PRIVACY POLICY

Effective Date: 29 July, 2020

PRIVACY POLICY AND COOKIES INFORMATION ON THE PROCESSING OF PERSONAL DATA

Thank you for playing our games! This Privacy Policy describes:

The ways we collect personal data about you and why we do so;
How we use your personal data, and the choices you have about your personal data.

This Privacy Policy applies to RELUDO games, websites and related services, which we here collectively call the Service.

We may periodically update this Privacy Policy by posting a new version on www.reludo.com . If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. This is an information that is made pursuant to art. 13 of Regulation EU 2016/679 for users who interact with web services starting from the address www.reludo.com

The information is provided only for this site and not for other websites that may be consulted by the user through links.

CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us so we can reply to you more quickly.

Name of the controller: Reludo srl

Address: Via del Pontiere, 11 Verona, 37122, Italy
Email: [email protected]

RELUDO S.r.l. is not required to appoint a D.P.O. (Data Protection Officer) pursuant to art. 37 of the GDPR.

RELUDO S.r.l. cannot derive the personal identity of a user because RELUDO S.r.l. only hold codes such as MAC ADDRESS and IMEI, but it jointly determines together with partners (art. 26 GDPR) such as Google, Facebook, Apple and others (see the complete list in “Opting Out” session) the purposes and methods of the treatment and never determine the identity of the natural person or data subject.

THE DATA WE COLLECT

Data you provide us.

Contact information (such as name and email address)

Your messages to the Service (such as player support tickets)

Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.

Data about your account and game progress

Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)

Data about your device, such as device name and operating system, browser type and language

Data we collect with cookies and similar technologies (see more below)

General location data

Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

Data we collect from our partners.

Data we receive if you link a third-party tool with the Service (such as Facebook, Apple or Google)

Demographic data (such as to determine the coarse location of your IP address)

Data to fight fraud (such as refund abuse in games or click fraud in advertising)

Data from platforms that the games run on (such as to verify payment)

Data for advertising and analytics purposes, so we can provide you a better Service

WHY DO WE COLLECT YOUR DATA

a) to make the Service work.

b) to perform the contract, we process data necessary to create accounts and allow you to play our games and use our Service

o Operate the Service

o Verify and confirm payments

o Provide and deliver products and services you request

o Send you Service-related communication

c) to make the Service more suitable for our players.

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to:

o Update and develop player profiles

o Develop and improve the Service and player experience

o Manage our relationship with you

o Provide social features as part of the Service

o Customize your Service experience

o Respond to your comments and questions and provide player support

o Send you related information, such as updates, security alerts, and support messages

o Enable you to communicate with other players

d) To show personalized advertisements.

To show you personalized advertisements in the Service we have a legitimate interest to process necessary data to:

o Track the content you access in connection with the Service and your online behavior

o Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section ‘Your rights and options’ below.

e) To keep the Service safe and fair.

Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the RELUDO Terms of Service.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

o Analyze and monitor use of the Service and its social features o Take action against fraudulent or misbehaving players

o To analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

WHO CAN SEE YOUR DATA

Apart from RELUDO S.r.l., your data can be accessed by others in the following situations:

o Other players and users.

Social features are a core component of our games. Other players and users may, for example, see your profile data, score, in-game activities.

o Partners working for RELUDO S.r.l.

RELUDO S.r.l has partners to perform services for us. These partners process your data only at and according to RELUDO ‘s instructions to provide the Service, such as hosting, player support, advertising, push notification, analytics and fraud prevention.

o Other companies and public authorities.

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

o Advertising and Social Media partners

The Service includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at http://www.reludo.com/privacy/optout_reludo.html These partners may access your data and operate under their own privacy policies.

We encourage you to check their privacy policies to learn more about their data processing practices.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

YOUR RIGHTS AND OPTIONS

o Opt-out of marketing push notification and other direct marketing.

You may opt-out of receiving promotional communications simply by uninstalling the application software from your device.

o Opt-out of targeted advertising.

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). For more information, see also: http://www.reludo.com/privacy/optout_reludo.html

o Access the personal data we hold about you.

If you request, we will provide you a copy of your personal data in an electronic format.

o Your other rights.

You also have the right to correct your data, have your data deleted (please contact us at: [email protected]), object how we use or share your data, and restrict how we use or share your data. You can provide the update, delete by yourself accessing to network platforms like Facebook or PlayFab or through the application software.

HOW DO WE PROTECT YOUR DATA

o Security Safeguards.

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS.

This paragraph supplements the information contained in the “Privacy Policy and Cookies” of RELUDO S.r.l. and applies only to California residents, defined as “consumers”, pursuant to the California Consumer Privacy Act of 2018 (” CCPA “).

RELUDO S.r.l., in fully complying with EU Regulation 2016/679, guarantees, even to citizens residing in the State of California, more restrictive privacy protections than the provisions of the aforementioned CCPA.

All general information in the previous paragraphs remains valid and in particular the categories of data processed (“The Data we collect”), the purposes of the processing (“Why we collect your data”), the recipients of the data or who contribute to the treatment (“Who can see your data”).

It also specifies the following.

The CCPA grants rights to California consumers:

The right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information;

The right to delete personal information held by businesses and by extension, a business’s service provider;

The right to opt-out of sale of personal information. Consumers are able to direct a business that sells personal information to stop selling that information. Children under the age of 16 must provide opt in consent, with a parent or guardian consenting for children under 13.

The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.

A consumer shall have the right to request that a business that collects personal information about the consumer disclose to the consumer the following:

The categories of personal information it has collected about that consumer.

The categories of sources from which the personal information is collected.

The business or commercial purpose for collecting or selling personal information.

The categories of third parties with whom the business shares personal information.

The specific pieces of personal information it has collected about that consumer.

RELUDO S.r.l. does not directly sell the aggregate personal data of consumers.

RELUDO S.r.l. sells advertising space, within its applications/games, to commercial partners, who can collect consumer data, in order to offer targeted offers or resell information, which contain the consumer’s personal data, to third parties.

The commercial partners of RELUDO S.r.l., independently determine the purposes and methods of the treatments and are required to guarantee the rights and privacy protections compliant with the applicable regulations.

The complete list of partners is shown in this document, users are invited to read their respective “Privacy Policies”.

Consumer rights under the California Consumer Privacy Act

Art. 1798.120.

(a) A consumer shall have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information. This right may be referred to as the right to opt out.

(b) A business that sells consumers’ personal information to third parties shall provide notice to consumers, pursuant to subdivision (a) of Section 1798.135, that this information may be sold and that consumers have the right to opt out of the sale of their personal information.

(c) A business that has received direction from a consumer not to sell the consumer’s personal information or, in the case of a minor consumer’s personal information has not received consent to sell the minor consumer’s personal information shall be prohibited, pursuant to paragraph (4) of subdivision (a) of Section 1798.135, from selling the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides express authorization for the sale of the consumer’s personal information.

(d) Notwithstanding subdivision (a), a business shall not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information. A business that wilfully disregards the consumer’s age shall be deemed to have had actual knowledge of the consumer’s age. This right may be referred to as the “right to opt in.”

Art. 1798.135.

(a) A business that is required to comply with Section 1798.120 shall, in a form that is reasonably accessible to consumers:

(1) Provide a clear and conspicuous link on the business’ Internet homepage, titled “Do Not Sell My Personal Information”, to an Internet Web page that enables a consumer, or a person authorized by the consumer, to opt out of the sale of the consumer’s personal information. A business shall not require a consumer to create an account in order to direct the business not to sell the consumer’s personal information.

(2) Include a description of a consumer’s rights pursuant to Section 1798.120, along with a separate link to the “Do Not Sell My Personal Information” Internet Web page in:

(A) Its online privacy policy or policies if the business has an online privacy policy or policies.

(B) Any California-specific description of consumers’ privacy rights.

(3) Ensure that all individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance with this title are informed of all requirements in Section 1798.120 and this section and how to direct consumers to exercise their rights under those sections.

(4) For consumers who exercise their right to opt out of the sale of their personal information, refrain from selling personal information collected by the business about the consumer.

(5) For a consumer who has opted out of the sale of the consumer’s personal information, respect the consumer’s decision to opt out for at least 12 months before requesting that the consumer authorize the sale of the consumer’s personal information.

(6) Use any personal information collected from the consumer in connection with the submission of the consumer’s opt-out request solely for the purposes of complying with the opt-out request.

(b) Nothing in this title shall be construed to require a business to comply with the title by including the required links and text on the homepage that the business makes available to the public generally, if the business maintains a separate and additional homepage that is dedicated to California consumers and that includes the required links and text, and the business takes reasonable steps to ensure that California consumers are directed to the homepage for California consumers and not the homepage made available to the public generally.

(c) A consumer may authorize another person solely to opt out of the sale of the consumer’s personal information on the consumer’s behalf, and a business shall comply with an opt out request received from a person authorized by the consumer to act on the consumer’s behalf, pursuant to regulations adopted by the Attorney General.

To exercise the rights illustrated above, we invite the consumer to send an e-mail to [email protected] with the subject “Request Rights provided by CCPA”.

RELUDO S.r.l. can provide services, including apps with simulators and video games, thanks to the financial support that its business partners recognize. The player or his/her parent / guardian on behalf of the minor, can interrupt the processing of his/her personal data for commercial purposes at any time but in this case RELUDO S.r.l. cannot guarantee services under the same economic conditions.

AGE LIMITS

If you are a minor under 14 years of age, to use our Services we must receive the consent of a parent (or guardian) who authorizes the processing of personal data, at the following e-mail address: [email protected], after reading this “Policy Privacy and cookies” information.

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 14 (or other different age limit per country considered as protected age) or knowingly allow such persons to use our Services. If you are under 14 (or other different age limit per country considered as protected age), please do not send any data about yourself to us, including your name, address, telephone number, or email address.

No one under the age of 14 (or other different age limit per country considered as protected age) may provide any personal data. If we learn that we have collected personal data about a minor under age 14 (or other different age limit per country considered as protected age), we will delete that data as quickly as possible. If you believe that we might have any data from or about a minor under the age of 14 (or other different age limit per country considered as protected age), please contact us at: [email protected].

USE OF COOKIES

What are cookies?

Cookies are small text files that the sites visited by users send to their terminals, where they are stored and then retransmitted to the same sites on the next visit. The cookies of the so-called “third party” are, instead, set by a Website other than the one the user is visiting. This is because on each site can be present elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the visited site.

What are cookies used for?

Cookies can be used for different purposes: execution of computer authentication, monitoring of sessions, storage of information on specific configurations concerning users accessing the server, storing preferences, etc.

Cookie Policy

The site (www.reludo.com) uses cookies to make its services simple and efficient for users who view the pages of this site.

Users who view www.reludo.com site will see minimal amounts of information inserted in the devices in use, which are computers and Mobile devices, in small text files called “cookies” saved in the directories used by the user’s web browser.

There are various types of cookies, some to make the use of the site more effective, others to enable certain features.

How can I disable cookies and manage user preferences?

Most browsers are configured to accept, control or possibly disable cookies through the settings.

However, we remember that disabling navigation or functional cookies can cause malfunction on websites and / or limit the service that we offer.

For more information on cookies and to manage your preferences on third-party profiling cookies, please visit the website of your browser.

TYPES OF COOKIES USED AND RELATED PURPOSES

Technical cookies

These cookies, always sent by the domain www.reludo.com, are necessary to correctly view the site and in relation to the technical services offered, they will therefore always be used and sent, unless the user changes the settings in the browser (thus affecting viewing the site pages).

Their use is not instrumental to the collection of personal identification data of users, but to improve navigation, such as returning to the same page if the internet connection is lost; or remember the preferences selected by the user while browsing.

Statistics

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”).

Google uses the personal data collected for the purpose of tracking and examining the use of this online space, compiling reports and sharing them with other services developed by Google.

Google may use personal data to contextualize and personalize the advertisements of its advertising network. Personal Data collected: statistical navigation data.

Place of treatment: USA

Other types of Cookies or third-party tools that may install them

Facebook social widgets (Facebook, Inc.)

are services of interaction with the social network Facebook, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data

Place of processing: USA

Policy privacy: https://www.facebook.com/policy.php

Twitter social widgets (Twitter, Inc.)

Social widgets are services of interaction with Twitter social network, provided by Twitter, Inc. Personal Data Collected: Cookies and Usage Data.

Place of processing: USA

Policy privacy: https://twitter.com/en/privacy

YouTube Video Widgets (Google Inc.)

YouTube is a video content display service managed by Google Inc. that allows this application to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data

Place of processing: USA

Instagram widgets (Instagram, Inc.)

Is an image visualization service provided by Instagram, Inc. that allows this site to incorporate content of this kind on its pages.

Personal Data collected: Cookie and Usage data.

Place of processing: USA

Discord

Discord, Inc. provides a social online and mobile chat platform via the Discord website, the Discord application (the “App”) and related Internet services. The Service is operated by Discord, Inc.

Personal Data collected: Cookie and Usage data.

Place of processing: USA

Legal references

The text of the Regulation EU 679/2016 and the rights of the data subject are available in extended form on Official Journal of the European Union: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L:2016:119:TOC

For more information on the Italian legislation regarding cookies visit: www.garanteprivacy.it/cookie.