Last updated February 16, 2017
store and use the information collected about you online on our websites
and mobile platforms, during your use of our products and/or services.
Developer and its subsidiary companies respect the privacy rights of Users
and recognize the importance of protecting the information collected. By
collection, storage, use and disclosure of your personal information as
If you have any questions or concerns, please contact our Support Team at
Zotobi Management Limited and its owned or controlled subsidiaries and
affiliates may be collectively referred to herein as «Developer», «we», or
«our», as the context requires. Zotobi Management Limited is a developer
and publisher of social games for the web and mobile devices. By using
thespellbox.com websites, Developer’s applications, or any of the related
understanding that Developer may process your data in accordance with this
SITES OR APPLICATIONS. If you access our games from a third party Social
Networking Site («SNS»), you may be required to also read and accept the
2. Information We Collect
2.1. Developer collects both personal and non-personal User information.
Personal information is information that identifies you and that may be
used to contact you on-line or off-line.
Developer may collect personal information from our online Users during:
- Registration for games;
- Registration for Developer's and/or other service accounts;
- User support and/or technical service requests;
- Player match up and other head-to-head online competitions and/or special
- Contest registration and prize acceptance;
- Creation of a personal profile;
- Access to our products and/or services on social networks or other third
- Otherwise through use of our software, mobile or online service where
personal information is required for use and/or participation.
- Information collected will vary depending upon the activity and may include
your name, email address, phone number, home address, birth date, mobile
phone number and credit card information. You can choose not to provide
(when such opportunity is provided) certain information, but then you might
not be able to take advantage of many of our features.
2.2. Non-personal information, alone, cannot be used to identify or contact
you. Developer collects non-personal information about your use of our
online and mobile products and services both on our websites and in the
course of game play and software usage.
When you use Developer's online and mobile products and services, we may
collect certain non-personal information including gender, zip code,
information about your computer, hardware, software, platform, game system,
media, mobile device, including device IDs, incident data, Internet
Protocol (IP) address and other information.
When you browse certain portions of the Service, we may automatically
collect and record standard user information and clickstream data about
analysis of the use of the Service. For example, when you visit or request
a web page from our server, we may record the IP address of the user’s
machine, the time, date and URL of the request and information about the
browser being used, and other information regarding the visit, such as the
pages visited on the Service, the time spent on each page, any
advertisements clicked and any search terms used (collectively «Log Data»).
2.3. When you use any Developer's game at an SNS such as Facebook or Google
+, you allow Developer to access certain information from you profile for
that site. The information you allow Developer to access varies by game and
SNS, and it is affected by the privacy settings you establish at the SNS.
You can control and find out more about these settings at the SNS where you
play our game. By playing a Developer's game through an SNS, you are
authorizing Developer to collect, store, and use in accordance with this
provide to Developer through the SNS Application Programming Interface.
Your agreement takes place when you «accept» or «allow» (or similar terms)
one of our applications on an SNS.
3. Where We Store Your Information
Developer stores information about you on servers located in the United
States. Personal data collected within the European Union may be
transferred to, and stored at, a destination outside the European Union.
Data we collect may also be processed by staff operating outside the US and
the EU who works for us or for one of our suppliers. By submitting your
personal data, you agree to this transfer, storing or processing. We will
take all steps reasonably necessary to ensure that your data is treated
4. How Developer Uses Information Collected
Developer uses your information only as follows:
- To provide our products and services to you and fulfill your specific
- To send you messages about our products and services, new products,
features, enhancements, special offers, upgrade opportunities, contests and
events of interest;
- To enable user-to-user communications;
- To better understand the behavior and preferences of our Users, to
troubleshoot technical problems, to deliver advertising, for the purposes
of proper functioning of our products and services and improving them;
- To improve our software and services by providing experiences and
recommendations, language and location customization, personalized help and
5. How We Disclose Information Collected
We disclose your information to third parties, that is parties other than
Developer, in the following circumstances:
- 5.1. We may share your information with subsidiaries and affiliates that we
own or control, but only if those entities are either subject to this
- 5.2. From time to time Developer's employs third party contractors to
collect personal information on our behalf to provide email delivery,
product, prize or promotional fulfillment, contest administration, credit
card processing, shipping or other services on our sites. We ask some third
party contractors, such as credit agencies, data analytics or market
research firms, to supplement personal information that you provide to us
for our own studies. When our third party agents or service providers
collect and/or have access to any information other than non-personal,
anonymous and/or aggregated data, Developer requires that they use data
consistently with our stated privacy policies and protect the
confidentiality of personal information they collect or have access to in
the course of their engagement by Developer. These third parties are
prohibited from using your personal information for any other purpose
without your specific consent.
- 5.3. The Service supports and may encourage interaction among players. Your
SNS friends may see your name, profile photo and descriptions of your game
activity, your game profile. Other players may also be able to send you
game requests or even friend requests through the related SNS’s
- 5.4. Developer may share aggregated information (information about you and
other users collectively), anonymous information and certain technical
information (including IP Addresses, MAC Addresses for mobile devices and
mobile device IDs) to develop and deliver targeted advertising in the
service and on the websites of third parties. We may also allow advertisers
to collect this information within the Service and they may share it with
- 5.5. We reserve the right to disclose your information when we believe
release is appropriate to comply with the law, judicial proceedings, court
order or other legal process; enforce or apply our Terms of Service and
other agreements; or protect the rights, property, or safety of Developer,
our employees, our users, or others. This includes exchanging information
with other companies and organizations for fraud protection and credit risk
- 5.6. In the event that Developer undergoes a business transition, such as a
merger, acquisition by another company, or sale of all or a portion of its
assets, we may transfer all of your information, including personal
information, to the successor organization in such transition.
Developer does not sell products for purchase by children and does not
knowingly collect personal information from children. If you are under age
of 13, you may use our Sites only with the involvement of a parent or
7. How Does Developer Protect Your Information?
Developer understands the importance of keeping your information safe and
secure. Developer will make commercially reasonable precautions to protect
your personal information and ensure the security of our systems. However,
there is no 100% secure method of transmission over the Internet or method
of electronic storage. We cannot assume responsibility or liability for
unauthorized access to our servers and systems. It is important for you to
protect against unauthorized access to your password and to your computer.
Be sure to sign off when finished using a shared computer. We strongly
recommend that you implement measures to protect your computer from
unauthorized access such as firewall protection and anti-virus software.
8. How You Can Access and Update Your Information
- 8.1. You can correct or update your account information at any time by
logging on our sites and navigating to different account settings. Should
you be unable to log in or wish to have your account(s) deactivated, you
may send an e-mail to our Support Team at firstname.lastname@example.org. You can
put «Delete my Account» or «Update my information» in the subject line and
include your first name, last name, e-mail address and user ID number (if
applicable) in the body of the e-mail. We will be happy to review, update
or remove information as appropriate. We may still retain your information
in our files however, to resolve disputes, enforce our user agreement, and
due to technical and legal requirements and constraints related to the
security, integrity and operation of our websites.
- 8.2. If you have granted Developer access to your SNS account information
through a Developer's application, you may manage the information Developer
receives about you from an SNS. For this purpose you will need to follow
the instructions at that site for updating your information and changing
your privacy settings.
- 8.3. You also may have the right (subject to certain exceptions to be given
a copy of certain data that Developer may hold about you (and for which we
may charge a small fee to process) and to have any inaccuracies in the data
that Developer holds about you corrected and/or erased. You may exercise
any such rights by emailing our Support Team at email@example.com. We
will need sufficient information from you to establish you identity and to
verify your access request, and also to assist us in handling your request.
Requests will be processed as soon as possible and not later than 40 days.
9. Terms of Service and Notices
- 9.1. If you choose to visit a Site, your visit and any dispute over privacy
is subject to this Policy and our Terms of Service. If you have any
concerns about your privacy, please contact us with a thorough description
or your question or concern via the postal addresses or email address in
notify you and other users by placing a notice on www.thespellbox.com or by
sending you a notice to the email address we have on file for you. We may
supplement this process by placing notices in our games and on other
Developer websites. You should periodically check www.thespellbox.com and
11. Contact Us
11.1. If you have any questions about the privacy aspects of our products
or services, or would like to make a complaint having to do with a privacy
matter, please send a written request as follows:
Zotobi Management Limited
Attention: Data Privacy
Office No. 309, 3rd Floor, Building No. 1, Dubai Internet City,
PO Box 500213, Dubai, United Arab Emirates.
Support team: firstname.lastname@example.org