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Privacy Policy

General

This Privacy Policy, together with our Terms of Use, governs More Gamification’s collection, processing and use of your Personal Data. As used in this Privacy Policy, “More Gamification”, “we”, “us” or “our” refers to Morfin S.A.R.L. registered with the Luxembourg Trade and Companies Register under the number B228318, with its registered address at 8, op Bierg, L-8217, Mamer, and Diginesis SRL, registered within the Romania Companies Registrar under the number RO18866612, with its registered address at Henri Coandă 33A, Brașov, 500167, România. Morfin SARL  and Diginesis SRL are both data controllers under this Privacy Policy, which sets out the manner in which both companies, as data controller, may use your Personal Data.

“DP Law” means data protection law applicable to More Gamification, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts. Personal Data” has the meaning set forth in DP Law. This notice covers our use of your personal data arising from use of the More Gamification mobile application, website (www.moregamification.com) as well as registering / subscribing / buying / using our products and services. If you have any questions or need any further clarity please get in touch. Contact details are set out below in the Contact Us section.

In this Privacy Policy capitalised terms have the meaning set out in the Definitions section below.
More Gamification is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

  • The types of Personal Data we collect and how it may be used;
  • Our use of cookies and similar technology;
  • How and why we may disclose your Personal Data to third parties;
  • The transfer of your Personal Data within and outside of the European Economic Area (“EEA”);
  • Your statutory rights concerning your Personal Data;
  • The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Data; and
  • More Gamification’s retention of your Personal Data.

User Roles

A. Member

As a registered user on the More Gamification Mobile Application, when you join a community and add it to your dashboard you become a member of that community and can take part on challenges posted in it.

B. Community Administrator

As a registered user on the More Gamification Mobile Application, when you create a new community you become a Community Administrator and you can post challenges for the members and manage members. (accept members or exclude them from the community)

C. Shop Administrator

As a registered user on the More Gamification Mobile Application, when you create a shop you become a Shop Administrator. As a shop user you can join communities to offer products and services against tokens.

Collection and Use of Personal Information and User Created Data

A. Personal Information and User Created Data (content) We Collect

Content and data/information submitted by users to More Gamification are referred to in this policy as “Content”. For instance Content can be: any data and content created with the platform tools like the Scenario Designer, uploaded directly(such as files),  or otherwise made available by Community Administrators through the Morfin platform (www.morfin.io) administration interfaces, and any data and content by Community Administrators and Community Members including text, photos, sounds, music, videos, audiovisual combinations, interactive features, profile information and anything else entered or uploaded onto the More Gamification Mobile Application or Morfin Platform (www.morfin.io).

As a More Gamification Mobile Application member, you may join communities or participate in challenges in which the Community Administrators request for Personal Data. Community Administrators are required to adhere to our Privacy Policy and take the same measures in protecting Personal Data of their Members as More Gamification would its users. That said we suggest caution joining a community which is not verified by More Gamification. All the challenges, tasks and actions from any communities can be audited to provide transparency to all the users in regards to the processing of personal information.

We collect the Personal Data you provide directly to us or which we generate when you open a More Gamification Account, perform any tasks and challenges on the More Gamification Mobile Application, win rewards, redeem rewards, or use other More Gamification Services or our website. This may include:

  • Contact information, such as name, home address, and email address, phone number. In order to prevent certain type of  fraud we rely on phone numbers instead of usernames, so the phone number is used for security reasons and to prevent fraud. Your name is requested but not verified and home address and email address are optional and required only for certain application features – such as delivery of rewards, account recovery, orders confirmation and so on. No marketing emails or SMSs will be send by More Gamification or any community administrators.
  • Account information, such as password, account settings, avatar and preferences: account information generally consist in points, achievements, token balance, coupons, all of them are created only when the user participates to challenges, tasks as a member of a community. Passwords are encrypted one way (cannot be decrypted).
  • Geolocation information: in case a challenge or a task require location for validation of the task or action we take the location via phone GPS or bluetooth beacon with user consent. The location is not saved and the user is not tracked.
  • Fitness activity information: if a task or a challenge requires the number of steps or to measure activities such as biking we the application will ask for that information from the phone sensors or from the operating system services with the user consent. This information is used only in the context of the challenge or task.
  • Billing information: we limit the information collected here to the legal requirements. This is applicable just to the users that are purchasing products and services inside the platform for instance community administrators with premium subscriptions.
  • Information regarding the way in which you use our services, such as when you used our services and the specific services used; and
  • Information relating to communications with us, whether through the More Gamification website or via e-mail, over the phone or via any other medium.

We also automatically collect certain computer, device and browsing information when you access the More Gamification website or use More Gamification Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

  • Computer or mobile device information, including IP address, operating system, network system, browser type and settings;
  • Website usage information.
  • Location information
B. Use of Cookies and Similar Technology

The More Gamification website is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Site. The information collected from cookies allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Site by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or services. Your use of our website or service with a browser that is configure to accept cookies constitutes an acceptance of our and third-party cookies.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or Services.

C. How We Use Your Personal Information

We collect and use your information for a variety of reasons. We need some information to enter into and perform a contract/subscription – for example your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers’ identities – especially for community administrators and community owners to try the best in protecting community members from different types of fraud by the community owners.

Some information is processed because you’ve given your consent to that, which can be withdrawn inside the mobile application.

We may use your Personal Information to:

  • Create and administer your More Gamification account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract), and for compliance with legal obligations to which we are subject;
  • Process your token transactions on the platform.
  • The user generated contest may be used for : maintain and improve More Gamification services. Prevent or address service, security, technical issues or at a Community Administrator’s or Member’s request in connection with customer support matters. To comply with the law.
  • Your content created in the context of a community might be removed by the community administrator if it does not comply with the community rules or with the community code of conduct. For example it’s offensive or inappropriate.
  • Personalise your More Gamification Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our services);
  • Analyse More Gamification website usage, and improve our website and website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our services);
  • Analyse More Gamification Mobile Application usage, and improve our application and offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our services);
  • Help us respond to your customer service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience);
  • Contact you about More Gamification Services. The email address you provide may be used to communicate information and updates related to your use of the More Gamification Services.
Automated Decisions Making

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.

If you disagree with the decision you are entitled to contest this by contacting us at following email address: info@moregamification.com

D. Marketing

We may also occasionally communicate company news, updates, promotions and related information relating to similar products and services provided by More Gamification. We may also administer a contest, promotion, survey or other site features as will be more explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under DP Law in pursuit of our legitimate interests (that is, promoting our services).

We may share personal data with third parties to help us with our marketing and promotional projects, or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from us (or our promotional partners) in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:

  • Log into your account and update your profile.
  • Click “unsubscribe” at the bottom of an email we sent you.
  • Contact us at info@moregamification.com to opt-out.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you reserve from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.

Disclosing and Transferring Personal Data

There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

  • We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this Privacy Policy;
  • We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function;
  • We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.

Your personal data may be transferred to other third party organizations in certain scenarios:

  • If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
  • If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;
  • If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
  • If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide More Gamification Services or as required by law.

More Gamification’s third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms complying with DP Law.

B. Disclosures to Legal Authorities

We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:

  • Compelled by court order, or other legal procedure.
  • Disclosure is necessary to report suspected illegal activity.
  • Disclosure is necessary to investigate violations of this Privacy Policy or Terms of Use
C. International Transfers of Personal Data

We store and process your Personal Data in data centers around the world, wherever More Gamification facilities or service providers are located. As such, we may transfer your Personal Data outside of the European Union. Some of the countries to which your personal data may be transferred for these purposes that are located outside the EU do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal data in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under DP Law will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.

Your Statutory Rights

You have certain rights concerning your Personal Data under DP Law as mentioned below, and can exercise them by contacting us at  info@moregamification.com

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it to check that we are lawfully processing it. We process a large quantity of information, and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.

Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.

Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

If you are a community owner, you are also entitled to request us to remove communities created in our app. All associated data, including shop transactions, member activity, inputs, and assets will be deleted. Please note that the community members will remain app users until they decide to opt-out.

Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: you may request the transfer of certain of your personal data to another party.

Objection: where we are processing your personal data based on a legitimate interests (or those of a third party) you may challenge this. However we may be entitled to continue processing your information based on the our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place. In Luxembourg you can make a complaint to the Luxembourg data protection authority (Commission nationale pour la protection des données, Tel: 00352 26 10 60 1 or at www.cnpd.public.lu).

Security of Personal Data

We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

  • Password protected directories and databases;
  • Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely;
  • PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized More Gamification personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by More Gamification. If you do receive a suspicious request, do not provide your information and report it by contacting one our member service representatives as set in this Privacy Policy.

You are responsible for keeping your account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorized use or any other breach of security involving your information, you must notify us below as soon as possible.

Retention of Personal Data

We retain Personal Data for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. The criteria we may use to determine the retention period for certain categories of data includes:

  • How long you have been a More Gamification member;
  • Whether there are contractual or legal obligations that exist that require us to retain the data for a certain period of time;
  • Whether there is any ongoing legal or financial claim that relates to your relationship with us;
  • Whether any applicable law, statute, or regulation allows for a specific retention period; and
  • What the expectation for retention was at the time the data was provided to us.

In accordance with our record keeping obligations, we will retain Account and other Personal Data for at least five years (and some up to ten years, as required by applicable law) after an Account is closed.

Updates to this Privacy Policy

This Privacy Policy was last revised effective April 19 2024. We may change this Privacy Policy from time to time, so it is advisable to review it frequently. Changes to this Privacy Policy will be announced on our website or through similar means for a reasonable length of time prior to and following the change taking effect.

Definitions

Account. The contractual arrangement wherein a More Gamification member has accepted our Terms of Use and Privacy Policy, and received approval to use the More Gamification Services, including the purchase and sale of tokens and other digital assets, make payments, use debit cards and to perform associated Transactions;

Morfin Platform. Hardware and software technologies used by More Gamification to provide the More Gamification Service as set out in our Terms of Use;

DP Law. means data protection law applicable to More Gamification, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts as well as equivalent legislation, which is applies to the processing of Personal Data by More Gamification.

Personal Data. Information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. Personal Data does not include anonymized and/or aggregated data that does not identify a specific user;

Service(s). The technological platform, functional rules and market managed by More Gamification to permit its users to perform purchase and sale transactions of tokens, currency exchange and use of debit cards.

Transaction. Includes the following:

  • The agreement between buyers and the sellers to exchange tokens through the Service for currencies at a commonly agreed rate;
  • The conversion of currencies into virtual currencies deposited by members on their account;
  • The transfer of currencies and virtual currencies among members;
  • Payments via SEPA transfer or via debit cards
  • The transfer of currencies among members; and
  • The purchase of ancillary products.

Contact Us

Please contact us with questions, comments, or concerns regarding our Privacy Policy and/or practices at info@moregamification.com

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