Privacy Policy
Please review this Privacy Policy carefully. This Privacy Policy will inform you about the information we may collect from you, how we use or store it, the choices you have regarding our use of it, your ability to review and correct it and how to opt out from any of our services and/or from receiving any promotional material. The data we may collect may be personal information about you or by which you can be identified e.g. your full name, address (email and/or postal), mobile number/MSISDN (mobile station integrated services digital network number), date of birth, gender etc. (“Personal Information”). We may aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse service use, to improve our content and service offerings, and to customize our Web App (as defined below) content, layout and services, we may gather certain usage information like the number and frequency of visitors to our Web App (as defined below). This information may include your URL/internet protocol address, mobile device location, browser type, pages of service accessed. We only use such data in the aggregate. This aggregate data helps us to determine how often our customers use our Web App (as defined below) and do research and demographic analysis of our customers as well as their interests and behaviour, so that we can better understand and provide you with the best service. 
This Privacy Policy is supplemental to the terms and conditions for our service found at URL:   which form an integral part of this Privacy Policy.
Who We Are
Digital Virgo Solutions SAS, a company registered in France and having its registered office located at 17 rue du Sergent Bauchat - 75012 Paris, France (the “Company”). The Company, provides games content which is accessible on your mobile handset via the internet through our web application (the “Web App”), (the “Service”). This Service is sponsored by Zain Bahrain B.S.C. (a company registered in in accordance with the laws of the Kingdom of Bahrain, holder of commercial registration number 50603, whose registered office is at Zain Bahrain Tower, Building 401, Road 2806, Block 428, Seef District P.O. Box 266, Manama, Kingdom of Bahrain (hereinafter “Zain”).

Privacy Commitment
We understand and recognise the importance of safeguarding the Personal Information received from our customers and so we have formulated this Privacy Policy to reflect our commitment to maintaining the confidentiality of the Personal Information received from you via your selected Service. 
We respect your privacy, and we will handle your data in an ethical manner. We will also ensure that we are compliant with mandatory data protection and privacy laws, including, the governing laws in the Kingdom of Bahrain.
Information Collected and Used
You may obtain confirmation from us about the existence or non-existence of Personal Data and obtain such confirmation in an intelligible form.
Generally, you can access our Service without telling us who you are or revealing any of the Personal Information, although we may collect certain data about your visit to the Service to help us improve the Service quality. Before you are able to fully access any of the games content, the Web App or use the Service you will be required to subscribe to the Service via the Web App. 
We may gather the Personal Information to allow us to process your subscription to the Service, process any requests or payments you may make, administer your contract, process refunds, communicate with you, award prizes, and, subject to your consent, provide marketing or promotional materials and we may also collect the Personal Information so you can access the online Service, monitor your usage of our Service, and/or participation in online activities including reviews, testimonials or competitions, if any, or for other purposes outlined below. 
You may at any time withdraw your consent to us collecting some of the Personal Information or any other data you provided but this could limit your access to part of the Service.
Every time you visit the Service our system automatically recognises the mobile device type used to communicate with us (where possible). Individual users will remain anonymous unless you tell us who you are. 
Children and Minors
We do not knowingly collect or solicit Personal Information or other data from children and minors. Anyone under the age of 21 (twenty-one) will not be knowingly allowed to register for the Service. 
If you are under 21 (twenty-one), please do not attempt to register for the Service (or any part of it) or send any Personal Information or other data to us. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us immediately. In the event that we become aware or informed that we have collected Personal Information from anyone under the age of 21 (twenty-one) without verification of parental consent, we will promptly delete such Personal Information from our servers. 
Information to Third Parties
We will not rent, sell or share your Personal Information with other organisations or non-affiliated companies for commercial purposes unless you have expressly consented to this. 

However, by law or for regulatory reasons, we may have to reveal any Personal Information to certain third parties if required to investigate or deal with any complaints relating to you or your use of the Service. Your Personal Information may be revealed to other businesses within our group of companies and to reputable third parties who will help process your subscription to the Service if necessary such as our supply and service agents and data processors. 

If all or part of our business is sold, (whether by sale of shares or assets) or integrated with another business, your Personal Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Following completion of any such sale or transfer your Personal Information shall be disclosed to and transferred to such new owner or third party.
We do ask our third parties to confirm that their privacy practices are consistent with ours to ensure maximum protection of your privacy. A complete list of the companies responsible for the data processing can be requested directly from the Company.
Linking to third party sites
If our Service, Web App and/or Content contain a link to any websites outside of our control these websites are not under our control and we are not responsible for those websites or the conduct of companies who own or control those websites. Your use of those other websites is subject to any terms of use and/or privacy policies on those websites.
Your Consent
You agree to us collecting, using and processing your Personal Information as set out in this Privacy Policy. 
Presently, we can confirm that any Personal Information collected from you is stored on secure servers which are located or hosted in the Kingdom of Bahrain. However, due to the global nature of the internet infrastructure and our business, the Personal Information you provide you provide may be transferred in transit to countries outside the Kingdom of Bahrain to our affiliates and subsidiaries. The laws governing data protection in these countries or jurisdictions may differ from the laws in Kingdom of Bahrain. We will comply with all mandatory data protection and privacy laws in the Kingdom of Bahrain and take all steps reasonably necessary to ensure that similar and/or comparable standards for data protection are maintained by any our affiliates and subsidiaries which are recipients of your Personal Information. By your voluntary submission of information to us, you are consenting to the disclosure, transfer and use of your Personal Information outside of the Kingdom of Bahrain for the purposes described in this Privacy Policy. 
We will provide you with the exact information about the countries of the data importers upon your request.
Your Right to Opt-Out.
You have the right to cancel any of the Services at any time using any of the following ways: a) clicking on unsubscribe option in the footer of the Web App portal and following the instructions or b) TEXTING “Unsub” to 94443 or by calling the customer care team using the contact details noted below at the bottom of the Agreement;
Updating Your Information
If you wish to access, correct, update or receive a copy your Personal Information please use the contact details listed in the Contact Information section below. 
Withdrawal of Consent
You may at any time withdraw your consent or object (in whole or in part) to us collecting and further processing your Personal Information in accordance with this Privacy Policy by giving us written notice to us, please see the Contact Information section below. Upon receipt of the withdrawal notice we shall cease (and cause our third parties to cease) collecting, using or disclosing the Personal Information as the case may be unless such collection, use or disclosure, as the case may be, without your consent is required or authorised under applicable data protection laws or other written law.
Our Service uses ‘cookies’ to distinguish you from other users of our Service. A cookie is a small amount of data or parcels of text that is sent to your browser from a web server and stored on your mobile device’s hard drive, if you consented to this. Generally, a 'cookie' being a file in your web browser enables the website to recognise your mobile device when you visit the website. 
Cookies help us to enhance your experience when you access our Service and also allows us to improve it. We may obtain information about your general internet usage by using such cookie files which are stored on the browser of your mobile device type. Cookies contain information that is transferred to your mobile device type.
They enable us to: 
•    estimate our audience size and usage pattern. 
•    store information about your preferences, and so allow us to customise our site according to your individual interests. 
•    speed up your searches. 
•    recognise you when you return to our site. 
•    provide a more convenient browsing experience for you.
You may refuse to accept all cookies, reject all cookies, or modify your browser to alert you of any new cookies by activating these settings on your browser. However, if you select any of these settings you may be unable to access certain parts of the Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access our Service. Please note that our advertisers may also use cookies, over which we have no control.
To reject cookies or alter the access in any way, you can follow the instructions below to do so. Please always check for updated software instruction versions as to how to control cookies.
1.    Turn on your iPhone 
2.    Tap on "Settings." 
3.    Scroll down and select "Safari." 
4.    Swipe to the bottom and tap on "Clear Cookies." 
5.    When it asks you to confirm, tap on "Clear Cookies" 
6.    Delete any saved passwords
1.    Turn on your Android 
2.    Tap on your preferred "Browser." 
3.    Press the "Menu" button 
4.    Tap "More" and then "Settings." 
5.    Select "Privacy Settings" and tap on "Clear All Cookie Data." 
6.    When it asks you to confirm, click "Yes" 
You can also discover independent information about cookies by researching the internet or carrying out online searches. 


Security Statement
The security internal procedures are designed to cover the storage, access and disclosure of your Personal Information. We are committed to online security. We maintain security measures to protect the sensitive data via the Service and to prevent unauthorised access of customer information that is transmitted to our databases. We cannot however guarantee the security of any data sent over the internet. Details of our security policy and measures can be found below. 

This Security Statement explains how we store and safeguard the data we collect about you, and procedures that we have in place to safeguard your privacy generally. 

We always use industry-standard encryption technologies when transferring and receiving customer data exchanged with our Service. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of data that we have collected from you on our Service. Unfortunately, however, no data transmission over the internet can be guaranteed to be 100% secure. 
To prevent unauthorised access, maintain accuracy of our records and data to ensure proper use of data, we have put in place appropriate physical, electronic and managerial procedures to protect, secure and safeguard your Personal Information that we collect or on through our website.
The following provisions and arrangements are in place: 
1.    We have a management and corporate commitment to data security within the organisation and provide clear direction, guidance and responsibilities and procedures in this respect. 
2.    We have a designated or nominated compliance officer who deals with security of your Personal Information together with relevant compliance with the applicable data protection laws. 
3.    All employees are briefed on the importance of personal data and security and confidentiality of data obtained. Employees may attend training programmes and are provided with updates or practical guidance under the applicable data protection laws. 
4.    We control physical security in relation to your Personal Information that is contained at our facilities and restrict access to the site, buildings, computer rooms, office desk, technology areas, equipment and other facilities where unauthorised access by people could compromise our security. 
5.    All proprietary or confidential information, including your Personal Information, is contained or stored on computer and any that is contained and stored on manual files are locked up and secure. 
6.    We may seek to control access to your Personal Information, including existing procedures for authorising and authenticating users as well as software controls for restricting access and techniques for protecting data such as encryption. Encryption is used in connection with our payment facilities for customers, which ensures that any communications between your computer and ourselves is unreadable by anyone else. 
7.    We monitor and log access so as to assist in detection and investigation of security breaches and any attempted breaches where they occur. 
8.    We maintain a business continuity plan as a contingency plan which identifies our business functions and assets (including your Personal Information) which would need to be maintained in the event of disaster and set out the procedures for protecting and restoring them if necessary. 
9.    In respect of detection and investigation of breaches where they occur, we have in place relevant controls which should alert us to a breach in security. We endeavour to investigate every notified breach of security. 
10.    The Personal Information held by us are currently stored on a relevant technology system, mass email programme data base, individual account contact manager’s systems together with the training booking spread sheet, invoicing spread sheet, Excel spread sheets, paper form. 
11.    Our security measures are reviewed and updated from time to time. 
Changes to Our Privacy Policy
From time to time it may be necessary for us to review and revise our Privacy Policy. If we intend to change our Privacy Policy in a manner that directly affects the use, storage and/or disclosure of your Personal Information, then we will seek your consent to such changes before they become applicable to you. In all other circumstances, we reserve the right to change our Privacy Policy at any time and we may notify you about changes to this Privacy Policy by posting an updated version of the policy on our Web App. By continuing to access or use the Service after we have posted an updated Privacy Policy or have provided you with notice of any material modifications of the same you are agreeing to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you your only recourse is to cease using the Service.
Contact Information
If you have any questions, comments or concerns about concern about how we handle your Personal Information, please contact us using the details below:
+973 36107107 (toll free, some network providers may apply their own charges, please refer to them for rates).
You can unsubscribe at any time by:
a) SMS “Unsub” to 94443, b) clicking on “unsubscribe” option in the footer of the Web App portal and following the instructions or c) by calling our customer care team No: +973 36107107  
Update: last update March 2021