Venturevate Limited (C 74415) with Sign uped office at No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta (“we“, “us“, and/or “Venturevate”) is committed to protecting data subjects’ privacy in accordance with the General Data Protection Regulation (”GDPR”) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) (“DPA”) (together, “Data Protection Laws”).
This Privacy Policy was prepared for the purposes of the app created by www.islandbebe.com available on both Google Play Store and Apple App Store, which app is called Nina U Ninu (the “App”). This Privacy Policy explains what personal data we collect from you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Kindly note that notwithstanding the fact that the game/s available on the App is/are aimed at minors, personal data of minors under the age of sixteen (16) years will not be collected. Only personal data regarding a minor’s parent/legal guardian may be collected.
The personal data which we may collect about you is given to us only if you choose to. If you send us an email, then the personal data processed will depend on what you send us within the email.
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collect it.
The tables below set this out in detail, showing what we do, and why we do it.
How we use your Name + surname + contact details (email address) | Why? |
| To provide you with service and support messages by email | This is required to reply to any queries you may have. |
| Knowing what you, and other users, like | To ensure we are providing users with what they want, and learn what can improved for future updates of the App. |
For all of the uses of your personal data (as described above), we ensure that there is a legal basis under applicable data protection laws for us to use such personal data.
This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you. We also use consent as a legal basis in order to process your query when you contact us, provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Generally we will keep personal data until such time as you ask us to stop communications with you, unless we need to keep the data for longer;– we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute.
We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for about 10 years in order to comply with tax/VAT reporting requirements);
You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us on [email protected].
We will not accept any personal data from persons under the age of 16. We shall only accept the personal data of parents/guardians.
We do not, and will not, sell any of your personal data to any third party – including your name, email address or any other information you may provide to us.
However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out below:
In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.
We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.
If we ever have to share data with entities that are outside of the EU/EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.
YOUR RIGHTS
Before addressing any request you submit to us, we may first need to verify your identity. In all cases we will try to act on your requests as soon as reasonably practicable.
Your various rights at law include:
You may, at any time request us to confirm whether we are processing personal data that concerns You and, if we are, you shall have the right to access that personal data.
You have the right to ask us to correct inaccurate personal data and to complete incomplete personal data concerning you. We may seek to verify the accuracy of the data before correcting it.
You have the right to ask us to delete your personal data, however, this is not an absolute right.
Despite a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
You have the right to ask us to restrict (that is, store but not process further) your personal data but only where:
Following your request for restriction, except for storing your personal data, we may only process your personal data:
You have the right to move, copy or transfer your personal data from one organisation to another. If you wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). we can provide the personal data to you directly or, if you request, to another organisation.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
You have a right to object to our use of your personal data including where we use it for our legitimate interests or where we use your personal data to carry out profiling using automated means.
You also have the right to lodge complaints with the appropriate Data Protection Supervisory Authority. The Data Protection Supervisory Authority in Malta is the Office of the Information and Data Protection Commissioner (IDPC). The IDPC’s website can be accessed at https://idpc.org.mt/en/Pages/Home.aspx
We kindly ask that you please attempt to resolve any issues you may have with us first. we may be contacted by email on [email protected], and by post at Venturevate Limited, No. 8 Regent House, Office 25, Bisazza Street, Sliema, Malta.
Nevertheless, you have a right to contact the appropriate Data Protection Supervisory Authority at any time.
As one of the security measures we implement, before being in the position to help you exercise your rights as described above, we may need to verify your identity to ensure that we do not disclose to or share any personal data with any unauthorised individuals.
We try to reply to all legitimate requests within one month from receiving them. In some cases (for example, if the matter is particularly complex or if You send us multiple requests), it may take us longer than a month. In such cases, we will notify You accordingly and keep You updated.
We value your trust when you choose to provide us with your personal data. we are striving to use commercially acceptable means of protecting it. Remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
We may update this Privacy Policy from time to time. You are advised to review this page periodically for any changes. we shall notify you of any changes by posting the new Privacy Policy. These changes are effective immediately.
We are always happy to hear from you!
If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal data, please contact us:
By email on: [email protected]
By post at: Venturevate Limited, No. 8, Regent House, Office 25, Bisazza Street, Sliema, Malta
