR), Children’s Online Privacy Protection Act (COPPA) and the data protection laws of the United States.

This website is provided by Aquiris. By visiting and using this website, you automatically accept the practices and conditions hereafter described in this Policy.

1. Which personal data does Aquiris collect?

Personal data are those that allow for the identification of an individual. Based on this definition, Aquiris collects the personal information required in order to properly provide its services and offer unique products to you. 

Such information can be collected automatically or when you voluntarily provide your personal data.

• Personal data provided voluntarily: Upon accessing our website, you will be introduced to various contents and functionalities with no need to provide your personal data. However, some interaction instances will necessarily depend upon data treatment: 
  - Contact: when you interact with us by means of our support – either through the website or by e-mail  support@aquiris.com.br -, as well as by means of our social networks, we may receive and store any information that you send and/or enter in our platforms directly and deliberately, such as full name, e-mail address, contact phone number and/or other personal information provided voluntarily. Such data will be used solely for the purpose of improving our services and completing our contact with you. Unless expressly authorized by you, your data will not be used for any marketing purposes;
  - Newsletters: finally, by entering your name and e-mail in the fields for receiving game updates, you agree to receive our contacts for the launch of new products, promotional material and other similar communications.
• Personal data collected automatically: In order to continue improving our product and your experience, we can collect some information during your navigation in our website by automatic means, such as cookies and web beacons.  The collected information serve to customize your navigation and is detailed in our Cookie Policy.

2. For which purposes does Aquiris treat personal data?

We understand that our users' personal information is an integral part of our business, to allow for the proper provision of services, better performance of our activities, improvement of our product and especially the maintenance of our communication channel with you. 

Thus, Aquiris only treats your personal data for lawful purposes, in agreement with the applicable laws, such as:

• Serve and interact with you in our support channels and social networks, by processing and responding to your requests, questions, complaints and/or comments about our products and services;  
• Send you information about games, system notices, new products, promotional material and other communications whenever required and/or desirable;
• Operate, assess and improve our activities (including improving our services and games, managing our communications, conducting analyses and performing other internal functions);  
• Protect, identify and prevent fraud and other illegal activities, complaints and other responsibilities;  
• Comply with the applicable legal requirements, industry standards, our own policies and terms and/or orders from authorities.

All our operations are supported by some of the legal bases of the applicable laws.

3. Does Aquiris share my personal data?

We need to share your personal data with third parties who provide services on our behalf in order to perform our activities. This is the case, for instance, of the services engaged by us for the hosting of our databases.  Below we describe some situations in which we may share your personal data:

• Business partners: We may share your personal information with partners of the Aquiris group in order to better offer our services and develop our business.
• Service providers: In order to provide you with high-quality products and services, we engage companies from fields such as technology, recruitment and data analysis to perform certain tasks in our business.  We may occasionally share your information with these companies to support the selection of new employees, allow for sending of our marketing e-mails and/or use efficient technological solutions. In these cases, data sharing with third parties shall comply with strict privacy and information security standards.  
• Government Authorities: We may share your personal data with government authorities whenever it is necessary to comply with statutory or regulatory obligations, for the exercise of rights in legal, administrative or arbitral proceedings and/or to protect the rights of Aquiris, our customers and employees. 
• Marketing:  Aquiris may use marketing companies to place ads by means of different technologies.  Therefore, you may occasionally received ads, contents and links displayed in a customized manner, according to your interests and behavior in our website or in other services where you interact, such as Facebook. For this purpose, data may be shared between Aquiris and these companies, especially unique identifiers, IP addresses and cookies, which may be used to measure the efficiency of on-line advertisement.  You may always oppose to this kind of advertisement by contacting us through the channels informed in this Policy.
• Business Transfers: In the event we enter into a commercial transaction such as a consolidation, acquisition by another entity or sale of all or part of our assets, your information may be among the transferred assets.  By means of this Privacy Policy you are informed that such transfers may occur and any acquirer of our assets may continue to process your personal data as established herein.  If our information practices eventually change, we shall publish such chances on our website in a transparent manner so you may learn the new procedures and eventually choose not to take part in them.  For this purpose, we suggest that you refer to our Privacy Policy periodically. 

Except as established above, your personal data will not be shared with third parties. In other cases of data sharing not related to the aforementioned purposes, you will be notified so you can consent to or refuse such practice. 

We use our best efforts to protect your personal data, but unfortunately we cannot guarantee the correct treatment of these personal data by third parties, who shall use, disclose and protect such personal data according to their respective privacy policies. If you have any question about these companies or our suppliers contact our Person in Charge at dpo@aquiris.com.br.

We further stress that our website may contain links, contents and/or connections to third-party applications/websites which we believe may be of interest to you. However, these third-party platforms are not under Aquiris' control and these links/contents do not constitute an endorsement by Aquiris of these other Platforms or the services provided through them. Therefore, we explain that the privacy and security practices of such third-party applications/websites are not covered by this Privacy Policy and Aquiris is not responsible for the privacy or security practices or the contents of such websites.

4. How does Aquiris protect my personal data?

In its procedures, Aquiris implements technical and organizational methods in order to protect your personal data against unauthorized access, improper use and/or accidental situations.  Examples of these methods are encryption and secure socket layer technology, undertaking to ensure the security of your information. 

For transparency purposes, we explain that such methods do not ensure that such firewalls and secure service software will be failure-free.  In case you identify or learn anything that may compromise the security of your data, please contact us through our Person in Charge at dpo@aquiris.com.br.

5. What are Cookies? 

Cookies are small files added to your computer in order to track your navigation in websites.  Our platform uses cookies to store certain information about your visits, such as your preferences and settings in order to identify the resources of your greatest interest and improve your on-line experience. 

For instance, cookies inform Aquiris whether you have visited us before or if you are a new visitor on our website.  Cookies also allow you to save your preferences and receive information according to your interests. 

Upon entering our website, you will be informed of the kinds of cookies we use and how to disable them; however, if you choose to disable the cookies, it is possible that your experience as a website user be limited. For further information refer to our Cookie Policy.

6. How does Aquiris protect the personal data of children and adolescents?

Our website is targeted at all audiences. Considering the characteristics of the industry and the offered product, we know of the possibility of children and adolescents accessing our website.

Before we collect any child's personal data, we use reasonable efforts, whenever required by the applicable laws to ensure that the child's parents or legal guardians be informed of and agree to our personal data treatment practices.

For the children, Aquiris may treat the same personal data informed in section 1 of this Policy for the purposes mentioned in section 2.  

In any event, we encourage parents to take part in their children's web experience. If you are a father, mother or legal guardian and wishes to request access to rectification and/or deletion of the data we collected as described in this Policy, please e-mail your request to Aquiris at dpo@aquiris.com.br.

7. How long will my personal data be stored? 

Aquiris shall keep the collected personal data until the fulfillment of purposes of each treatment of your connection to us and/or while the consent lasts, when applicable.  After the end of these cases, the personal data may be preserved for compliance with statutory, regulatory and contractual obligations for the necessary period, whenever applicable.

8. What are my rights as the owner of personal data?

Guaranteeing the protection of your personal data and your rights as the owner thereof is extremely important to us. Below we list your rights, which will be respected according to the laws applicable to you, in order to inform you of them and also help you exercise them within the context of our operations:

• Confirmation and Access: you can request the confirmation of the existence of treatment for your personal data by requesting access to and/or copy of the data we have of you. If you are a resident of the United States of America, in the State of California, we not that the right of access also encompasses the information of the categories of the collected personal data, the sources of this information and the business purpose of the treatment thereof, apart from the information already provided under this Policy.
• Correction: you have the right to the correction of incomplete, inaccurate or outdated data by requesting it directly do us;
• Anonymization, Blocking or Deletion: as data owner, you also have the right to request (a) the anonymization of your data, so they can no longer be connected to you and cease to be personal data; (b) the blocking of your data, temporarily suspending the possibility of us treating them; and (iii) the deletion of any data that you deem unnecessary, excessive or not treated in compliance with the applicable laws; 
• Portability: you have the right to submit and express request for Aquiris to provide your personal data in a structured and interoperable format to you or any third party of your choice for the transfer thereof to another service or product provider, provided it does not violate the company's intellectual property or business secret;
• Information about sharing: you have the right to know which the public and private entities are with which Aquiris shares the use of data.  We shall maintain in this Policy an updated list of the kinds of partners with which we share such data. In any event, if you have any questions or need further details, you have the right to request such information from us.
• Information about the possibility of withholding consent: it allows you to have clear and complete information about the possibility and consequences of withholding consent. Your consent, when required, must be free and informed.  Thus, whenever we request your consent, you will be free to withhold it – even if, in these cases, it is possible we have to limit our services. 
• Withdrawal of Consent:  you have the right to withdraw your consent regarding the consent-based treatment activities. However, this shall not affect the lawfulness of any treatment conducted before. If you withdraw your consent, maybe we cannot provide certain services, but we will inform you when it happens. 
• Opposition or Objection: in case you do not agree with any treatment we perform with your personal data, in some cases you may oppose to it or submit your objection, requesting the interruption thereof. 

In case you are a user resident in the United States of America, in the State of Nevada, we note that you have the right to refuse (opt-out) the "sale" of your personal data as established by the applicable laws. Aquiris does not sell personal data in its activities; however, we are concerned with your knowledge of your rights as data owner, wherever you are.  Thus, if you are a Nevada resident, you may exercise your opt-out right by sending a request for cancellation of future "sales" under Nevada’s New Internet Privacy Law, Senate Bill 220 (“SB 220”), also referred to as Nevada Revised Statutes: Chapter 603A (“NRS 603A”).

Also, if you are a California resident, the law of California provides you with specific rights concerning your personal information, including the right to request that we provide you with certain information about the collection and use of your personal information in the last 12 months; the right to request the deletion of any personal information we may have collected about you, subject to certain exceptions; and the right to refuse the "sale" of your personal data, as defined by the law of California. 

Whenever you exercise your rights, Aquiris may request some supplemental information in order to verify your identity and prevent fraud. We do this in order to ensure the security and privacy of our website users, our patients, escorts and other third parties. Also, some complex requests may not be responded to immediately, but Aquiris undertakes to respond to all requests within a reasonable period of time and always in compliance with the applicable laws.

We note that there is a possibility of maintaining personal data by Aquiris after the request for deletion of personal data by the owner, when it is necessary to keep such information as required by the law, for the performance of obligations and/or to protect the company's interests. 

In order to exercise your rights, please contact us by e-mailing your request to dpo@aquiris.com.br.

9. Can this Policy be changed?

The Aquiris team reserves the right to change this Policy at any time for the purpose of adapting it to the applicable laws and/or to reflect new operations of the company.   

In case our Privacy Policy is significantly changed, we shall place a prominent warning of such changes on our website.

We recommend that you refer to our Privacy Policy periodically, so you are always aware of its updated contents. 

10. Who should I contact for any questions or requests?

In case you have any question or request concerning the treatment of your personal data, please e-mail our Person in Charge for Personal Data Treatment at dpo@aquiris.com.br.

Versions of this document:

For your convenience, this Policy is available both in Portuguese and English.  In case there is any doubt about the interpretation of these two versions, the Portuguese version shall prevail for all purposes. 

The General Privacy Policy is a controlled document. Version control must be carefully observed.