Date last updated: August 28, 2019
SPIL may use affiliates’ or reputable third parties’ services for the processing of personal data collected on or through the Website.
2.1. SPIL GAMES BV is registered with the Chamber of Commerce under number 32106054 and is the data controller as referred to in the General Data Protection Regulation (“GDPR”). SPIL has its registered office at Mussenstraat 15, 1223 RB, Hilversum, The Netherlands. Our telephone number is +3135 646 6300.
2.2 Our Website offers a diverse, and exciting mix of online games created by SPIL, as well as games created by independent developers and others with whom we do business. Users can access our Website to play games without registering. Certain games on our Website are controlled by third parties, including third parties located outside of the European Economic Area (“EEA”). Our own hosting facility for the Website is located within the EEA. We use commercially reasonable efforts to ensure that no personal data of children is being processed via our Website. 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 we become aware of any third party violating our agreement with them by collecting personal data of children without verifiable parental consent, we will take appropriate action to terminate our relationship with such third party or otherwise take corrective measures.
3.1. SPIL collects certain information when a user visits our Website (“User Information”). The User Information we collect is:
We do not collect any additional information from or about the users of our Website.
|Unique personal identifier||To identify user’s behavior for analytics, such as retention, gameplays, time spent on our Website, and other anonymous metrics that are used only for support for the internal operations of the Website|
|IP address||To identify the country in which the user is located while using the Website, which data is used only for support of the internal operations of the Website|
|Geolocation data to identify country only||To identify the country in which the user is located while using the Website, which data is used only for support of the internal operations of the Website|
We may also use User Information:
5.2. SPIL’s Website is hosted within the EEA, and the User Information will be stored by SPIL in the EEA. To the extent that any User Information is processed by anyone outside of the EEA, we have taken such measures as are reasonably necessary to ensure an adequate level of protection for the User Information in accordance with the requirements of applicable data protection legislation, including but not limited to contractual safeguards.
SPIL uses third-party analytics companies in order to help get insights into the usage of the Website (“Usage Data”). These analytics companies process Usage Data, which may include, among others, User Information. This data is used to analyze the use of the Website and to improve the Website and related services. These analytics companies 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.
6.2. Customer Support
SPIL uses third party service providers in order to offer our users customer support services. We may share User Information with these service providers. The legal basis for the processing of the User Information is legitimate interest or consent depending on the service provided.
The Website is monitored and improved to maintain and effectuate the best experience for our users. Developers may therefore see and have access to the User Information, but they will only use this information for Website optimization purposes. The legal basis for the processing of this data is contractual necessity.
7.1. Your User Information may be stored by SPIL and our service providers. In case the applicable data protection laws provide so, a user has the right to access, rectify, and erase the User Information we hold about the user and to restrict or object to our processing of the User Information.
7.2. If a user wishes to exercise these rights, the user can do so by sending a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, The Netherlands, detailing the request, (to prevent misuse of requests for information), or sending an email containing the request to: email@example.com.
7.3. As we do not collect email or street addresses, we will not send any marketing communications to our users by email or otherwise.
7.4. SPIL does not knowingly process personal data from anyone under the age of 16 without verifiable parental consent, unless the applicable law allows SPIL to do so. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent and/or without a legal basis to do so, we will promptly delete such data.
7.5 In the event there are any questions or concerns in relation to the processing of User Information, please send an email to our Data Protection Officer by email at firstname.lastname@example.org. If you are an EU subject, and 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) Member State where you work, normally live, or where any alleged infringement of data protection laws occurred.
8.1. SPIL has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to the Website.
8.2. Although we take reasonable and appropriate measures to protect the security of User Information, please be aware that no security measures are perfect or impenetrable. We are not responsible for the circumvention of any privacy settings or security measures.
9.1 We do not share any User Information with third parties for direct marketing purposes. In addition, please note the following:
9.2. Information We Collect From California Consumers
Within the last twelve (12) months, we have collected the following categories of Personal Information from consumers. Some of the categories may overlap with each other:
|Identifiers||Unique personal identifier, Internet Protocol (IP) address||YES|
|B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))||Unique personal identifier, Internet Protocol (IP) address:||YES|
|C. Legally Protected Characteristics||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)||NO|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||NO|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or similar network activity||Browsing history (information regarding the page the consumer visited prior to coming to our website); , information regarding a consumer's interaction with a website, mobile application, or online advertisement; device type, brand, and platform; timestamp; whether consumer is a registered user or guest; game and page views||YES|
|G. Geolocation data||Physical location or movements||YES – on a country basis only|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information||NO|
|I. Employment information||Professional or employment-related information||NO|
|J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records||NO|
|K. Inferences drawn of other categories of Personal Information||A profiles created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||NO|
9.3. Personal information does not include:
9.4. We obtain the categories of Personal Information listed above from the following categories of sources:
9.5. Use of User Information
We may use or disclose the User Information we collect for one or more of the following internal business purposes:
We will not collect additional categories of personal information or use the User Information we collected for materially different, unrelated, or incompatible purposes.
9.6. Sharing Personal Information
We may disclose your User Information to a third party for internal business purposes. When we disclose User Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that User Information confidential and not use it for any purpose except performing the contract on our behalf.
In the preceding twelve (12) months, we have disclosed the following categories of User Information for an internal business purpose:
We disclose User Information for an internal business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold any User Information.
9.7. Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at email@example.com.
10.2. We and you agree that in the event of any dispute, the party wishing to address the dispute must contact the other party in writing, including by e-mail, and advise the other party of the dispute in reasonable detail as well as informing the other party of the remedy being sought. We may send you notices via the email address or physical address you provide to us, and all notices to us shall be sent to the following email address: firstname.lastname@example.org and include the words “DISPUTE NOTICE” in the subject. The parties shall then make a good faith effort to resolve the dispute before resorting to more formal means of resolution. In the event that the dispute is not resolved through this procedure, the party raising the dispute may proceed to mandatory arbitration as set forth below.
10.4 Any arbitration, claim or other proceedings by or between you and us shall be conducted on an individual basis and not in any class action, mass action, or on a consolidated or representative basis. You further agree that the arbitrator shall have no authority to award class-wide relief or to combine or aggregate similar claims or unrelated transactions. You acknowledge and agree that this agreement specifically prohibits you from commencing arbitration proceedings as a representative of others. If for any reason a claim proceeds in court rather than in arbitration, each party waives any right to a jury trial. Any claim that all or part of this Class Action Waiver is unenforceable, unconscionable, void, or voidable may be determined only by a court of competent jurisdiction.
11.3 We may disclose User Information and/or any of our users’ personal information (if we are aware of the same) pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we reasonably believe the disclosure is necessary or appropriate to protect our legal interests or the legal interests of another. We may also disclose such information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Website, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.
11.4 If you have any additional general questions or requests about our Website, you may send an email to email@example.com. In the event you have any questions or concerns in relation to the collection or processing of User Information, please send an e-mail to firstname.lastname@example.org.
Date last updated: August 28, 2019