Privacy Policy

PRIVACY POLICY

This Privacy Notice for Carmin Studios Limited (doing business as Carmin Studios) describes how and why we might access, collect, store, use, and/or share (‘process’) your personal information when you use our Services, including when you:

•  Visit our website at http://www.carminstudios.com or any website of ours that links to this Privacy Notice.

•  Download and use our mobile application (Carmin Studios) or our Facebook application (Carmin Studios), or any other application of ours that links to this Privacy Notice.

•  Use our Roblox Development Services — a service where people pay us to build their Roblox games or custom-made assets.

•  Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@carminstudios.com.

SUMMARY OF KEY POINTS

What personal information do we process? We may process personal information depending on how you interact with us, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some information may be considered ‘special’ or ‘sensitive’ in certain jurisdictions. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. No electronic transmission over the internet can be guaranteed 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? Submit a data subject access request or contact us. We will consider and act upon any request in accordance with applicable data protection laws.

1.  WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include:

•  Names

•  Phone numbers

•  Email addresses

•  Mailing addresses

•  Job titles

•  Contact preferences

•  Billing addresses

•  Debit/credit card numbers

•  Contact or authentication data

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

•  Social security numbers or other government identifiers

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Collected via Facebook Application

We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes.

2.  HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for the following purposes:

•  To deliver and facilitate delivery of services to the user — to provide you with the requested service.

•  To fulfil and manage your orders — to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

•  To protect our Services — as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

•   To save or protect an individual’s vital interest — when necessary to save or protect an individual’s vital interest, such as to prevent harm.

•  Confirm Identity — to make sure the user is who they claim to be.

3.  WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law.

If you are located in the EU or UK

The GDPR and UK GDPR require us to explain the valid legal bases we rely on:

•  Consent — We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.

•  Performance of a Contract — We may process your personal information when necessary to fulfil our contractual obligations to you.

•  Legitimate Interests — We may process your information when reasonably necessary to achieve our legitimate business interests, e.g. to diagnose problems and/or prevent fraudulent activities.

•   Legal Obligations — Where necessary for compliance with our legal obligations, such as cooperating with a law enforcement body or regulatory agency.

•  Vital Interests — Where necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada

We may process your information if you have given us specific permission (express consent) or where consent can be inferred (implied consent). You can withdraw your consent at any time. In exceptional cases, we may process without consent, such as for fraud detection, business transactions, legal compliance, matters of vital interest, or where information is publicly available.

4.  WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may need to share your personal information in the following situations:

•  Business Transfers — We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition.

•  Affiliates — We may share your information with our affiliates, requiring them to honour this Privacy Notice.

•  Business Partners — We may share your information with our business partners to offer you certain products, services, or promotions.

5.  HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law. No purpose in this notice will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or securely store it in isolation until deletion is possible.

6.  HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security.

Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7.  DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect, solicit data from, or market to children under 18 years of age (or the equivalent age as specified by law in your jurisdiction), nor do we knowingly sell such personal information.

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

To report concerns, contact us at: contact@carminstudios.com

8.  WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your state of residence in the US or in some regions such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In regions like the EEA, UK, Switzerland, and Canada, these rights include:

•  Right to request access and obtain a copy of your personal information

•  Right to request rectification or erasure

•  Right to restrict the processing of your personal information

•  Right to data portability (if applicable)

•  Right not to be subject to automated decision-making

•  Right to object to the processing of your personal information

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided below. This will not affect the lawfulness of processing before withdrawal.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in emails we send, or by

contacting us using the details provided below.

For questions about your privacy rights, email: contact@carminstudios.com

9.  CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track (‘DNT’) feature you can activate to signal your privacy preference. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

10.  DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you.

Categories of Personal Information Collected (Past 12 Months)

We will use and retain the collected personal information as needed to provide the Services, with specific retention periods: Categories A, B, E, K, L — 1 year; Category I — 6 months.

Your Rights

You have rights under certain US state data protection laws, including:

•  Right to know whether or not we are processing your personal data

•  Right to access your personal data

•  Right to correct inaccuracies in your personal data

•  Right to request the deletion of your personal data

•  Right to obtain a copy of the personal data you previously shared with us

•  Right to non-discrimination for exercising your rights

•  Right to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling

How to Exercise Your Rights

To exercise these rights, submit a data subject access request or email us at contact@carminstudios.com. We will need to verify your identity before processing your request. You may also designate an authorised agent to make a request on your behalf.

If your appeal is denied, you may submit a complaint to your state attorney general.

11.  DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. This Privacy Notice satisfies the notice requirements defined in both Privacy Acts.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with how we address any complaint, you can contact the Information Regulator (South Africa) at enquiries@inforegulator.org.za.

12.  DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated ‘Revised’ date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

13.  HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, please contact us:

Carmin Studios Limited

Email: contact@carminstudios.com Website: http://www.carminstudios.com

14.  HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request, or contact us at contact@carminstudios.com.