Effective Date: April 25, 2022
Updated on: April 25, 2022
Thank you for using RELEXA!
- The ways we collect and store your personal data and why we do so,
- How we use and disclose your personal data, and
- The choices you have about your personal data.
RELEXA publishes, distributes and sells Platform including but not limited to applications, games and meditation products for mobile devices and websites.
2. The Data We Collect and How We Collect It
(a) Data You Provide Us
Summary of the section – RELEXA will collect and store any data that you provide to us, including when you create your account.
For using our Platform, you may be asked to give us the following:
- Information regarding your first and last name;
- Information regarding your username;
- Information regarding your gender;
- Information regarding your age or birthday;
- Information regarding your e-mail address;
- Information regarding a password;
- Information regarding your profile photo;
- Information regarding the approximate physical location data that you provide;
- Information regarding links to your profiles on various social networks;
- Information regarding other data that helps us make sure it’s you accessing your account or helps us improve our Platform.
- Information regarding your mobile telephone number (including for SMS text messaging services)
In most cases, we also create a RELEXA specific ID for you when you use the Platform.
(b) Data Collected While Using Our Platform
Summary of the section – RELEXA will collect data in connection with the ways you use and interact with our Platform.
When you use our Platform, we will collect data in connection with the ways in which you use and interact with our Platform, such as:
- playing our games,
- using our game features,
- using our applications,
- using our meditation products,
- interaction with other users,
- any purchases made on the Platform by you,
- data related to levels or progress you achieve in the Platform.
RELEXA will collect data communicated or shared by you in case you opt to use communication features in RELEXA’s Platform that may allow you to communicate or share data with other users. This may include:
- data related to your participation in user forums and message boards;
- data related to your public posts or gameboards or comments on other users’ profiles;
- data related to any invitations sent to other users or non-public messages, made on our websites directly or through our in-app mechanisms;
- any data related to your chats with other users on RELEXA’s Platform; and/or
- data related to your posted photos, drawings, or other user-generated content.
RELEXA has the right to access in real-time, record, and/or store archives of the above collected data on RELEXA’s servers to make use of them for:
- protecting your well-being and safety;
- protecting RELEXA Platform’s rights and property;
- conducting research; operating, improving, personalizing, and optimizing RELEXA’s Platform and your experiences, including through the use of analytics; and
- managing and delivering advertising.
We will seek your prior consent on the above, wherever prior consent is required by law.
(c) Data Collected From Payments Made By You
Summary of the section – We will collect data related to any purchases you make.
All the billing and financial data in connection with any purchases made on our Platform including our website and app shops such as Google Play or iTunes will be collected by our third-party payment processor. They will collect the data to process charges for the payments made. The data collected by them may include
- data related to your postal address,
- data related to e-mail address, and
- financial data.
No financial data like credit card numbers is shared with RELEXA by RELEXA’s payment processors, however, they may share any non-financial data with us related to your purchases, like:
- your name,
- billing address, and
- the items purchased.
- your name,
- approximate physical location, and
- the items purchased.
The data RELEXA receives depends on the RELEXA Platform you’re using and the third-party application. Our policies and terms related to charges, billing, third-party credits, and virtual currencies are described in detail in RELEXA’s Terms and Conditions.
(d) Data Collected From Customer Support Communication
Summary of the section – RELEXA will keep a record of any communication between you and RELEXA.
RELEXA is always there to provide help through our Customer Support team. When you contact our Customer Support team, our team will collect and store the data you provide such as:
- information regarding your name and e-mail address,
- data about your activity on our Platform, and
- information regarding your user ID and/or social network ID number.
For providing support and improving the Platform, RELEXA will also store all the communications you may have with our Customer Service team and further any additional data in such communications.
(e) Data We Collect From Third-Party Applications, Including Social Networks
Summary of the section – RELEXA will collect data from other companies, including social networks, if you access our Platform through your accounts with those companies or you choose to connect your accounts with those companies to our Platform.
RELEXA will allow log in to our Platform through sign-in services such as Facebook Connect. These services may pre-populate our sign-up form, authenticate your identity information, provide an option to share personal information such as your name and email address with us. Platform like Facebook Connect may give you the option to post information about your activities on our Platform or to your profile page to share with others within your network. RELEXA Platform may receive certain additional data about you from the provider of the third-party application, if you use RELEXA’s Platform on connected third-party applications or connect our Platform to any third-party applications, including social networks like Facebook. All the data received by RELEXA depends on the RELEXA’s service you’re using, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application.
Indicatively, RELEXA may collect and store the following from connected third-party application:
- data in connection with your first and last name;
- data in connection with your profile picture or its URL;
- data in connection with your user identification number (like your Facebook ID number), which may be linked to publicly-available data like your name and profile photo;
- data in connection with your friends’ user ID numbers and other public data;
- data in connection with the e-mail address you provided to that third-party application;
- data in connection with your approximate physical location and that of the devices you use to access our Platform;
- data in connection with your gender, your birthday, age, and/or age range;
- data in connection with your activities on or through the connected third-party application;
- data in connection with other publicly-available data on the third-party application; and/or
- data in connection with any other data that you or the provider of the third-party application share with RELEXA.
If you are unclear about what data a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.
(f) Cookies and Other Data Collection
Summary of the section – RELEXA will collect data about your device and how you use our Platform, including using cookies and other similar technologies.
- IP address;
- Information regarding devices used by you such as mobile or computer devices;
- platform type (such as Apple iOS or Android);
- Information regarding version of your operating system;
- Information regarding your mobile device’s identifiers, for example Apple Identifier For Advertising (IDFA), your MAC Address, and/or Android Advertising ID (AAID);
- Information regarding de-bugging data and application performance;
- Information regarding your language and browser type;
- Information regarding URLs, and referring and exit pages;
- Information regarding website page and/or the number of clicks on an application feature or website page;
- Information regarding the amount of time spent by you on an application feature or web page;
- Information regarding domain names;
- Information regarding landing pages;
- Information regarding pages viewed and the order of those pages; and/or
- Information regarding game state and the date and time of activity on our Platform.
RELEXA may connect, in some cases, the above data with your social network or RELEXA user ID.
In addition to your mobile device identifiers as described above, RELEXA may also collect additional data if you use RELEXA’s Platform on a mobile device, such data can be as follows:
- Data regarding the username associated with your device;
- Data regarding the country you belong to;
- Data regarding your telephone or mobile number;
- Data regarding your specific geo-location which will be taken with your permission;
- Data regarding your mobile contacts which will be taken with your permission; and/or
- Data regarding the RELEXA’s Platform and other third-party apps you have on your device.
For understanding how to adjust your preferences, please see the section on How to Access, Update, and Manage Your Personal Data.
(g) Data About Your Contacts
Summary of the section – RELEXA will collect data that you provide to us about your contacts, provided you have sought their permission first.
RELEXA’s Platform may provide you the facility to import your address book contacts or to manually feed them so that you can locate your contacts and RELEXA will also provide an opportunity to invite them to join you on our Platform. You agree that you will responsible for seeking requisite permission from your contacts’ before you give their contact data to us. RELEXA may also receive data about you from other RELEXA’s users importing or entering their contacts. In order to ensure that you and your contacts connect through our Platform, we may use and store this contact data. Please contact us at email@example.com in case you want to remove your contacts stored by us by following instructions provided in the Platform and request that we remove the contacts from our systems. We will not store any password which allows us to access your address book.
(h) Other Sources
Summary of the section – RELEXA may also collect data from other third-party sources. In case any such data is collected by us, we will let you know accordingly.
RELEXA may use other sources such as third party data providers for collecting or receiving data about you and this data along with the data provided by you may be used inter alia to help you and your friends connect or to make your advertising needs more tailored to your interests.
(i) Data Submitted Via Platform
Summary of the section – RELEXA will use the content of any communications submitted by you.
For purposes included but not limited to developing, manufacturing, and/or marketing goods or the RELEXA Platform, RELEXA may use the content of any interactions or communications submitted by you on RELEXA Platform, including any concepts, inventions, ideas, techniques, or know-how disclosed therein.
RELEXA will keep your name confidential and will not publicize or advertise the fact that you submitted materials or other information to us unless:
(a) a permission is granted by you to us;
(b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or
(c) we are required to do so by law.
3. Why Do We Collect Your Data and How We Use it Including Legal Bases
Summary of the section – RELEXA uses your data to provide, personalize, maintain the security of, and improve the Platform you use. We also use it for maintaining our business operations and for exercising, defending or establishing our rights.
RELEXA uses your data under several legal bases, including for performing our contract with you, for RELEXA’s legitimate business interests, for complying with our legal obligations, or otherwise we use it with your consent.
The collected and stored data may be used:
- for improving and enhancing our Platform;
- for creating your account and allowing you to use our Platform;
- for identifying and suggesting connections with other RELEXA users and personalizing our Platform to you;
- for communicating with you and informing you about the Platform you are using, including in-game updates, new services including any new meditation products, and promotional offers that we think might be of interest to you;
- for enabling users to communicate with each other;
- for providing any technical support and for responding to your concerns or inquiries;
- for protecting your safety;
- for protecting RELEXA’s rights and property in connection with our Platform;
- for preventing fraud or potentially illegal activities, and for enforcing our Terms of Service;
- for managing and delivering contextual and behavioral advertising;
- for administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- for complying with our legal obligations, resolving any disputes we may have with you or other users, and for enforcing our agreements with third parties; and/or
- for conducting research including marketing research.
If you are located in the European Countries (as defined above in Section 1), our legal basis for collecting and using the data described above depends on what the data is and the context in which we collect it.
However, we will normally collect data from you only where we need it to perform our contract with you (i.e., our Terms of Service), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if we otherwise have your consent.
In some cases, we may also have a legal obligation or need to collect data from you or may otherwise need the personal data to protect your vital interests or those of another person (for example, another user).
If we ask you to provide data to comply with a legal requirement or to perform a contract with you, this will be clear from the context in which we are asking you to provide your data (for example, when we ask you to provide a username to access our Platform, this will be to create an account for you in accordance with our Terms of Service), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing data is mandatory.
Similarly, if we collect and use your data in connection with our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and marketing, etc.).
4. How We Share Your Data
Summary of the section – RELEXA will share your data with third parties when you use our Platform under the circumstances described in this section.
We may share your data, including personal data, with third parties or allow third parties to collect this data from our Platform in the following circumstances:
(a) Friends and Other RELEXA Users
Summary of the section – RELEXA will share some of your data with your friends and other RELEXA users to facilitate your interactions with them.
RELEXA’s Platform support and often encourage you to interact with other users. In most RELEXA Platform, if you use a social network or connect to a social network (for example, Facebook), your social network friends who also use a RELEXA service will see your name, photo, user profile (which may include the data described above in Data About You That You Share With Us Directly), and descriptions of your activity.
In addition, in many RELEXA Platform, other users, regardless of whether they are your social network friends, will be able to:
- see your profile (as described above);
- view descriptions of your activity;
- communicate with you within our Platform; and
- send you game requests or friend requests through our Platform or the related social network.
(b) Third-Party Advertising Including Behavioral Advertising and Analytics
Summary of the section – RELEXA will share some of your data with advertisers to tailor the advertisements you see when you use our Platform to your interests and to enable us to offer some of our Platform for free.
RELEXA uses advertising for offering some portions of the Platform for free. These may include, without limitation, banner advertisements on game boards or on the Platform itself, as full-screen advertisements between games or moves, or through an “offer wall” in which third-party advertisers may offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, or completing a survey, or finishing a particular level in the game. RELEXA does not host any Offer walls and no offers are made by RELEXA. Hosting of Offer walls is done by third-party offer wall providers, and all the offers are made by third-party advertisers,
Unless your consent is received, RELEXA does not share personal data that directly identifies you with third-party advertisers for their direct marketing purposes.
Following information may be shared when our Platform is used for enabling advertisers, advertisement networks, and offer wall providers to serve you with more relevant ads. They may collect, or we may collect and share with them:
- information regarding performance data such as the number of clicks in ads;
- information regarding technical data such as your IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID;
- information regarding a unique identifier, such as your social network or RELEXA User ID; and/or
- information regarding any other contextual data about your game play such as your level.
The data may also be additionally used for:
- measuring the effectiveness of ads;
- offering targeted advertising on and off RELEXA’s Platform for personalizing your experience by showing you advertisements for products and services that are more likely to appeal to you. Such a practice is already known as interest-based advertising or behavioral advertising;
- undertaking web analytics for analyzing traffic and other user activity to improve your experience.
On clicking a third-party advertisement or offer, please note that you may no longer be on a site or application controlled by RELEXA or the social network through which you are playing RELEXA’s games.
(c) Safety, Security, and Compliance with Law
Summary of the section – RELEXA will share your data if necessary for safety, security, or compliance with law.
RELEXA may access and monitor all your data including contents of all of your online communications in our Platform and between you and RELEXA for providing our Service. RELEXA may further disclose your data:
- for satisfying any laws or regulations that may apply;
- when RELEXA has a good faith belief that we have to disclose the data in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes;
- when RELEXA believes in its sole discretion that its Platform is being used for committing a crime. We may report such criminal activity or share your data with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when RELEXA has a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
- for protecting the rights or property of RELEXA or applicable third parties, including for enforcing our Terms of Service.
(d) Third-Party Service Providers
Summary of the section – RELEXA will share your data with the third-party service providers and business partners that we work with to bring you our Platform.
RELEXA may share your data with third-party companies who may perform following on our behalf, such as
- services related to payment processing,
- services related to analytics,
- services related to analysis,
- services related to hosting,
- services related to customer support,
- services related to marketing, and
- services related to advertising optimization.
We will also share your data with our third-party business partners who assist us in delivering and optimizing our Platform, such as our platform partners (Apple, Google, Facebook, Amazon, etc.). We ensure that we have appropriate agreements in place to protect your data as required by applicable data protection laws especially wherever we share your data with third-party service providers and business partners.
(e) Sale or Merger
Summary of the section – RELEXA will share your data with the interested party if we undergo or evaluate undergoing a sale or merger.
(f) Other Third Parties
Summary of the section – RELEXA may share some of your data with other third parties if we have your consent to do so.
5. Your Rights and How to Access, Update, and Manage Your Personal Data
(a) European Countries’ Users’ Rights
Summary of the section – If you are a user located in the European Countries, you have certain rights with respect to your personal data.
If you are located in the European Countries (defined above in Section 1), you have the following data protection rights:
- You can access or request deletion of your personal data by submitting a request to us at firstname.lastname@example.org.
- You can correct or update your personal data, object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
- You can opt-out of marketing communications we send you by following the instructions in “Opting Out of Promotional Communications from RELEXA” below.
- If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal data. For more data, please contact your local data protection authority. (Contact details are available here.)
To exercise your rights to access or deletion, please submit a request to us at email@example.com. If you have any other problems or would like to exercise any of your other rights, you can contact us at firstname.lastname@example.org. We respond to all data protection requests we receive in accordance with applicable data protection laws.
(b) Accessing and Deleting Personal Data Held by RELEXA
Summary of the section – You can request a copy of or deletion of your RELEXA account data by submitting a request to us at email@example.com
To review and update personal data associated with your RELEXA user profile in certain games, visit the “settings” page in that game.
If you want to review or delete personal data associated with your game account data, please submit a request to us at firstname.lastname@example.org.
For deletion requests, we will take reasonable measures to delete your personal data from our records. If you have sent content through or posted content on the Platform, we may not be able to delete it. We will keep certain records (e.g., personal data relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We will also keep data in order to exercise, defend, or establish our rights.
(c) Managing Personal Data We Receive From Third-Party Applications / Platforms And From Your Mobile Device
Summary of the section – To manage the data we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by the third-party application and your mobile device.
To manage the data RELEXA receives about you from a third-party application or platform where you use our Platform, like Facebook, Apple, Google, or Amazon, you will need to follow the third-party application’s instructions for updating your data and changing your privacy settings.
You also can manage many aspects of data collection and use from your mobile device by visiting the “settings” page of your mobile device or web browser and reviewing the access permissions of each RELEXA Service.
To the extent that one of our Platform is collecting data about non-RELEXA applications you have on your mobile device, the Service will provide you with an option to stop making that data available to us in the game’s “settings” page.
(d) Opting Out of Promotional Communications from RELEXA
Summary of the section – You can unsubscribe from promotional emails by clicking the “unsubscribe” link or visiting our Email Settings page. You can opt out of mobile push notifications in your device’s settings page. You can opt out of SMS text communications by texting STOP.
If you want to stop receiving promotional e-mails from RELEXA, click on the “unsubscribe” link at the bottom of any promotional email from RELEXA or visit our Email Settings page. Your unsubscribe request or e-mail preferences change will be processed promptly, and in no event longer than ten business days. During that processing period, you may receive additional promotional emails from us.
If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our Platform also offer the ability to turn off push notifications in the in-game “settings” page.
You can opt out of receiving SMS text messages by texting back STOP to the number we send the text from for that particular SMS text messaging program or by contacting us at email@example.com. When we receive an opt-out message from you for SMS text messages, we may send a text message confirming receipt.
(e) Opting Out of Third-Party Behavioral Advertising
Summary of the section – You can opt out of third-party behavioral advertising through your device settings and other third-party opt-out tools.
If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for behavioral advertising.
All of the opt-out tools described in this subsection are provided by third parties, not by RELEXA. RELEXA does not control or operate these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive third-party advertisements in RELEXA’s Platform after using these opt-out tools, but the advertising you see may be less relevant to your interests.
6. California Online Privacy Protection Act Notice
Summary of the section – RELEXA does not respond to Do Not Track signals.
At this time, there is no general agreement on how companies like RELEXA should interpret Do Not Track signals. RELEXA does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
7. Privacy Policies of Linked Third-Party Platform and Advertisers
Summary of the section – RELEXA is not responsible for the ways in which third parties use your data (other than our service providers acting under our instructions).
Our Platform may contain advertisements from “Third-Party Services,” meaning companies other than RELEXA that may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your data, you should review their policies and contact them directly.
8. Our Policies Concerning Children
Summary of the section – RELEXA seeks to ensure that we do not collect data from children.
Most of our Platform are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Platform, and we do not knowingly collect any personal data from Children.
Though our Platform do not target Children as the primary audience, we may collect age data before allowing a user to proceed for certain Platform. For users who identify themselves as Children in our age-gate on such Platform, if we allow Children to use the Platform, we will either provide a version of that Service that does not collect, use, or disclose “personal data” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.
If we learn that we have inadvertently gathered personal data that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that data from our records.
9. International Operations and Transfers Out of European Countries
Summary of the section – When you use our Platform, your personal data may be sent to the United States and possibly other countries. When we transfer, store, and use personal data collected in the European Countries outside of the European Countries, we comply with our legal obligations and ensure that your personal data is subject to suitable safeguards or transferred to “approved” territories.
IMPORTANT: When you use our Platform, your personal data may be sent to the United States and possibly other countries.
As part of our international operations, we may transfer personal data to our “Affiliated Entities,” which are any other corporate entities under common ownership with RELEXA, or to our business partners and service providers from time to time for our legitimate business purposes. For example, RELEXA provides certain services to its Affiliated Entities.
We store personal data about you and visitors to our sites on servers located in the United States, and we may also store this data on servers and equipment in other countries. Personal data collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details, or (ii) the provision of support services.
When we transfer your personal data internationally we will take reasonable steps to ensure that your personal data is treated securely, lawfully, and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your data is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.
10. Data Retention
Summary of the section – RELEXA will keep your data for as long as necessary to provide you with the Platform, maintain our legitimate business operations, and/or exercise, defend or establish our rights.
How long we retain your personal data depends on why we collected it and how we use it, but we will not retain your personal data for longer than is necessary for our business purposes or for legal requirements.
We will retain personal data about you and connected with your account and/or the Platform you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal data if you delete your account. However, you acknowledge that we may retain some data after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
11. Security of Your Data
Summary of the section – RELEXA works hard to protect your data but you also have a role to play.
If you have an account registered directly with RELEXA, your profile data is protected by the password you use to access your RELEXA account. It is important that you protect and maintain your RELEXA account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your RELEXA account, the Platform allow you to request that instructions be sent to you that explain how to reset your password. If you access our Platform through a social network and your social network account is hacked or otherwise compromised, this may lead to someone accessing or deleting your RELEXA accounts without your permission. So, be careful to keep your social network account data, including your social network account password, secure as well. We urge you to log out of your RELEXA account and any social network account you have used to access our Platform when you are finished using them.
When you sign into your RELEXA account or enter payment data, we and our third-party payment processor use encryption to transmit that data.
While we take precautions against possible security breaches of our Platform and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your data while it is being transmitted to our Service. Any transmission is at your own risk.
12. Contact Us
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we request you to contact us so that we can reply to you more swiftly and efficiently.
Name of the Controller: RELEXA LLC
Address: 1309 Coffeen Avenue STE 1200, Sheridan, Wyoming 82801, USA