‹1. WHO IS RESPONSIBLE FOR YOUR INFORMATION

Puffgames is the data controller with relation to the any Information collected by the Service and through your interaction with the Service (including through mobile devices).

2. THE INFORMATION WE COLLECT

We receive both Information that is directly provided to us, such as personal information you provide when you visit or participate in an activity on the Service, and information that is passively or automatically collected from you, such as usage information collected from your browser or device.

Information You Provide To Us. In order to participate in an activity on the Service such as a competition, or other similar activity, you may be required to provide some contact information such as name and email address and other Information such as a photograph or a video, depending on the specific activity. Additional details the collecting and processing will be provided at the point of collection and by the specific terms for participating in that activity.

Information That is Passively or Automatically Collected. We also receive Information when you visit the Service that is automatically collected from your browser or device such as page views, clicks, IP address, device ID (or equivalent), the name of your Internet service provider, and the type of browser you are using.

3. HOW WE USE YOUR INFORMATION

We use your Information for the following purposes:

3.1. To fulfil a contract, or take steps linked to a contract pursuant to Article 6(1)(b) of Regulation (EU) 2016/679 (“GDPR”):

(a) to provide the Service and to communicate with you about your account with us where we offer registration;

(b) to send you information about changes to our terms or policies;

(c) to allow you to take part in any competitions that we run from time to time, administer the competition, notify you if you have won, verify your identity, residency and other eligibility requirements, as applicable, deliver the prize and respond to any query you may have around the competition;

(d) to allow you to submit End User Content (as defined in the Terms of Use),and allow us to use the End User Content you submit in accordance with the Terms of Use or other more specific terms which may apply from time to time;

3.2. Where this is necessary for purposes which are in our, or authorised third parties', legitimate interests pursuant to Article 6(1)(f) of GDPR:

These interests are:

(a) to fulfil your requests and inquiries regarding the Service;

(b) to provide technical support (including testing, quality assurance, troubleshooting and security) for the Service;

(c) to analyse how the Service is used including search queries, frequency of viewing and length of viewing time, page views and clicks to help us manage and improve the Service and to develop new services;

(d) to manage the delivery of advertising, including the number of times the same advertisement is served and viewed

(e) to enforce our policies and terms of use, to check for potential illegal activity (such as copyright infringement or fraud);

(f) to run a survey or market research on the Service to understand our audience; and

(g) protecting the safety of our users.

3.3. Where you give us consent pursuant to Article 6(1)(a) of GDPR:

(a) to send you newsletters about our products and services and authorised third party products and services and to use technologies to check if these have been received and opened, in accordance with the additional information provided at the point of collecting your consent;

(b) if you are under sixteen and participate in an activity that requires consent, we will also make reasonable efforts to obtain your parents’ permission to process your Information pursuant to Article 8 of GDPR. We do not knowingly collect Information from anyone under sixteen for these types of activities without giving parents the option to consent to their child’s personal details being included in the applicable database for that activity. During the period when parental consent is being requested, the Information provided will be held on a temporary basis. If we do not receive your parent’s consent we will delete the information provided by you within a reasonable period in accordance with the specific terms which will be provided with relation to that activity. For purposes of this Privacy Policy, any reference to “parent” shall include legal guardian.

3.4. For purposes which are required by law pursuant to Article 6(1)(c) of GDPR;

(a) in response to requests by government or law enforcement authorities conducting an investigation.

(b) to comply with our legal obligations.

4. INFORMATION WE RECEIVE FROM AUTHORISED THIRD PARTIES

When you engage with our content through social media, or other non-Puffgames, sites or applications, you may allow those sites to share Information with us such as content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on.

The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.

5. INFORMATION SHARING AND DISCLOSURE

We share your Information:

(a) With service providers we have engaged to perform business-related functions on our behalf. For example, to: (i) conduct research and analytics; (ii) create content; (iii) provide customer support services; (iv) conduct or support marketing; (v) fulfil orders; (vi) host Services; (vii) provide technical or operational support; (viii) administer competitions or other user activity; (ix) maintain databases; and (x) otherwise support the Service;

(b) In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request;

(c) With authorised third parties if this will help us to enforce our policies and terms of use, to investigate, prevent take action regarding potential illegal activity (such as copyright infringement or fraud) or to protect the safety of other users of the Services; or

(d) If we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets.

6. COOKIES AND SIMILARTECHNOLOGIES.

We use cookies and other similar technologies to help provide Service and to analyse how you and authorised users use our Service. We also allow authorised third parties to use these technologies for similar purposes. Please see our Cookie Policy for more information.

7. OTHER IMPORTANT INFORMATION ABOUT YOUR PRIVACY

7.1. International Transfer

From time to time we may need to allow our service providers or assistance providers, who may be located outside the EEA, access to your Information. We may also make other disclosures of your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:

(a) we will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection such as Argentina, from where our affiliate Imagen Satelital S.A. provides support, security, infrastructure and maintenance services for our websites, or where we can be satisfied that alternative arrangements are in place to protect your privacy rights;

(b) transfers to our service providers and other authorised third parties will always be protected by contractual commitments and where appropriate further assurances, such as standard data protection clauses, certification schemes, provider’s Processor Binding Corporate Rules. and the EU - U.S. Privacy Shield for the protection of personal data transferred from within the EU to the United States of America. We have entered into standard data protection clauses with our US affiliate Puffgames which provides support, security, infrastructure, maintenance services for our websites.

(c) any requests for information we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out below if you would like further information.

7.2. Retention of Your Information

We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 3 of this Privacy Policy. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

Where we offer registration, we keep details of users who have registered with us for as long as you use the Service and your user account details for up to 18 months afterwards. We delete user profile information provided to us for the Service automatically when the registration for the Service is cancelled.

If you contact us with support queries, we keep the data for between 3 and 18 months, depending on the nature of the query and whether you have registered with us.

Where we process Information for marketing purposes, we process the Information while you remain interested in the marketing (for example, where you open and read our offers) and for three years after that point. If you ask us to stop sending marketing we will keep your Information for a short period after this (to allow us to implement your requests).

Where we process Information for a competition, we keep the data for 12 months form the day the competition ends unless a longer period is required by law.

Where we process Information with relation to the submission of End User Content, we will keep the data for as long as necessary in accordance with the specific terms of the activity.

8. YOUR RIGHTS

You have a number of rights in relation to your personal data. More information about each of these rights is set out below.

You have the right to ask us for a copy of your Information (Article 15 GDPR), to correct (Art. 16 of GDPR), delete (art. 17 of GDPR) or restrict (stop any active) processing of (Article 18 GDPR), your Information; and to obtain the Information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this Information with another controller (Article 20 of GDPR).

In addition, as far as the processing of your Information is based on our, or authorised third parties', legitimate interest, you have the right to object to the processing in accordance with Article 21 of GDPR.

These rights may be limited, for example if fulfilling your request would reveal Information about another person, or if you ask us to delete Information which we are required by law to keep or have compelling legitimate interests in keeping.

You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided. You can also opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails.

To exercise any of these rights, you can get in touch with our Privacy Office using the details set out below in Section 9. Please include your registration information, where we offer registration, such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes.

You also have a right to complain to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred, although we hope that we can assist with any queries or concerns you may have about our use of your Information.