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SIP GAMING SRL is committed to protect its user’s personal data in line with the requirements of applicable laws, namely of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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) (hereinafter: “GDPR”).

SIP GAMING SRL’s commitment applies to all individuals whose personal data the Company may process.

In accordance with GDPR “Personal Data” means any information relating to an identified or identifiable natural person.

This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data, when and with whom we share it and how we will keep it safe. It also details your rights in respect of our processing of your personal information and how you may exercise them.

Please take the time to read and understand this policy.

1.Who is processing your information?

SIP GAMING SRL, a registered company located in Bucuresti Sectorul 5, Strada Zării, Nr. 9, CAMERA 3, Etaj 3, is the data controller for all processing operations which involve your personal information. Contact information for the Data Protection Officer is located in the last section of this document.

2.What information do we collect, and how long do we keep it?

SIP GAMING SRL processes information:

a. You Give Us Directly such as:

  • Account information, including your email address, username, real name, country, date of birth, telephone number and password;
  • Information you provide when seeking help from us, such as your name, telephone number, and records (including call recordings) of the issues you experience; and
  • Billing/Payment information, such as your name, payment card number, payment account details.

b. We Collect When You Use Our Services such as:

  • IP address;
  • Information about your device, hardware, and software, such as your hardware identifiers, mobile device identifiers (like Apple Identifier for Advertising [IDFA], or Android Advertising ID [AAID]), platform type, settings and components, and the presence of required plugins;
  • Approximate geolocation data (derived from IP or device settings);
  • Browser information, including your browser type and the language preference;
  • Referring and exit pages, including pages viewed and other interactions with web content;
  • Internet or Electronic Network Activity information; such as, browsing history, search history, and information regarding interactions with our games, websites, applications, and/or advertisements.

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.

c. we get or generate from your use of our games or services.We collect information related to your game play and in-game activity, the services that you use and how you use them, and your devices and activities when you install or access our services.

d. we obtain data collected by the third-party cookies implemented on our application “Wild Goose” (e.g. Google, Facebook, Apple)

All personal information processed under this chapter are recorded/kept only for the period necessary to fulfill the purposes for which the data were collected, imposed by the applicable legal provisions in the field, respectively by the provisions on archiving.

3. How do we use your personal information

a. To contact you:

    • to respond to an inquiry or request for information;
    • to thank you for contacting us;
    • to welcome you to our game;
    • to communicate with you regarding your use of the Game; and
    • to notify you about changes/updates of the Game.
    • to confirm purchases using our services

It may be necessary for us to contact you for the performance of our services, but also for the purposes of our legitimate interests of maintaining our business relationship.

b. To Provide and Receive Services

When you create an account or purchase tokens we use the personal data provided to verify your identity and age and to provide services and carry out our obligations. The same applies to the personal data provided in relation to your player account.

The processing of players’ gameplay information is necessary for us to perform our contract with players of the respective Game. The information may also be necessary for maintaining, operating, developing, administrating, and supporting our services. The processing of gameplay information is necessary for reviewing, researching and developing our Services.

c. To identify and repair errors/debug;
d. To detect security incidents and protect our players against malicious, deceptive, fraudulent, or illegal activity;
e. To verify or maintain the quality of our products and services and to improve, upgrade, or enhance them for your convenience;
f. To Ensure Compliance with the General terms and conditions;
g. For Marketing Purposes;

4.What is the legal bases for processing your information?

a. For fulfilling the contract concluded between us;
b. Consent in the following situations:

    • Cookies – Information stored on your device so that we can better understand how our sites and apps are used and send more relevant offers to you.
    • Mobile push notification – Managed in the mobile device settings
    • Marketing communications.

c. Legitimate interests in the following situations:

  • Analytics & data segmentation
  • Training & development
  • Statistics/reporting
  • Troubleshooting and diagnostics
  • Data Privacy Notifications System
  • Social Media Content Management
  • Research and studies
  • Finance and accounting

d. Legal purposes in the following situations:

  • Legal compliance
  • Litigation or pre-litigation
  • Security monitoring and Investigations

5. To whom can we send your information?

  • Other group companies or affiliates – we may share your personal data with other group companies and our parent company for the purpose of improving and developing the Game.
  • Partners and service providers – we may disclose your personal data to third party contractors, consultants and suppliers in relation to their work for us. Personal data may for example be disclosed to external parties which provide us with IT services and third parties which assist us in administering, operating, maintaining and supporting the Game. In these cases we ensure that these third parties process your personal data in accordance with this Privacy Policy based on a specific data processing agreement.

In the event you make a payment on our site through a payment service provider, we may transfer your contact details, that is name, address and e-mail address, to the applicable payment service provider, where it is necessary for the execution of payment and/or other information deemed necessary to authorize financial transactions.

SIP GAMING Srl may disclose your personal data to law enforcement or other government officials, as SIP GAMING Srl, in its sole discretion, deems necessary or appropriate to investigate or resolve possible crimes or to respond to judicial, regulatory, agency or similar inquiries. Disclosure may also be necessary in emergency situations and to ensure the rights and safety of users/players, SIP GAMING Srl staff or third parties.

 

  • Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.
  • Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

6. International Transfer

The data SIP GAMING Srl collected from you is normally not transferred to companies/business partners outside the European Economic Area (“EEA”) or the European Union (“EU”). In general, our contractors, consultants and suppliers are located in the EEA and EU.

If situations which imply that your information will be transferred to and processed outside the EEA and the EU arise, we use European Commission approved Standard Contractual Clauses to protect your information.

7. What rights do I have?

Right of access – you have the right to request from us to provide you with a copy of the personal data that we hold about you.

Right of rectification – you have a right to request from us to correct the personal data we hold about you that is inaccurate or incomplete.

Right to be forgotten – you have a right to request from us in certain circumstances to erase your personal data from our records. In case that these circumstances apply to your case and provided that no exception to this obligation applies SIP GAMING Srl acting as your controller will erase your personal data from its records. There are certain types of personal data that SIP GAMING Srl is required by law to retain.

Right of portability – you have the right to request from us where certain conditions apply, to have the data we hold about you transferred to another organisation. Where these conditions apply the Company will transfer your personal data to another organisation.

Right to object – you have the right to object on grounds relating to your particular situation, to certain types of processing such as direct marketing or where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In respect to the aforementioned rights, we will respond to requests for personal data and, where applicable, will correct, amend or delete your personal data. You can send the relevant request to the following e-mail address: privacy@wildgoosegame.com

8. What level of security is applied to your personal information?

Ensuring security for the personal information you provided and that we learned from you is a priority for us that’s we implement and maintain physical, technical and administrative safeguards.

We implement appropriate technical and organizational measures such as data encryption, access management procedure, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy, etc. In addition, we will take reasonable steps to assure that third parties to whom we transfer any personal information will provide sufficient protection. We restrict access to your personal information to those employees who have absolute need of processing your personal information. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

Even so, please be aware that no security measure is 100% perfect. Thus, we cannot guarantee the security of your information at all times. You should always be diligent when it comes to the protection of your personal information.

9. Children’s personal data

We recognize the importance of protecting personal information about children. As such the User must fulfil certain age criteria in order to be able to play the game. We do not knowingly process personal information from or direct or target interest-based advertising to anyone under the age limit imposed by law or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age limit contact us at:  privacy@wildgoosegame.com

Please do not play our games or use our Services if you are under 13 years old.

10. How we treat your personal data for marketing activities

We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.

The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services. This information helps SIP GAMING Srl to improve its services, customize browsing experience and enables it to inform you of relevant products, services or promotions.

We can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.

You have the right to object at any time to the processing of your personal data for marketing purposes by contacting at any time our Data Protection Officer to the following e-mail address:   privacy@wildgoosegame.com

11. Further Information or Complaints

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority if you prefer.

Contact details for all Data Protection Authorities may be found at the level of the European Data protection Board – https://edpb.europa.eu/about-edpb/about-edpb/members_en

Address: 28-30 G-ral Gheorghe Magheru Bld. District 1, post code 010336 Bucharest, Romania

E-mail: anspdcp@dataprotection.ro and dpo@dataprotection.ro