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Privacy Policy Thalia Games

Version 1.1.
This page was changed on 13-10-2018.

  1. Thalia Games

Thalia Games is a Netherlands based company. Our business operations are located in the Netherlands and we store our data on servers in the European Economic Area (EER). 

We are committed to comply with all applicable Dutch and European data protection laws and regulations. 

These Privacy Terms (“Privacy Terms”) summarize when and how your personal information is collected, used, safeguarded and disclosed in connection with your access to, and use of, applications, software and websites operated by us and all features, functions and services offered through the applications, software and website. The applications, the website, the features, functions, and services offered through the applications, software and website collectively constitute the “Service.”

  1. General

We reserve the right to change the provisions of these Privacy Terms from time to time. If we make changes, we will notify you of the changes. We encourage you to periodically review the latest Privacy Terms.

  1. What personal information do we collect, for what purpose and for how long?

Personal information may be collected in a number of ways when you use our Service. We may collect the following information:

3.1 Processing necessary to represent the legitimate interests of Thalia Games (processing duration of 2 years after the agreement between you and Thalia Games has come to an end)

Improving the game

  • Device identifiers
  • The OS you use
  • IP-address
  • Identification cookies
  • Timestamp of when you install the game
  • Timestamp of when you boot up the game
  • How many times it takes you to complete a level

Determining the effectiveness of our marketing strategy

  • IP-address
  • The link that referred you to Thalia Games
  • Identification cookies

Marketing (newsletter)

  • Name
  • Email address

3.2 Processing for which you have given permission by filling in optional fields or otherwise (processing duration of 2 years after the agreement between you and Thalia Games has come to an end or 2 years after the last event for which the personal information was provided has ended)

Contact information

  • Name
  • Email address
  • Other personal information entered in the contact form

Marketing (newsletter)

  • Name
  • Email address

Promotional purposes (such as giveaways)

  • Name
  • Date of birth
  • Address
  • Email address
  • Phone number

  1. Consequences of limiting our ability to process personal information

Per processing ground as mentioned under article 3, we shall disclose the consequences of limiting our ability to process the mentioned personal data either by not making available such personal information, by providing wrong personal information or by filing requests to limit or stop processing personal information. 

Limiting processing based on the ground mentioned in article 3.1 (processing necessary for our legitimate interests): you may be hindered in your use of the Service. We may block or limit your access to the Service and we reserve the right to end the agreement in accordance with our terms of use. The personal information mentioned in this subsection is required for the Service to function properly and to prevent data breaches to the best of our ability. 

Limiting processing based on the ground mentioned in article 3.2 (processing with your permission): you will in principle not be hindered in your use of the Service. It is possible that part of the Service cannot be provided to you.

  1. Sharing of personal information

Unless otherwise described elsewhere in these Privacy Terms, we do not disclose, sell or trade any personal information about our visitors and users to any third parties.

5.1 Sharing with processors

We may engage third parties to assist in the provision of the Service and which may, as part of their role in delivering the Service, process personal information of users of the Service. In this respect, such a third party is hereinafter referred to as ‘Processor’. We engage the following type of Processors:

  • hosting providers;
  • parties providing marketing tools (such as Google Analytics , which is configured in a way that no data is shared with Google);
  • parties that provide tools to analyze the use of our Services (such as GameAnalytics).

In some cases, the Processor may be directly collecting the information from you on our behalf. We inform Processors that they are not permitted to use personal information they obtain from us other than to provide the Service for us. We are not responsible for any additional information you provide directly to these Processors. Please become familiar with their practices before disclosing any personal information directly to such Processors.

5.2 With your consent

From time to time, we may also share personal information with third parties when you give us your consent to do so. For example, we may enter into relationships with other parties to make specific services or offers available directly to our users. If a user opts-in to these third party services or marketing offers, we may share the personal information you provide at the time of sign-up or such other personal information, such as your name or other contact information, that we deem reasonably necessary or appropriate for our business partner to provide these services or offers or get in contact with you.

5.3 Our legal responsibility

We may disclose Personal information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of us, our users, our employees or the public, including without limitation to protect ourselves or our users from fraudulent, abusive, inappropriate or unlawful use of the Service. We will promptly notify you of any request of an executive or administrative agency or other governmental authority that it receives and which is related to personal information of you, unless prohibited by applicable law. 

5.4 Aggregate information

Please note that nothing herein restricts the sharing of aggregate information, which may be shared with third parties without your consent.

  1. Protection of personal information

We shall ensure we implement and maintain compliance with appropriate technical and organizational security measures for the processing of personal information. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. 

We have put in place physical, electronic, and managerial procedures that are designed to prevent unauthorized access, loss, or misuse. 

We use: 

  • SSL (secured socket layer) technology where possible, to encrypt your transmission of sensitive information to us, such as account passwords and other payment-related identifiable information.
  • We restrict internal access to personal information to employees who need the information to perform their duties. The unauthorized access or use of such information by an employee is prohibited and constitutes grounds for disciplinary action. Our employees are bound to a confidentiality clause.
  • Our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access.
  • You should note that our Processors may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Processors are contractually, by means of a data processing agreement with Thalia Games, required to safeguard and secure the personal information they received from us.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. 

  1. Links to third party sites

Our Services and/or Website may contain links to other websites as well as advertisements from third parties. Third party sites may log information about you. We do not control such sites or their activities. Any personal information you provide on the linked or advertised pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of websites to which we link or which we advertise. Links from our Website to third parties or to other sites are provided for your convenience only. We encourage you to learn about their privacy and security practices and policies before providing them with personal information

  1. What choices do you have regarding the use of its personal information?

Before sharing your personal information with third parties in ways not covered by these Privacy Terms, including any use for direct marketing purposes, you will be notified and required to opt-in to such sharing at the point at which such information is collected. 

We may send you marketing and promotional postal mail about our products and services. If you no longer want your information to be used us for direct marketing sent by postal mail please contact us at the e-mail address mentioned under ‘Contact Us’.

You can also opt-out by following the unsubscribe instructions included in each promotional e-mail. This shall not affect our ability to send you service and account related e-mails or to use your personal information as otherwise described in these Privacy Terms. 

We will comply with your request as soon as possible after receipt.

  1. Rights of the customer

As customer you have certain rights regarding your personal information. Your rights are stated below. Keep in mind that these rights may be subject to restrictions, if our or other legitimate interests weigh heavier than your legitimate interests.

Your rights as data subject:

  1. You may review, update, correct or delete its personal information collected through the Website and Service by using a feature in the Service designed for that purpose, if such a feature is available, or by e-mailing us at the e-mail address mentioned under ‘Contact Us’. 

Note that the deletion of you information data may lead to the termination of your account and the end of the right to make use of the Service. 

  1. You can delete its account and personal information using an in-app feature. We reserve the right to retain your information in our files if we believe it is necessary or advisable to provide the Service to others, resolve disputes, enforce applicable terms of service, and for technical and legal requirements and constraints related to the Service. 

  1. To have access to your personal information per e-mail, you must provide sufficient proof of identification as we request, and we reserve the right to deny access to any user if we believe there is a question about your identity. We will respond to all access requests within 4 weeks. 

  1. You can request us to limit or stop the processing of its personal information in the future. We will meet your request, but you may be hindered in its use of the Service or may no longer be able or allowed to use the Service, as stated in Article 4 of these Privacy Terms. 

  1. You can request us with reasonable intervals to transfer the personal information we process about you, as long as the requested information does not include personal information of other natural persons and as long as the requested information has been processed based on the grounds mentioned in article 3.1 of these Privacy Terms. We will meet the request of Customer within 4 weeks after we have received the request. 

  1. Customer has the right to file a complaint related to the data processing to the competent privacy authority. For the Netherlands, this authority is the Autoriteit Persoonsgegevens, which can be reached at https://autoriteitpersoonsgegevens.nl/. 

  1. Contact us

If you have any questions, concerns, or comments regarding these Privacy Terms, please contact us via e-mail at info@ThaliaGames.com