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Privacy policy

General information

This Privacy Policy describes the methods for collection, processing, storage and transferring of your personal data as applied by SRG Community.

Controller information

SRG Community LTD, registration number <<insert>>, registered at <<insert>>. If you have any questions related to personal data, please, send to <<insert>>.

SRG Community undertakes to abide by the legal requirements as per Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union from April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR).

This Confidentiality Policy applies to our SRG (SRG Community) Loyalty Program for online games accessible through our website www.srg-community.com using mobile devices, tablets, PC or other platforms, such as Facebook, Instagram, Twitter and other social media. It also applies to our marketing and promotional campaigns run on all platforms and other services that may be provided by us to you on a continuing or temporary basis. For purposes of this Confidentiality Policy our Loyalty Program, mobile application, websites, marketing and advertising campaigns and other services shall be jointly referred to as the Services.

If you download, access, become a member or use our Loyalty Program, or in any way interact with our websites, our mobile application or other Services, it means that you consent to the collection and use of your data as per this Confidentiality Policy, including a consent to the use of your data by SRG Community, our gaming partners, including our advertising partners for targeted advertising purposes as prescribed by the Marketing and Advertising sections of this Confidentiality Policy, and the use of cookies by us. If you have any concerns regarding submission of your data to us or use of such data as per this Confidentiality Policy, you should not download, sign up, use or become a member of the SRG (SRG Community) Loyalty Program or use any other Services.

Definitions

  • personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  • processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  • recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, puauthorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
  • third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
  • consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
  • supervisory authority means an independent public authority which is established by a Member State
  • cross-border processing means either:
    1. processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the European Union where the controller or processor is established in more than one Member State; or
    2. processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State

Principles of personal data processing

We process your personal data on the following principles:

  1. lawfully, fairly and in a transparent manner in relation to the data subject
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
  4. accurate and, where necessary, kept up to date
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

The controller shall be responsible for and be able to demonstrate compliance with principles above.

How we use your personal data

We collect your data when you use our Loyalty Program or any other Services via the resources of our partners. You provide the data voluntarily.

Data provided by you voluntarily:

  • Last Name, First Name, email address, other contact details;
  • Data provided by you when you fill in the forms, answer the questions or complete surveys using our Services or the Services of our partners, or when you create your account or invite your friends to join our Loyalty Program or use our other Services;
  • Any data that your submit to the customer service via the application or by email can be stored by us;
  • Data related to your interaction with us through social media;
  • Your data collected by us from third parties that have obtained your consent or have other lawful rights to share such data with us. Such data may include your characteristics and the information on your interests, as well as any information on the games other than partner games of SRG Community, or any other Services, demographic data and general information on your location. We will use such data and information in accordance with this Confidentiality Policy with due regard to any confidentiality limitations applied by any company collecting your data.

Data collected by us automatically:

  • Data and analytics regarding the use of our Services and the Services of our partners (for example: Loyalty Program progress, levels, session duration, games played, preferred settings, ads watched by you while using the Loyalty Program, resources from which you were redirected to our Services, progress in the games of our partners);
  • Identifiers of your IP address and device;
  • Type of your device;
  • Geographic location (for example: country, city, etc.) determined on the basis of your IP address;
  • GPS location data (with your consent);
  • Data concerning your interaction with our services.

We may request your consent to collection of other data concerning you or your device. For example, we may request access to your contacts to invite them to our Loyalty Program used by you. In such event we will inform you of the data we would like to obtain, as well as the purpose of accessing such data and the ways we are going to use it.

A part of such data could be collected using cookies and/or similar technologies (for example, using SDK developer tools) as described in the Cookies and Similar Website Tracking Technologies section

Data from open sources:

  • Social media data. You can sign in to our Services using your social media accounts. The actual data that we will obtain from you will depend on your confidentiality settings of your social media accounts, but as a rule it will include general profile information, such as:
  • User name;
  • Profile picture;
  • Age range;
  • Email address;
  • Country;
  • Sex.

Any other public data:

  • Third-party service providers. We can obtain your data from external sources. For example, we may receive personal data during or prior to installation of the Loyalty Program when you click on the Loyalty Program advertisement;
  • Advertising partners. We can obtain your personal data from other external sources. For example, when you click on an advertisement that redirects you to one of our Services (for example, our in-game Loyalty Program advertisement, a referral link shared by a Loyalty Program member, social media posts) we will obtain the information on the advertising network and campaign where you got the installation link from.

How we use your personal data

We use your personal data for the following purposes.

Provision and management of our services:

  • Creating accounts / user profiles so as you could use our Loyalty Program and our other Services;
  • Providing a correct version of the Loyalty Program and/or the application to you (for example, based on the language preferences of the Loyalty Program used by you);
  • Sending you service messages, including confirmations, technical statements, updates, security notices and technical support / administrative messages.

Improvement of services and ensuring security:

  • Replying to the customer service enquiries;
  • Consulting you via the customer service channels;
  • Receiving reports on errors identified by you/your devices while using our Services so that we could correct any errors and compatibility issues;
  • Detecting and preventing illegal activities (for example, hacking or fraud);
  • Tracking the Loyalty Program installations (for example, to evaluate the efficiency of marketing campaigns);
  • Conducting additional user surveys and researches;
  • Understanding and taking into account your preferences so as to improve our work and make the use of the Loyalty Program more comfortable;
  • Conducting researches.

Personalization of our services, namely the following:

  • Remembering you when you visit our Loyalty Program our any of our Services next time;
  • Sending messages concerning promotions, rewards, upcoming events, and offering you products and services.

Advertising campaigns, namely the following:

  • Offering you rewards based on your behavior in the Loyalty Program;
  • Offering you our gaming partners’ discounts on game items;
  • Sending you marketing messages and/or information statement regarding rewards and promotions if you have subscribed to them.

Other:

  • Please note that when you use the News Feed & Comments section, any comments or materials published by you will be publicly available, and any data that you submit can be read and/or used by other users. Therefore, you should only publish the content that you deem acceptable for public use;
  • You can connect your Loyalty Program profile to any third-party network (for example, Facebook). If you do so, your personal information will be visible to other Loyalty Program users;
  • Your Loyalty Program profile and its contents will be visible to any other Loyalty Program users;
  • If allowed by your settings, you may sign in to the Loyalty Program using your account on third-party social media like Facebook, Instagram or Twitter. If you do so, you can use your account for authentication and synchronization of several devices;
  • Exercising, ascertaining or protecting our lawful rights or your fundamental interests;
  • Preventing and/or detecting fraud or cheating;
  • For any other purposes stipulated by the effective legislation.

Marketing and Advertising

We and our partners use your data to send you advertising messages regarding new gaming partners who have joined our Loyalty Program, promotions and discounts.

We use your data to offer you only those products that might be of interest to you (for example, the games you play).

Cookies and Similar Website Tracking Technologies

Our Services may use cookies and other technologies, such as pixel tags, local shared objects, hardware device identifiers, flash cookies, operating system identifiers, clear GIFs and web beacons.

Cookies. Cookies are small files that are created by websites and stored by the browser. As a rule, websites place several cookies on the end user’s device. Cookies are personal data. Nevertheless, cookies used by SRG Community LTD do not contain any personal data and are generally used to identify and “remember” your device for subsequent visits so as to ensure the necessary functionality, meet your preferences and guarantee efficient website operation.

You can turn off cookies on your device or configure your device so that it notifies you of any outgoing cookies, but turning off your cookies may affect the use of our Loyalty Program and other Services.

What types of cookies we use

Legal Grounds for Personal Data and Information Processing.

Contractual requirements. Such requirements apply to the data used by us to grant you the access and use of our Loyalty Program and other Services that we have agreed to provide.

Consent. We process your personal data on the basis of your consent (for example, when we grant you the access and use of our Loyalty Program and other Services, conduct marketing or personalized advertising activities, ensure security of our Loyalty Program and the Services, and for technical purposes, user behavior analysis, moderation, etc.). You consent to data collection when you agree to install our Loyalty Program, and you may withdraw your consent by uninstalling the Loyalty Program; we and our partners may store data on your device, including using cookies. By accessing our Loyalty Program, you consent to such storage, and you may withdraw your consent by changing the cookies settings. You grant your consent to the data collection when you accept this Confidentiality Policy.

Legal obligation. We must process personal data as per the legal obligations (for example, to prevent crimes and fraud, or for tax accounting purposes).

If we ask you to provide personal data to meet our legal obligations or for any other purpose, we will do so expressly and notify you whether our request is mandatory or not (and we will also inform you of the consequences of non-provision).

Disclosure of Information

We may disclose information to our partners, our data processing service providers or other persons or entities that process personal data for the purposes described in this Confidentiality Policy and disclosed to you when we collect your personal data.

Any competent law enforcement authority, regulatory body or governmental authority acting in compliance with the statutory or common law, or any other third party when we expect that disclosure of information is required by the applicable law or rule to exercise, ascertain or protect our lawful rights or your fundamental interests.

In case your data were anonymized or aggregated meaning that you may not be identified using such data.

If we believe that such disclosure is allowed by the law or any regulations, or necessary to fulfil any legal obligation, or to ensure compliance with or application of our terms and conditions and/or provisions of any other agreement with you, or for protection of ownership rights of SRG Community LTD or our users.

To any potential or existing buyer (its agents and/or advisors) related to any potential or actual purchase, merger or acquisition of any portion of our business, provided that we have notified the buyer that it must use your personal data solely for purposes described in this Confidentiality Policy.

Any other person or entity that you have granted your consent to disclosure of your personal data to.

Personal Data Security

SRG Community LTD implements data security procedures and engineering controls to protect your data against unauthorized access, loss or improper use. Besides, we require that our service providers who process personal data on our behalf to take a series of security measures to protect your personal data and maintain a certain level of security. Nevertheless, we cannot guarantee absolute safety of your data both online and offline as the Internet inherently is not secure and the nature of risks changes continuously. Therefore, you should always be cautious when you exchange data over the Internet.

International Data Transfer

Your personal data may be transferred and processed outside the country of your residence. The laws of other countries may differ from the laws of your country.

Considering that our Loyalty Program is used globally, your data may be collected and processed in any country of the world. Nevertheless, we use our best efforts to ensure proper security and protection of your personal data as per this Confidentiality Policy. Such requirements apply to the transfer of personal data to third-party service providers and partners who are certified in compliance with the EU-US Privacy Shield.

In the case of data processing in third countries that do not provide adequate protection, we take all possible technical and other measures to protect your personal data.

Data Storage

We store the personal data received from you if so lawfully no more than requiredby our business needs (for example, to grant you the requested services or comply with the applicable legal, tax and accounting requirements). For example, from time to time we anonymize the unused accounts and/or irrelevant personal data.

If we do not have a lawful business need to process your personal data, we will either delete or anonymize such data, or, should it be impossible (for example, when your personal data is stored on a backup server), we will securely store your data and prevent its further processing until we are able to delete it.

We will store your personal data for as long as your account remains active, or as long as there is a need to use it for the purposes described above in this Confidentiality Policy. We will also store and use your personal data during the period of time required to perform our legal obligations.

Your Rights

For all questions related to the exercise of your rights, please contact <<insert>>.

Right of access to personal data. You have the right to know which personal data we have about you and (in some cases) obtain such data. If you want to exercise this right, please contact us and inform us of your desire to exercise such right to access. We reserve the right to request reasonable evidence to verify your identity prior to provision of any personal data. Please note that we will not be able to provide you all personal data requested by you if such data contains information about any other person. In the event we cannot provide to you the personal data requested by you, we will use our best efforts to disclose the reasons for denial. We will try and reply as soon as possible to any request made by you regarding your right to access personal data, provided always that it takes at least 1 month since the date of your request and identity verification.

Right to rectification. You may rectify, update your personal data or demand deletion thereof. You may do so in your account settings or by contacting the customer service. If you realize that some of your personal data is incorrect, please contact us at: law@srg-community.com

Erasure of data. In some cases you will have the right to obtain the personal data stored by us. Please note that you must uninstall our Loyalty Program and the Services from your mobile devices and clear the cookies on any device so that we could process your request for erasure of personal data. Even if we erase your personal data, we will still be entitled to store such data or any portion thereof for other purposes, such as financial accounting, protection or enforcement of %p legitimate rights, maintaining the containment lists that is created under legislation, marketing activities or for technical reasons, such as ensuring technical safety and integrity of our database. We also have the right to store your personal data in an anonymized form. In some cases your personal data displayed in the course of your use of our Loyalty Program (such as user name, profile picture, your achievements) may be cached on devices of other players, and we will not be able to delete or update the data stored on other devices (for example, when a device is not connected to WiFi).

Account deactivation. If you have registered an account in our Loyalty Program, you may request deactivation of such account by contacting us using our contact details. Prior to deactivation of your account we may request additional information from you. Such information may include the data on your mobile and other devices. Other steps required from you in order to entirely deactivate your account include deletion of the links to your Facebook, Instagram, Twitter and other social media accounts from our Loyalty Program and uninstallation of our Loyalty Program from your devices. Please remember that in the event you choose to deactivate your account you will lose all your achievements, information, any other data, etc., and we will not be able to restore them in the future.

Data portability. In some events you will have the right to have your personal data transmitted to you for further transfer to another data controller.

Restriction of processing. In some cases you will have the right to demand that your personal data processing is restricted (for example, when you challenge the accuracy of any data stored by us).

Right to object. Object against processing of your personal data (being processed based on legitimate interests), demand that we restrict the processing of your personal data or submit a request for transmission of your personal data. Besides, you can do it by declining the personalized offers by contacting us using our contact details.

No marketing and targeted advertising. If you elected to receive targeted advertising messages from us, you may at any time change your decision by clicking on the respective link contained in any advertising message received by you. If you agreed to receive advertising messages of various types from us, you may be required to unsubscribe from each type of messages. It may take several days before your request is completed.

Complaint. You have the right to file a complaint to the personal data protection authority regarding collection and use of your personal data by us. For additional information, please contact the local personal data protection authority.

Age Restrictions

We do not collect the personal data of persons who are under 13. We do not know the age of our Loyalty Program users when we collect personal data. If a user has a Facebook, Instagram, Twitter or other social media account when such user joins the Loyalty Program, we receive the information on the age of such user from such social media accounts. Should it be revealed that we accidentally collected any data regarding any minor under age of 13, we shall take reasonable steps to delete such data from our databases as soon as possible.

Exceptions

Please note, that in following cases data controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34 GDPR:

  1. national security;
  2. defence;
  3. public security;
  4. the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
  5. other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation a matters, public health and social security;
  6. the protection of judicial independence and judicial proceedings;
  7. the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
  8. a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in points (a) to (e) and (g);
  9. the protection of the data subject or the rights and freedoms of others; (j) the enforcement of civil law claims.

Privacy Policy Updates

We may from time to time update this Confidentiality Policy. The updated Confidentiality Policy will be published in the respective section. Please visit the respective section regularly to check the current version. Any updated Confidentiality Policy shall become effective upon publication.

Contact Us

Official website: srg-community.com
E-mail: law@srg-community.com