Privacy Policy

Privacy Statement

We take your privacy seriously. This privacy statement explains how Surefun (collectively, "we," "us," or "our") collects, uses, shares, and processes your information.

Collection and Use of Personal Data

Personal data is information that can be used to directly or indirectly identify you. It also includes anonymous data that is linked to information capable of directly or indirectly identifying you. Personal data does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.

Promoting Safety and Security

We abide by the principles of legality, legitimacy, and transparency. We process the minimum amount of data necessary within a limited scope of purpose, implementing robust technical and administrative measures to protect your data. We use personal data to help verify accounts and user activity, and to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is based on our legitimate interest in helping ensure the safety of our products and services.

What Personal Data We Collect

1. Data You Provide:
We collect the personal data you provide when you use our products and services or otherwise interact with us, such as when you create an account, contact us, participate in an online survey, or use our online help or live chat tool. If you make a purchase, we collect personal data in connection with that transaction. This data includes payment information, such as your credit or debit card number and other card details, account and authentication credentials, and billing, shipping, and contact details.

2. Data About the Use of Our Services and Products:
When you visit our website or application, we may collect data about the type of device you use, your device's unique identifier, its IP address, your operating system, the type of Internet browser used, usage patterns, diagnostic details, and location information from or about the computers, phones, or other devices on which you access our products or services. Where available, our services may use GPS, your IP address, and other technologies to determine a device's approximate location to help us improve our offerings.

How We Use Your Personal Data

Generally speaking, we use personal data to provide, improve, and develop our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect ourselves and our customers.

• Providing, Improving, and Developing Our Products and Services: We use personal data to help us provide, improve, and develop our products, services, and advertising. This includes using data for purposes such as data analysis, research, and audits. Such processing is based on our legitimate interest in offering you products and services and for business continuity. If you enter a contest or other promotion, we may use the personal data you provide to administer those programs. Some of these activities have additional rules, which may contain further details about how we handle personal data; we encourage you to read those rules carefully before participating.
• Communicating with You: Subject to your prior express consent, we may use personal data to send you marketing communications regarding our own products and services, communicate with you about your account or transactions, and inform you about our policies and terms. If you no longer wish to receive email communications for marketing purposes, please contact us to opt-out. We also use your data to process and respond to your requests when you contact us. Subject to your prior express consent, we may share your personal data with third-party partners who may send you marketing communications regarding their products and services. Subject to your prior express consent, we may use personal data to personalize your experience with our products and services and on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.

Note: For any of the uses of your data described above that require your prior express consent, you may withdraw your consent at any time by contacting us directly.

Definition and Use of "Cookies"

Cookies are small pieces of text used to store information on web browsers. They are widely used to store and receive identifiers and other information on computers, phones, and other devices. We also use other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, for similar purposes. In this Cookie Statement, we refer to all of these technologies collectively as "cookies."

We use cookies to provide, protect, and improve our products and services, such as by personalizing content, offering and measuring advertisements, understanding user behavior, and providing a safer experience. Please note that the specific cookies we use may vary depending on the specific websites and services you access.

Disclosure of Personal Data

We make certain personal data available to strategic partners that work with us to provide our products and services or help us market to customers. Personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.

Data Disclosure, Storage, Transfer, and Processing

1. Fulfillment of Legal Obligations: Due to the mandatory laws of the European Economic Area or your country of residence, certain legal obligations must be fulfilled. This includes the processing and storage of personal data as required by law.
2. Corporate Transactions and Affiliates: We may share personal data with all our affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
3. Legal Compliance and Safety: We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, protect our operations, or safeguard our users. It may also be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data.

Your Rights

We take reasonable steps to ensure that your personal data is accurate, complete, and up to date. You have the right to access, correct, or delete the personal data that we collect. You are also entitled to restrict or object, at any time, to the further processing of your personal data. You have the right to receive your personal data in a structured and standard format. You may lodge a complaint with the competent data protection authority regarding the processing of your personal data.

To protect the privacy and security of your personal data, we may request details from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data we maintain. You may contact us to exercise your rights. We will respond to your request within a reasonable timeframe, and in any event within 30 days.

Third-Party Websites and Services

Our website, products, and services may contain links to or the ability for you to access third-party websites, products, and services. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their products and services contain. This Privacy Statement applies solely to data collected by us through our products and services. We highly encourage you to read the privacy policies of any third party before proceeding to use their websites, products, or services.

Data Security, Integrity, and Retention

We use reasonable technical, administrative, and physical security measures designed to safeguard and help prevent unauthorized access to your data, and to correctly use the data we collect. We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

Changes to this Privacy Statement

We may periodically change this Privacy Statement to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. Your continued use of our products and services after the effective date of the Privacy Statement means that you accept the revised version. If you do not agree to the revised Privacy Statement, please refrain from using our products or services and contact us to close any account you may have created.

Contact Information

If you have any questions or would like to contact us regarding our privacy practices, please reach out to us at:

Email: shop@surefun.com