Privacy Policy

For Children's Privacy, see Section 5

Welcome to Gabro!

Gabro Games is headquartered in Cork, Ireland. This privacy policy describes the different ways we may collect, use, and share information on, through, or in connection with the Gabro Services (see "What are the Gabro Services?" below). If you have any questions, you can always reach out to us as described in "Contact Us" below.

When we refer to "Gabro" (or any similar terms like "we" or "us") in this privacy policy, we mean the Gabro Games entity that controls and is responsible for your information, including Gabro Games and its subsidiaries that help provide and support the Gabro Services. You can also find details about the data controller for personal information we collect through different Gabro Services in "Contact Us" below.

1. What Are the Gabro Services?

We use the term "Gabro Services" to describe any Gabro products or services that directly link to this privacy policy. These include, for example:

Apps like the Gabro desktop app;
Websites and applications such as www.gabrogames.com and gabrodb.com;
Live events where this privacy policy is posted.

Note that your use of the Gabro Services may also be subject to additional terms and conditions. For example, signing up for a Gabro account may require you to read and accept an End User License Agreement in order to login and host games using the Gabro app.

Please read this entire privacy policy. You should also carefully review any other agreements that apply to the Gabro Services you use, and confirm you understand and agree to them, before using those products or services.

2. What Information Do We Collect?

The types of information we collect depend on how you interact with us. Generally speaking, we collect information in three main ways: A) when you provide it to us, B) automatically when you use the Gabro Services, and C) from service providers and third parties.

A. Information You Provide

You can provide us with different kinds of information depending on how you interact with the Gabro Services. Sometimes we'll ask you to provide specific pieces of information, such as when we require it to provide parts of the Gabro Services to you (for example, by prompting you to complete an online registration process). If we ask you to provide us with information in these cases and you choose not to, you may not be able to access the Gabro Services and/or some features may not operate as intended.

For instance, in order to join games using the Gabro app, you'll need a Gabro account. To create one, you'll need to provide us with basic registration information like a public-facing display name, password and email address. If you want to make a purchase, we may ask you to provide payment-related information (like your credit card number and expiration date) to complete the transaction. In addition, many of our services require your date of birth to determine which features we can offer you and which settings to apply to your account based on your age and location.

We also collect the information you voluntarily provide to sign up for email alerts, use social features like forums or chat, register for early access to our games and services, enable two-factor authentication, register for or attend our events, complete surveys, or contact us through Player Support requests or customer service. If you enter a contest or competitive event we'll collect your application information and other information we may need to help confirm your eligibility and process rewards. We collect whatever information you choose to provide to us in those or other similar cases.

B. Information We Collect Automatically

We collect some information automatically when you visit, access, or use the Gabro Services. This includes information about your gameplay or application usage, purchases, entitlements, and other activity in the Gabro Services, that are typically associated with your account (if you are logged into your Gabro account or use a third-party account to access the Gabro Services) or with an identifier we have assigned to your device or profile. While the specific types of information that we automatically collect may vary, they generally include:

Usage information and statistics about how you interact with the Gabro Services, including the application you used, how long you used it and when, what games you joined or hosted, progression and results, saved preferences, crash reports, the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, and platform type;
Technical information about your computer, device, hardware, or software you use to access our services, such as IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and
The general location of your device, which we typically derive from your device's IP address.

The Gabro Services use technologies such as cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools that may be stored on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the Gabro Services. For example, they support our ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics.

Please note that if certain features on the Gabro Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Gabro Services, their services, or others' websites over time. For example, when you use Gabro Services (like the Gabro app) to access software made by a third party, those third-party providers may collect information through their technology. These features are subject to those third parties' privacy notices and policies.

C. Information We Collect from Other Sources

In some cases, we may also receive information about you from service providers and third parties in connection with your use of the Gabro Services or your interactions with us on other platforms.

You can buy, download, or access some Gabro Services on or through services operated by third parties. If you do, they may provide us with information to facilitate your access to and use of the Gabro Services. This typically includes information like your display name, user ID, and device and region information.

D. Fraud Prevention & Anti-Cheat

We believe cheating is not resolved with restrictions but clarity. Cheating is allowed but only in-game. In cases where cheating is allowed it is to be performed exclusively in a game server hosted with a Gabro account — the account owner must clearly label the server as a "cheating server".

However, we strictly enforce prohibitions against undisclosed cheating or hacking of any kind directed at Gabro's services. For example, if a user hosts a game server with the Gabro app and tells users who join that they can cheat in-game using an automated aim assistant, but fails to disclose that in the server or Gabro community title, they are in breach of this agreement.

Cheating or hacking outside of the game server context is strictly forbidden. For example, trying to circumvent Gabro's protections on game servers that prevent users from accessing the underlying machine is forbidden.

This kind of cheating or hacking outside the game server context includes hacking, account stealing, and any other unauthorized or fraudulent activity on the Gabro Services. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and may be provided by Gabro or by service providers.

3. How Do We Use Information?

As a general matter, we use the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and promote the Gabro Services. This includes using it for purposes such as:

Creating, verifying, and managing user accounts and features;
Providing the Gabro Services, as well as support and assistance for them, including by responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates);
Developing, delivering, and improving the Gabro Services and other offerings, some of which may be offered in partnership with other parties;
Personalizing your experience, including by presenting content or features better tailored to you or your interests, or our inferences about your interests;
Promoting the Gabro Services, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events;
Managing alpha, beta, or early access tests (and collecting feedback);
Conducting data analytics (like analyzing how the Gabro Services are used so we can better understand, improve, and personalize them);
Complying with our legal or contractual obligations and enforcing our terms;
Securing the Gabro Services, such as by detecting fraud and otherwise protecting Gabro and other users from illegal or harmful actions; and
Improving technologies or processes used to accomplish these purposes (like training machine learning models used to help detect or moderate toxic, illegal, or harmful content or conduct and enforce our terms and policies like our Community Rules).

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.

4. How Do We Share Information?

We may share some of the information we collect to help operate and improve the Gabro Services. Depending on how you interact with us, common examples might include sharing:

With console and platform partners (for example, to facilitate gameplay when you access the Gabro Services through a third-party console provider);
With other game developers (such as to enable features for games you host through the Gabro app);
With other users (like if you use social features such as chat);
Publicly (for example, your display name, content you create or share, basic game statistics, and other similar information may be generally accessible to others);
With service providers that operate on our behalf to help support the Gabro Services in accordance with our instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners);
When we believe we must in order to comply with the law or to protect you, Gabro, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);
With other Gabro entities (including to help provide support for the Gabro Services internationally);
In connection with certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant part of our business);
With your permission (for example, if you link external accounts with your Gabro account, or participate in cross-promotional events); and
We may also share information that does not identify you with third parties, including aggregate or de-identified information.

No mobile phone numbers provided to Gabro for security purposes will be shared with third parties or affiliates for marketing or promotional purposes.

To the extent that we share your personal information with third parties, we endeavor to ensure these third parties provide the same or substantially similar protections as those that Gabro describes in this privacy policy.

Third parties you interact with through Gabro Services may have different privacy practices than Gabro, so we encourage you to review their privacy policies before sharing your information with them.

5. Children's Privacy

The information below is for parents and guardians to understand our privacy practices with respect to children (under 13 or the age of digital consent in the user's region, whichever is higher).

When a user indicates that they are a child, they are placed in a "Restricted Account" until they are no longer a child as defined above or until their parent or guardian provides additional privacy permissions. Restricted Accounts cannot host or play on Gabro Games. Gabro collects limited personal information from Restricted Accounts to operate them, in each case according to applicable youth privacy and protection laws:

User email address for sign-in; and
Persistent identifiers like IP address, account IDs, device identifiers, and similar data collected with website tracking technologies to provide and maintain the Gabro Services (including analytics to improve them), protect the security and integrity of users, ensure legal and regulatory compliance, and facilitate in-game personalization such as game advancement and avatar choice.

If a user with a Restricted Account contacts us with a question or request, any personal information provided will be deleted after the inquiry is resolved. When we share personal information from Restricted Accounts externally, it is to help us carry out these limited purposes (like sharing with mobile devices to provide account information).

This privacy policy will be updated to reflect any changes made to Restricted Accounts and children's permission to host or join games using the Gabro app.

6. Your Choices and Controls

We seek to provide you with meaningful choices about the personal information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as the Gabro Services you use. Common examples include:

You can request that we provide access to, or that we correct or delete, personal information we've collected from you. Please submit requests to access, update, or delete personal information associated with your Gabro account by reaching out to us as described in "Contact Us" below. Note that we may ask you for additional information to help us verify who you are before completing your request.
If applicable, you may also have the option to appeal or otherwise request human review of decisions made by automated means.
You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the Gabro Services not to work as intended and some features may not be available.

Some parts of the world provide individuals with specific choices related to their personal information by right under local law.

7. Retention

Because the specific personal information we process and our reasons for doing so often vary depending on how you use the Gabro Services, how long we retain it can also vary. We generally store personal information for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless a longer retention period is required or permitted by law.

The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of information in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the information is required to prevent fraud or similar abuse of the Gabro Services (including to enforce prohibitions against hacking and other unauthorized behavior). For example, if you create a Gabro account, we will generally store the personal information associated with your Gabro account for as long as needed to maintain your account, provide the Gabro Services you requested, enforce any terms that apply and govern your use of the Gabro Services, and maintain appropriate records to reflect how we deliver the Gabro Services to you.

To learn more about requesting that Gabro delete your personal data, please see "Your Choices and Controls" above.

8. Security

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected. If we become aware of unauthorized disclosure of your personal information, we will notify you as required by law and take steps to help secure your information.

9. Updates

We'll update this policy from time to time to reflect changes in our practices or relevant laws. When we do, we'll change the date noted at the top of the policy. In some cases, we may also notify you of the relevant changes by email or within the Gabro Services. Please review this policy regularly to make sure that you understand your relationship with Gabro and the ways we may collect, use, and share information in connection with the Gabro Services.

10. Our Global Operations

Gabro Games is based in Ireland, but we operate globally to help provide users all around the world with a better experience on the Gabro Services. We have subsidiaries, offices, service providers, and partners worldwide to support these operations in a number of different ways — for example, one of our service providers AWS is based in the United States. This means that Gabro may process the information we collect in connection with your use of the Gabro Services in places outside the region where you reside.

A. Data Transfers

When you use the Gabro Services, your information may be transferred to or stored in Ireland or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you're authorizing Gabro to process your information in any of the locations where we operate (including Ireland) by using the Gabro Services.

Gabro does not sell personal data it collects or process it for targeted advertising. Gabro also does not profile its users through automated means to make decisions that have legal or similarly significant effects. This includes for users for whom we have actual knowledge are under 18.

For more information on (1) the categories of personal data processed by us, please see "What Information Do We Collect?" above; (2) our processing of sensitive data from a known child under the age of 13, please see "Children's Privacy" above; (3) our purposes for processing personal data, please see "How Do We Use Information?" above; and (4) the categories of third parties with whom we share personal data and the categories of personal data we shared, please see "How Do We Share Information?" above.

B. Exercising Your Privacy Rights

To exercise your privacy rights, use one of the methods listed in the "Contact Us" section below. Only you may submit a verifiable request, which must include enough information for us to confirm your identity and understand the request. If you have a Gabro Games account, we may ask you to log in to verify your identity. Appeals can be submitted using the same contact methods listed in the "Contact Us" section below.

We will not discriminate against you for exercising any of your privacy rights under applicable law.

C. Residents of the European Economic Area, the United Kingdom, and Switzerland

If you're located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

You may have the right to access, correct, or delete personal data we have collected about you through the Gabro Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. If applicable, you can request human review or contest decisions made by automated means. Where you have provided your consent to our data processing, you have the right to withdraw consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the "Contact Us" section below to learn more about reaching out to Gabro with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

EEA: European Data Protection Authorities
UK: Information Commissioner's Office
Switzerland: Federal Data Protection and Information Commissioner

Basis for Processing

The legal bases we rely on to process your personal data depend on the Gabro Services you use and how you interact with them. They primarily include:

Contractual Necessity: We process personal data to perform the Gabro Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Gabro Services; detect and prevent fraud, hacking, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require us to share your information with third-party partners; and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.
Legitimate Interests: We process personal data as needed for Gabro's business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you'd reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Gabro Services and other offerings; manage and customize advertisements or promotional offers; manage purchases; secure and protect the Gabro Services; support auditing, data analysis, and other legitimate business operations; and prevent or moderate fraudulent, toxic, harmful, or illegal content or conduct that breaches our terms.
Legal Obligations: We process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes; to identify or moderate illegal content or conduct on the Gabro Services; or processing date of birth to facilitate compliance with applicable youth protection laws.
Consent: We process personal data when you provide us with your consent to do so. You aren't required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.

11. Contact Us

If you have questions or concerns about Gabro Services (such as game-related issues, trouble accessing your Gabro account, bugs or other technical problems, payment matters, or content and entitlement issues), please contact our Player Support teams:

Data Controller: Gabro Games
Data Protection Officer: support@gabrogames.com