EFFECTIVE DATE: MAY 25TH, 2018
1. VISIT TO OUR WEBSITE
Every time you visit our website LDRLY Games, our system automatically collects data and information from your computer system.
The following data is collected and stored in log files:
Information about the browser type and version used
The user’s operating system
The Internet service provider of the user
The IP address of the user
Date and time of access
Websites from which the user’s system reaches our website
Websites accessed by the user’s system via our website
The log files contain IP addresses or other personal information. The data is stored in the log files of our system. This data is not stored together with other personal information of the user.
2. PERSONAL INFORMATION WE COLLECT
We only collect and use personal information of our users insofar as this is necessary to provide the Services. We only collect and process personal information only with the user’s consent or in those cases in which the collection and processing of the personal information is permitted by law.
We collect your personal information in the following circumstances:
to register for the Services, we may collect your name, email address, state/province and country of residence, zip/postal code, birthdate and gender;
when you signup for a LDRLY newsletter, we collect your name and email address;
if you connect the Services to a social media account, such as Facebook, we collect your name, email address, profile picture, age range, gender and other information you make public on Facebook, in addition to your friend list (unless you affirmatively revoke such collection);
we collect your geolocation data when you use the Services, which we associate with your personal and anonymous information;
if you contact us for customer service, we may collect your email address, first and last name and, if required, Facebook information, and associate this personal information with anonymous information, such as information about your device.
Please note that while the Services may allow you to visit as a guest and remain anonymous, you may not be able to access all content and features without providing personal information.
3. ANONYMOUS INFORMATION WE COLLECT
We collect anonymous information from you, which may be provided to us by a third party, including but not limited to:
metrics and other types of statistical data, which could be derived from your use of the Services, for example how you interact with the Services;
how you access the Services, for example, computer operating system and web browser, type of mobile device and unique device identifier, device settings, SDK version, mobile advertising identifier (Apple IDFA, Google Advertising ID or Android ID), MAC address, IP address, Wi-Fi information, your "click path" through the Services and the web site or advertisement that was linked to or from the Services;
diagnostic information concerning the Services, for example, logs, error reports and events and the type, number, date and page relating to this information; and
apps you have installed and enabled and how you use those applications.
Please note that while your computer or mobile device may allow you to turn off the collection of some of the above information, you may not be able to access all content and features on the Services.
4. HOW WE USE YOUR INFORMATION
We use your personal and anonymous information internally for purposes that include:
to provide the Services to you, such as hosting and displaying information, providing updates, developing, improving or expanding the Services and addressing technical issues;
to generate and analyze information about our users so we can better understand them and how they use the Services and draw trends and predictions based on this information;
to serve you advertisements, provided by LDRLY or third parties, on the Services, as well as for marketing and promotional purposes;
to send Service-related push notifications to your device;
to establish and maintain your account on the Services and to protect the security of your account;
to provide customer support or to resolve customer issues;
to inform you of changes to the Services, such as outages, suspensions or other material changes, which could occur through email or a push notification sent to your device; and
if you signed up for any LDRLY newsletter, to contact you by email for LDRLY news, promotional purposes or market research and that you may opt-out of by clicking an opt-out link located in such an email.
5. INFORMATION DISCLOSURE
We disclose your information outside of LDRLY for the following purposes:
for internal LDRLY purposes, we may disclose your personal and anonymous information to our parent companies, affiliates, subsidiaries and contractors; for a list of plug-ins we use, click here.
we disclose your information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, other suspected illegal activities or as otherwise may be required by applicable law or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of LDRLY; and
6. COOKIES AND THIRD PARTY SERVICES
You consent to us using tracking technologies, such as cookies, web beacons and clear gifs, (“Tracking Technologies“) which assist us to analyze the Services’ functionality, analyze technical issues, send useful notifications to user devices, track use of the Services and generate reports and data models that we use to improve the Services.
We use third parties, who we share your information with. These third party services may be embedded into the Services, such as through an API or SDK, or may take the form of Tracking Technologies which enable these third parties to collect information on our behalf and who may collect information from you to assist us with, for example, serving advertisements, fulfilling a purpose you requested of us (for example, billing services), customer support and feedback, analyzing Services functionality and technical issues, sending useful notifications to user devices, tracking use of the Services and generating reports and data models that we use to improve the Services.
A list of third party services used by LDRLY, and corresponding privacy policies, is available by contacting us at: firstname.lastname@example.org
You may be able to opt-out of mobile behavioral advertising by accessing the settings on your Apple or Android device and selecting the appropriate advertisement tracking settings.
8. SERVICE COMMUNICATION FEATURES
Your username and profile picture on the Services are visible to other users of the Services. We recommend you exercise discretion when selecting your username and profile picture and when using the Services. Personal information disclosed by you within our chat areas, instant message service, message boards or during use of the Services can be collected by other users and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our Services (for example, sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our Services, you are solely responsible for its content and accuracy. To edit, change, or delete the above information, follow the instructions provided in the Services.
A cookie is a file that is sent by a service through your browser to your computer, if your browser is enabled to accept cookies, in order to store certain information on your computer and communicate with a service while you are online. Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. You should refer to your browser instructions or "Help" screen to learn more about how to manage cookies. Please note that, if you block cookies, some portions of the Services may not function properly.
10. CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track, or DNT, is a web browser setting that requests that a web application disable its tracking of you. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter while browsing to stop tracking your activity. Currently, there is no DNT technology standard and, as a result, the Services do not respond to DNT signals.
11. CALIFORNIA "SHINE THE LIGHT" RIGHT
If you are a California resident, California Civil Code Section 1798.82 grants you the right to request LDRLY's disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would to make this request, please contact us at email@example.com or:
LDRLY (Technologies) Inc
Attn: Legal / Privacy Officer
550-555 W 12th Ave
Vancouver, BC V5Z 3X7
Please note that you may only make this request once per year.
12. ACCESSING OR CHANGING INFORMATION YOU PROVIDED TO US
You may contact LDRLY to obtain a copy of any personal information we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact LDRLY to correct or delete such information, except to the extent that retention is necessary for our legitimate business purposes, required by applicable law, in the control of a third party or where correction or deletion is not technically feasible.
If you have any questions or would like to access or change your information via email, please contact us at firstname.lastname@example.org.
13. INFORMATION STORAGE AND RETENTION
While LDRLY is a Canadian company, the data you provide through the Services is stored and processed by third parties in countries around the world. You authorize LDRLY and third parties acting on LDRLY's behalf to use and process your data in any country of their choosing, which may cause your data, including personal and anonymous information, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.
Your personal information is retained until you request its deletion pursuant to section 12 or until LDRLY no longer requires such information for the purpose for which it was collected.
14. INFORMATION FOR EUROPEAN UNION PERSONS
a) Legal basis for the processing of personal information
Insofar as we obtain the consent of the data subject for the processing of personal information, Art. 6 para. 1 lit. a GDPR serves as the legal basis.
If the processing of personal information required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to steps at the request of the data subject prior to entering into a contract.
Insofar as the processing of personal information is processing is necessary for compliance with a legal obligation to which LDRLY is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
In the event that processing of personal information is necessary in order to protect the vital interests of the data subject or of another natural person, Art. 6 para 1 lit. d GDPR serves as the legal basis.
In the event that processing of personal information is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in LDRLY, Art. 6 para 1 lit. e GDPR serves as the legal basis.
If processing of personal information is necessary for the purposes of the legitimate interests pursued by LDRLY or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal information, in particular where the data subject is a child, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for processing.
b) Retention of personal information
The personal information will be deleted or access will be restricted as soon as the purpose of storage ceases to apply. The data will also be deleted or access will be restricted if a storage period expires, unless there is a need for further storage of the personal information for the conclusion or fulfilment of a contract.
c) Visit to the website ldrlygames.io
The legal basis for the temporary storage of the data identified in Section above in log files is Art. 6 para. 1 lit. f GDPR.
The purpose of data processing the temporary storage of the IP address by the system is necessary to enable the website to be accessed by to the user’s computer. For this reason, the IP address of the user must remain stored for the duration of the session. The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. These are our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR. An evaluation of the data for marketing purposes does not take place in this context.
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it collected.
If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that the personal information is anonymized.
The collection of data for the provision of the website and the storage of data in log files is necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
Our Website makes use of Google Analytics, a Web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files which are saved on your computer and through which an analysis of website usage is enabled. The information generated by the cookie about your usage of this website is normally transmitted to a Google server in the USA and saved there. In case of activation of the IP anonymisation of this website, your IP address will however first be abbreviated by Google within the member states of the European Union, or other contracting member states of the Treaty of the European Economic Area. Only in exceptional cases shall the full IP address be transmitted to a Google server in the USA, and then be abbreviated there. On our behalf, Google will use this information in order to analyze your use of the website, to compile reports regarding website activities and to render further services to us associated with website and Internet usage. The IP address transmitted by your browser within the scope of Google Analytics will not be combined with other data from Google. You can prevent the storage of cookies by setting your browser appropriately; however it should be noted that in this case it may not be possible to use all functions of this website to their full extent. Furthermore, you can prevent the recording of data generated by the cookie and data related to your usage of the website (incl. your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link.
For more information, please
d) Cookies and third party services
The legal basis for the processing of personal information using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.
The legal basis for the processing of personal information using cookies for analytical purposes is, in the case of existing consent, Art. 6 para. 1 lit. a GDPR.
e) Email newsletter
You can subscribe to a free newsletter. When registering for the newsletter, the personal information namely name and email address, is transmitted to us. No personal information is passed on to third parties. The data will be used exclusively for sending the newsletter.
The collection of the user’s e-mail address serves the purpose of sending the newsletter.
The legal basis for the processing of personal information using cookies for analytical purposes is, in the case of existing consent, Art. 6 para. 1 lit. a GDPR.
The personal information will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The user’s e-mail address will therefore be stored for as long as the subscription to the newsletter is active. The user may cancel the subscription to the newsletter at any time by clicking on the unsubscribe link at the end of each email newsletter.
f) Registration to the Services via Facebook
In order to use some of our Services, you may register by providing personal information via Facebook (see above). The data will not be passed on to third parties.
The registration is necessary to access the Services through Facebook Gameroom.
The legal basis for the processing of personal information in the course of the registration is a contractual relation according to Art. 6 para. 1 lit. b GDPR.
The personal information will be deleted once the respective game was removed from Facebook Gameroom. You may at any time remove the game from Facebook Gameroom. If the personal information is required to fulfil a contract, premature deletion of the personal information is only possible if LDRLY is not bound by contrasting contractual or statutory obligations.
g) Rights of the data subject
If your personal information is processed, you have the following rights vis-à-vis LDRLY. To invoke those rights, please send an e-mail to email@example.com specifying the type of request.
aa) Right of access
You have the right to obtain from LDRLY confirmation as to whether or not personal information concerning you are being processed, and, where that is the case, access to the personal data and the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from LDRLY rectification or erasure of personal data or restriction of processing of personal information or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from you, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Art. 22 para. 1 and 4 and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.
bb) Right of rectification
You have the right to obtain from LDRLY within undue delay the rectification of inaccurate or incomplete personal information. Taking into account the purposes of the processing, you shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
cc) Right to erasure (‘right to be forgotten’)
You shall have the right to obtain from LDRLY the erasure of personal information concerning without undue delay and LDRLY shall have the obligation to erase personal information without undue delay where one of the following grounds applies:
the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you withdraw consent on which the processing is based according to Art. 6 para.1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, and where there is no other legal ground for the processing;
you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para 2 GDPR;
the personal information has been unlawfully processed;
the personal information has to be erased for compliance with a legal obligation in the European Union
the personal information has been collected in relation to the offer of information society services referred to in Article 8 para.1.
Where LDRLY has made the personal information public and is obliged pursuant to the above to erase the personal information, LDRLY, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The right to erasure shall not apply to the extent that processing is necessary:
for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing by the European Union or for the performance of a task carried out in the public interest
for the establishment, exercise or defence of legal claims.
dd) Right to restriction of processing
You shall have the right to obtain from LDRLY restriction of processing where one of the following applies:
the accuracy of the personal data is contested by yourself, for a period enabling LDRLY to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal information and requests the restriction of their use instead;
LDRLY no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
You have objected to processing pursuant to Art. 21 para. 1 pending the verification whether the legitimate grounds of LDRLY override those of the data subject.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
If you have obtained restriction of processing pursuant to the above, you shall be informed by LDRLY before the restriction of processing is lifted.
ee) Right to data portability
You have the right to receive the personal information, which you have provided to LDRLY, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal information have been provided, where:
the processing is based on consent pursuant to Art. 6 para 1 lit. a or Art. 6 para 1 lit. b or Art. 2 para 2 lit. a
the processing is carried out by automated means.
The right shall not adversely affect the rights and freedoms of others.
In exercising your right to data portability you shall have the right to have the personal information transmitted directly from one controller to another, where technically feasible.
The exercise of this right shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
ff) Notification regarding rectification or erasure of personal data or restriction of processing
LDRLY shall communicate any rectification or erasure of personal data or restriction of processing carried to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. LDRLY will inform you about those recipients if the you request it.
gg) Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning him or her which is based on Art. 6 para. 1 lit e) or lit. f). LDRLY shall no longer process the personal information unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal information is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.
At the latest at the time of the first communication with you, the right referred to above shall be explicitly brought to your attention shall be presented clearly and separately from any other information.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise his or her right to object by automated means using technical specifications.
hh) Automated individual decision-making
The you shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.
This shall not apply if the decision:
is necessary for entering into, or performance of, a contract between you and LDRLY
is authorised by European Union law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
is based on your explicit consent.
LDRLY shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of LDRLY, to express his or her point of view and to contest the decision.
Decisions shall not be based on special categories of personal data referred to in unless Art. 9 para.2 lit. a) or lit g) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
ii) Right of complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the European Member State where you reside, work or suspect of infringement, if you believe that the processing of personal information concerning you is not in compliance with GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.
15. IF YOU ARE UNDER THE AGE OF 13
LDRLY complies with the U.S. Children's Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. If you are under the age of 13, you may not create an account on or use the Services. LDRLY will not knowingly collect, maintain, or disclose any personal information from children under the age of 13.
16. IF YOU ARE BETWEEN THE AGE OF 13 AND 18
17. INFORMATION FOR PARENTS/GUARDIANS
LDRLY encourages parents and guardians to spend time online with their children to become familiar with the types of content available on the Internet, including our Services. Parents and guardians should regularly oversee their children's use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.
If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, LDRLY will take reasonable steps to remove that information from the LDRLY database at your request. To request removal of your child's information, please send an e-mail to firstname.lastname@example.org.
While LDRLY takes precautions against possible breaches in the Services, no website, application or Internet transmission is completely secure. For example, LDRLY employs a security technology known as a secure-socket-layer, or SSL, to protect the transmission of critical account information through the Services. However, LDRLY cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Services is at your own risk. LDRLY urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account and closing your web browser.
20. EMAIL AND PUSH NOTIFICATION PREFERENCES
We communicate with our users primarily by email. If you would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within emails that we send to you. If you would like to opt out of receiving push notifications from LDRLY, to the extent permitted, you may do so by changing the notification settings on your device.
21. OTHER IMPORTANT AGREEMENTS THAT GOVERN YOUR USE OF THE SERVICES
22. CONTACT US
LDRLY (Technologies) Inc
550-555 W 12th Ave
Vancouver, BC V5Z 3X7
Representative in the European Union according to Art. 27 GDPR:
Dr Christian Rauda
GRAEF Rechtsanwälte Digital PartG mbB
Tel. +49.40.80 6000 9-0
Fax +49.40.80 6000 9-10