SPIL Games BV (hereafter referred to as "SPIL"), is dedicated to protecting the privacy of our users and handling any personal date we obtain from our users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.
1.1 Our Websites offer a diverse, and exciting mix of online games created by SPIL, as well as games created by independent developers and SPIL partners. Players can access our Websites to play games without registering; however, they may choose to register to create a public or private profile and to save games, high scores, and comments on this profile. Also, visitors to the Websites will be able to rate games and browse for the newly added, top-rated, and most-popular games. The Websites may include automated decision making in the form of behavioral advertising.
1.2 Certain games on our Websites are controlled by third parties, including third parties located outside of the European Economic Area (“EEA”). SPIL’s own hosting facilities for the Websites are located within the EEA. SPIL uses commercially reasonable efforts to ensure that any data processing that takes place on the Websites is in line with the applicable data protection laws. Privacy safeguards we take are contractual safeguards with third parties and the employment of technical privacy solutions, such as monitoring and blocking tools. However, as we do not control all games, data may be collected and transferred of which we are not aware. If you have concerns about data processing in a game, please send an e-mail to firstname.lastname@example.org stating your concerns and the URL of the games.
2.1 SPIL collects information when you use or access our Websites. This information relates to how you use our websites including with what device, and may include information that you submit when creating an account with us or through your social network accounts such as Facebook or Google+. We may also collect information from ad network providers and other third parties such as payment service providers.
The information we may collect when you use our Websites includes (among others) the following:
IP address, Cookies, and Web Beacons
2.2 When you visit our Websites, our servers automatically save your computer's IP address via our analytics tracking system. IP addresses will be collected for the purpose of analytical tracking and improving the Websites, along with geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Websites. If you arrive at the Websites via a link from another website, the URL of the linking website and the URL of any website that you link to next will also be collected for the purpose of assessing our main traffic sources, and debugging and tracing.
2.4 SPIL uses analytics partners in order to help get insights into the usage of the Websites and services (“Usage Data”). These analytics partners process Usage Data which may include among others your IP address, geographical location, browser type and version, operating system, length of visit, page views and other information about how you use and navigate the Websites. This data is used to analyze the use of the Websites and to improve the Websites and services. Our analytics partners will act as a data processor in relation to the Usage Data. The legal basis for the processing of the Usage Data is legitimate interest.
2.6 SPIL uses Facebook technology to provide certain services on the Websites. The Websites may include the “Facebook Like Button” which is controlled by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304 USA (Facebook). In the event you click on the Facebook Like Button, Facebook will ask you whether you want to log in to Facebook if you are not logged in at that moment, or register with Facebook. If you decide to do so, your personal data will be transferred to Facebook. In the event you are already logged into your Facebook account and you have given SPIL your explicit consent to the sharing of your information with Facebook, your information is shared with Facebook when visiting the Websites or playing games including the “Facebook Like Button”.
The Websites also use the “Facebook Pixel” controlled by Facebook in order to show conversions, create “lookalike audiences” and provide SPIL with relevant statistics about our Websites in order to improve them. When you use our websites and you have given SPIL your explicit consent to the sharing of your information with Facebook, your information is automatically shared with Facebook.
For more information on the “Facebook Like Button” and “Facebook Pixel” and sharing and use of your personal data please consult Facebook’s Data Policy at: https://www.facebook.com/policy.php.
2.7 SPIL may also use third-party payment service providers ("PSP"), offering payment transaction services to SPIL in order to sell a product or service through the Websites. The PSP acts a data controller with regards to the personal data related to the transactions (“transaction data”) processed for the purpose of purchasing the product or service. The transaction data may include your personal details, your payment card details, and the transaction details. Whenever you buy something from the Websites (e.g., a virtual game item), the information that you provide to the PSP is subject to their privacy policies, not ours. The legal basis for this processing is the performance of a contract. You explicitly consent that SPIL may provide personal information collected from you to a PSP for the purpose of the offering of the payment-transaction service whenever you buy something from the Website(s) and that such PSP may use such data for (statistical) analysis of payment transactions. After you have purchased a product or service, SPIL and the PSP have a legal requirement to retain your information for a legally determined period of at least 7 years. SPIL shall be allowed to notify a PSP regarding a user that engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person's rights, or that led to such a user's suspension or termination of use of the Websites.
2.8 SPIL uses third party service providers in order to offer our users customer support services. We may share personal data such as the communication content, IP address, e-mail address, and username (“Correspondence Data”) with these partners. The Correspondence Data may be processed by SPIL and business partners for the purpose of communication with you, blocking users, changing email addresses, reactivating or blocking accounts, adding or removing in-game items and other customer support services. The legal basis for the processing of the Correspondence Data is legitimate interest or consent depending on the service provided.
2.9 Most browsers are initially set to accept cookies, but you can (re)set your browser to refuse all cookies or to indicate when a cookie is being sent. You can opt out of receiving cookies from certain third-party advertising networks by resetting your browser. You may also use the following link to the Network Advertising Initiatives cookies opt-out pag or the link to the European Interactive Digital Advertising Alliance (EDAA) opt-out page. However, some features and services may not function properly if cookies are disabled.
2.10 You may choose to register with us for a better game experience and/or to create a public or private profile for participating in our social gaming network. This includes, for example: overviews of high scores, achievements listings and individual game recommendations on the Websites. When you register with us, you may provide us with certain personal data such as a username, gender, date of birth and your email address (“Account Data”). The Account Data you provide us will be used for the purposes of providing our services, improving our Websites, maintaining back-ups and communicating with you. The legal basis for this processing is consent.
The information you disclose in that respect may also become publicly accessible if you choose this privacy setting. We provide you with privacy settings that restrict other users from accessing your information; namely, our network architecture and your privacy settings allow you to make informed choices about who has access to your information. We allow you to choose the information you provide to friends and networks through our Websites. When your privacy settings permit it, other users may be able to see and supplement your profile (e.g., by posting comments).
2.11 If you decide to disclose information in a public venue or in games, we will consider that information as part of the public domain. This information will be accessible to any person who uses the Websites.
2.12 We only collect email addresses that were provided to us directly by you. Your email address will only be used for the following purposes:
2.13 Without your approval, we will not:
You can revoke your consent to use your email address for promotional purposes at any time, including the newsletter by changing the privacy settings in your account or sending an e-mail to email@example.com.
Combination of Personal Data
2.14 For optimizing our services and the Websites, and for the purposes mentioned in this article 2, we are entitled to combine your personal data (including your email address, as applicable) with other information about you collected by or provided to us.
3.1 SPIL may provide information to any party whose services it engages for the purposes of its normal operations (for example, those partners who assist us by providing technical or operational facilities for the Websites and so forth), as mentioned under section 2. We may also supply information to other parties if we are required to do so by law or by a ruling handed down by a court of law. SPIL does not provide personal details to other parties for commercial, advertising, or marketing purposes, except if you explicitly give us permission to do so, or if doing so is part of a specific program or operation for which you have registered. In such case, you may withdraw your permission at any time.
5.1 Your personal data may be stored by SPIL and its business partners.
In case the applicable data protection laws provide so, you have the right to access, rectify and erase the personal data we hold about you and to restrict or object to our processing of your personal data. To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time.
5.2 Users with a personal profile on the Websites that wish to exercise these rights, can mostly do so by clicking on the appropriate link in the personal profile. Furthermore, you can send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, The Netherlands, detailing your request, along with a copy of your passport (to prevent misuse of requests for information), or send an email containing this information to: firstname.lastname@example.org. After the verification of your identity, the copy of your passport will be shredded.
5.3 SPIL does not knowingly process personal data from anyone under the age of 16 without parental consent. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data.
Parents of users under the age of 16: If you wish to have access to your child's personal data to view, correct, or delete the information that we have collected about your child, please send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, the Netherlands, detailing your request along with a copy of your passport (to prevent misuse of requests for information), or send an email with all such information to email@example.com. After verification, the copy of your passport will be shredded.
5.4 In the event you have any questions or concerns in relation to the processing of you personal data you can send an e-mail to our Data Protection Officer by email at firstname.lastname@example.org.
If you are not satisfied with our responses and/or support to resolve your concerns, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
6.1 You post personal data and any other content on the Websites at your own risk. Although we allow you to set privacy options that limit access to such personal data and other content, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you choose to share your profile and information. Therefore, we cannot and do not guarantee that any content you post on the Websites will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. You understand and acknowledge that, even after removal, copies of personal data or content may remain viewable in archived pages.
6.2 We have implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect online. Your personal data visible on the Websites (such as any public comments posted by you and/or any data in your profile) are accessible to third parties, and you acknowledge and agree that such third parties are able to copy such information to their own websites or other locations.
7.1 SPIL will only retain your information for as long as we consider necessary for the purposes described under section 4. The retention rate per category of personal data shall differ depending on the purpose for which it is processed. We will also retain and use your information for as long as necessary to comply with any legal obligations, resolve disputes, and enforce our agreements. In the event you have any questions in relation to the retention of your personal data, you can send an e-mail to email@example.com indicating the concerned category of personal data.
If you have any additional questions or requests, you may send an email to firstname.lastname@example.org.