Phoneum Apps and Games Terms of Service

Last updated: May 5th, 2021

LEGAL DISCLAIMER

1.) Risks related to the use of the Phoneum Applications and Games.
Phoneum will not be responsible for any losses, damages or claims arising from events falling within the scope of the following categories:
a.) Mistakes made by the user of any cryptocurrency-related software or service, e.g., forgotten pins, payments sent to wrong coin addresses, accidental deletion of wallets, and/or forgetting to back up private keys.
b.) Software problems of the applications, wallets and/or any cryptocurrency-related software service, e.g., corrupted wallet file, incorrectly constructed transactions, unsafe cryptographic libraries, malware affecting the applications, wallet and/or any cryptocurrency-related software or service.
c.) Technical failures in the hardware of the user of any cryptocurrency-related software service, e.g., data loss due to a faulty or damaged storage device.
d.) Security problems experienced by the user of any cryptocurrency-related software service, e.g., unauthorized access to users' applications, wallets and/or accounts.
e.) Actions or inactions of third parties and/or events experienced by third parties, e.g., the bankruptcy of service providers, information security attacks on service providers, and fraud conducted by third parties.

2.) Compliance with tax obligations
- The users of the applications are solely responsible to determinate what, if any, taxes apply to their crypto-currency transactions. The owners of, or contributors to, the wallet are NOT responsible for determining the taxes that apply to cryptocurrency transactions.

3.) No Warranties
- The applications are provided on an "as is" basis without any warranties of any kind regarding the applications and/or any content, data, materials and/or services provided on the applications.

4.) Wallet Data Security
- The owners of, or contributors to, the wallet do not retain access at any time of the pin code, as well as the private keys entered or created by the cryptocurrency-related software. Instead, the information is encrypted and stored on the devices' storage with a well-known recommended method, Advanced Encryption Standard (AES). AES uses substitution–permutation network to encrypt user’s data with a key. Using this approach, it replaces bytes from one table with the bytes from another, and as such creates permutations of data.

5.) Limitation of liability
- Unless otherwise required by law, in no event shall the owners of, or contributors to, the applications be liable for any damages of any kind, including, but not limited to, loss of profits, or loss of data arising out of or in any way connected with the use of the applications. In no way are the owners of, or contributors to, the applications responsible for the actions, decisions, or other behavior taken or not taken by users in reliance upon the applications.

6.) Arbitration
- The user of the applications agrees to arbitrate any dispute arising from or in connection with the applications or this disclaimer, except for disputes related to copyrights, logos, trademarks, trade names, trade secrets or patents.

SECURITY POLICY

The intent of this Security policy is to protect the information assets of the organization and users, the main objective followed by is to establish and maintain adequate and effective security measures for the users to ensure that the confidentiality, integrity and operational availability of information is not compromised.
Sensitive information must therefore be protected from unauthorized disclosure modification, access, use destruction or delay in service.
Each user has a duty and responsibility to comply with the information protection policies and procedures described in this document

1.) Purpose
- The purpose of this policy is to safeguard information belonging to Phoneum within a secure environment.
This policy informs Phoneum user and staff authorized to use Phoneum applications of the principles governing the retention use and disposal of information.

2.) Scope
-This policy applies to all user who use Phoneum applications or work with documents or information that concerns customers or any other partner for whom the organization has collected information in the normal course of its business.

3.) Goals and Objectives Followed:
The goals and objectives followed of this policy are:
- Protect information from unauthorized access or misuse
- Ensure the confidentiality of information
- Maintain the integrity of information
- Maintain the availability of information systems and information for service delivery
- Comply with regulatory, contractual and legal requirements.
- Maintain physical, logical, environmental and communications security
- Dispose of information in an appropriate and secure manner when it is no longer in use
Which include deletion of all the information on a user’s account if requested by the user itself, providing information regarding his account. For the process to start the user needs to open a ticket through the application which the account is registered to.

Steps:
a. Open the application.
b. Open the menu from the side bar.
c. Press Contact Support.
d. Ask for deletion of the account
e. Approve that you want your account to be permanently deleted.

4.) Access Control
The fundamental element of this security policy is the control of access to critical information resources that require protection against unauthorized disclosure or modification. Access control refers to the permissions assigned to persons or systems that are authorized to access specific resources. Access controls exist at different layers of the system including the network. Access control is implemented by username and password. At the application and database level, other access control methods can be implemented to further restrict access. All access to the database is limited and only staff with specific privileges can access that information in order to assist the user. Also, historical data on the account to be reviewed by the staff for clearing out misunderstandings or occurred issues.

5.) Account Control
For each of our applications a user can own only one account associated with each app/game. If a user own multiple accounts he will be subject to a ban on all associated accounts.

6.) Security System
As businesses, we need to be ever vigilant to ensure we are one step ahead of cyber threats and secure our data, technology, and networks from increasing threats. Our cyber security policy can provide a comprehensive and proactive response to threats of this nature that can be shared with our organization. As such if our system detects any violation the account detected will be permanently suspended. You will be able to open a ticket to our support team for an engineer to review the case ([email protected]). Upon reviewing the account and the final decision is that the account will be kept suspended all communication will be suspended, as such you may not get a reply on our follow up email.
Phoneum does not guarantee a bug-free environment, as such in cases where the user account is suspended by a bug related reason, the account will be reviewed by the companies’ engineers and it will be re-enabled, only when it is confirmed that it is a bug related issue.

DEPOSITS POLICY

1.) Deposits:
- All deposits made to our applications have to deposit Phoneum (PHT-TRC10). All deposits containing a different token other than PHT will not be processed and cannot be restored after the deposit process is done.

REFUND POLICY

Thanks for purchasing our products from our applications operated by Phoneum.
We offer a full money back guarantee on all purchases made in our applications, but under certain conditions. We invite you to read the conditions explained in more detail below, in order to see the condition that applies to your situation, while following the correct procedure.
After the three-day period, we cannot offer you a refund or exchange.
To be eligible for a refund or exchange, all products must be unused. The purchase can also be eligible for a refund if it was uncredited to the account.
If You have any further questions or would like to request a refund, please do not hesitate to contact us at [email protected]

Refunds (if applicable)
For the refund process to take place you need to provide us with the following information:
a. The e-mail address linked to your account in the application
b. The e-mail associated with the purchasing account (i.e., Google Play Account)
c. The order number for the purchase (It will start with “GPA”)
d. What you purchased and how much you paid
e. Reason for refund
Please provide the information above only if it is applicable with the refund reason.

Refunds on payments that did not go through
If a purchase was made and it was either declined or cancelled, the payment will be invalid, and there will be no need for a refund, as the payment will not go through and will be back in your bank account, between three to five business days, depending on your bank and region.

GDPR data protection policy

1. Introduction
Phoneum is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.
This policy details expected behaviors of Phoneum’s Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a Phoneum’s Customers and Staff (i.e., the Data Subject) and irrespective of the media used to store the information.
Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organizations may process Personal Data.
An organization that handles personal data and makes decisions about its use is known as a Data Controller. Phoneum, as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy.
Non-compliance may expose Phoneum to complaints, regulatory action, fines and/or reputational damage.
Phoneum’s leadership is fully committed to ensuring continued and effective implementation of this policy and expects all Phoneum Employees and Third Parties to share in this commitment.
Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

2. Scope

2.1. This policy applies to all Phoneum Entities where a Data Subject’s personal data is processed:
- in the context of the business activities of the Phoneum Entity
- for the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) by Phoneum
- to actively monitor the behavior of individuals.

2.2. Monitoring the behavior of individuals includes using data processing techniques such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to:
- taking a decision about them
- analyzing or predicting their personal preferences, behaviors and attitudes.

2.3. This policy applies to all processing of personal data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals.

2.4. This policy has been designed to establish a baseline standard for the processing and protection of personal data by all Phoneum Employees. Where national law imposes a requirement that is stricter than that imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to.

2.5. The protection of personal data belonging to Phoneum Employees is not within the scope of this policy.

2.6. The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines. The DPO within our company is Ivan Likov, email for correspondence [email protected]

2.7. Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR, or if you have any concerns that this Privacy Standard is not being or has not been followed. You must always contact the DPO in the following circumstances:
- if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company)
- if you need to rely on Consent and/or need to capture Explicit Consent
- if you need to draft Privacy Notices or Fair Processing Notices
- if you are unsure about the retention period for the Personal Data being Processed
- if you are unsure about what security or other measures you need to implement to protect Personal Data
- if there has been a Personal Data Breach
- if you are unsure on what basis to transfer Personal Data outside the EEA
- if you need any assistance dealing with any rights invoked by a Data Subject
whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA or plan to use Personal Data for purposes others than what it was collected for if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making if you need help complying with applicable law when carrying out direct marketing activities; or
- if you need help with any contracts or other areas in relation to sharing Personal Data with Third Parties (including our vendors).

3. Policy

3.1. Governance
3.1.1. Policy Dissemination and Enforcement
The management team of Phoneum must ensure that all Phoneum Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. In addition, Phoneum will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e., their Data Processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by Phoneum.

3.1.2. Data Protection by Design
To ensure that all Data Protection requirements are identified and addressed when designing new systems or processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing.
Phoneum must ensure that a Data Protection Impact Assessment (DPIA) is conducted, for all new and/or revised systems or processes for which it has responsibility. Phoneum should consult with a Data Protection subject matter expert during completing the DPIA. The subsequent findings of the DPIA must then be submitted to the senior risk office for Phoneum for review and approval. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will cooperate with the Data Protection subject matter expert to assess the impact of any new technology uses on the security of Personal Data.

3.1.3. Compliance Monitoring
To confirm that an adequate level of compliance is being achieved by Phoneum in relation to this policy, Phoneum will carry out an annual Data Protection compliance audit. Each audit will, as a minimum, assess compliance with this policy and the operational practices in relation to the protection of Personal Data, including:
- the assignment of responsibilities
- raising awareness
- training of Employees
- adequacy of organizational and technical controls to protect Personal Data
- records management procedures (including data minimization)
- adherence to the qualified rights of the Data Subject
- Privacy by Design and Default
- consent for direct marketing
- Personal Data transfers
- Personal Data incident management (including Personal Data breaches)
- Personal Data complaints handling
- the currency of Data Protection policies and Privacy Notices
- the accuracy of Personal Data being stored
- the conformity of Data Processor activities
- the adequacy of procedures for redressing poor compliance.
Any major deficiencies identified will be reported to and monitored by Phoneum Executive Management team.

3.2. Principles

3.2.1. Data Protection
Phoneum has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data.
PRINCIPLE DEFINITION
PRINCIPLE 1: Lawfulness, Fairness and Transparency Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, Phoneum must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).
PRINCIPLE 2: Purpose Limitation Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means Phoneum must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.
PRINCIPLE 3: Data Minimization Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means Phoneum must not store any Personal Data beyond what is strictly required.
PRINCIPLE 4: Accuracy Personal Data shall be accurate and kept up to date. This means Phoneum must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.
PRINCIPLE 5: Storage Limitation Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means Phoneum must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.
PRINCIPLE 6: Integrity & Confidentiality Personal Data shall be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful Processing, and against accidental loss, destruction or damage. Phoneum must use appropriate technical and organizational measures to ensure the integrity and confidentiality of Personal Data are always maintained.

3.2.2. Accountability
The Data Controller shall be responsible for, and be able to demonstrate, compliance. This means Phoneum must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.

3.3. Data Collection
Personal Data should be collected only from the Data Subject unless one of the following applies:
- The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.
- The collection must be carried out under emergency circumstances in order to protect the vital interests of the Data Subject or to prevent serious loss or injury to another person.
- If Personal Data is collected from someone other than the Data Subject, the Data Subject must be informed of the collection unless one of the following apply:
- the Data Subject has received the required information by other means
- the information must remain confidential due to a professional secrecy obligation
- a national law expressly provides for the collection, Processing or transfer of the Personal Data.
Where it has been determined that notification to a Data Subject is required, notification should occur promptly, but in no case later than: 30 days for the Data Collector to provide the requested information from a user.