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.
We process your personal data on the following principles:
The controller shall be responsible for and be able to demonstrate compliance with principles above.
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:
Data collected by us automatically:
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:
Any other public data:
We use your personal data for the following purposes.
Provision and management of our services:
Improvement of services and ensuring security:
Personalization of our services, namely the following:
Advertising campaigns, namely the following:
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. 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.
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).
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.
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.
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.
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.
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: firstname.lastname@example.org
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.
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.
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:
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.