- We are committed to safeguarding the privacy of the visitors to our websites and users of our mobile games.
- This policy applies where we are acting as a data controller with respect to the personal data of visitors to our websites and users of our mobile games ; in other words, where we determine the purposes and means of the processing of that personal data.
(please use the “Cookie Settings” link at the bottom of the page.
- In this policy, "we", "us" and "our" refer to SPYR, Inc. SPYR, Inc. is a company based in the United States. For more information about us, see Section 13.
- This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
- In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
- We may process data about your use of our website, services, mobile games ("usage data"). The usage data may include your IP address (anonymized, except as described in Section 3.11 below), mobile device ID, in-game user name or nickname, low level geographical location (country), browser type and version, device type, operating system, referral source, as well as information about the timing, frequency and pattern of your game use (which includes data about your gameplay such as progress within the game, in-game items and currency owned and in-game character choice). The source of the usage data is you. This usage data may be processed for the purposes of operating our service, securing our service and analyzing the use of the website and games. The legal basis for this processing is our legitimate interests, namely running, monitoring and improving our websites and games.
- We may process your account data ("account data"). The account data may include your user name or nickname within our games, your password(s), your email address, and, if applicable, your identification hash from external providers/portals. The source of the account data is you or the external provider/portal.] The account data may be processed for the purposes of operating and providing to you our websites and games and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our websites and business.
- We may process your information included in your personal profile on our websites or within our games. ("profile data"). The profile data may include your email address, user name or nickname, profile pictures and date of birth. The profile data may be processed for operating our services and games and providing necessary age check services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our websites, games and business.
- We may process information that you post for publication on our website or in one of our games through any comment, post or chat functionality] ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and games. The legal basis for this processing is consent.
- We may process information contained in any enquiry you submit to us regarding goods and/or services, including our games ("enquiry data"). The enquiry data may be processed for the purposes of responding to your enquiry or for offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
- We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include links to user accounts, such as Facebook, VK.com, Kongregate and any other account you may have on a portal through which you access our websites or games. The source of the customer relationship data is the third-party portal holding the relevant account. The customer relationship data may be processed for the purposes of managing our relationships with portals, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
- We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or within our games ("transaction data"). The transaction data may include the purchase price, the type of currency used (the chosen payment solution), the date of the transaction and the transaction identification hash. We do not process your bank account numbers or credit card numbers or information related to your accounts with external payment providers, which are only available and stored with our payment partners. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our websites and business.
- We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters and/or push notifications ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication and your email address or other information provided by you within the communication. Our website will generate the metadata associated with communications made using the website contact forms or support desk systems. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business and communications with users.
- We may process non-anonymized IP addresses in our system’s log files for security reasons, which data is deleted after no more than 7 days, though the data may be stored longer if anonymized, at which point identification to a particular individual is no longer possible. This data is not stored together with any other personally identifying data. The source of this data is you . This data may be processed for optimizing the service we provide through our websites and games and to secure our IT systems. The legal basis for this processing is our legitimate interests, namely protecting the security of our IT systems and optimizing the performance of our websites and games.
- We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
- In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Please do not supply any other person's personal data to us, unless we prompt you to do so. Never share your password with anyone, including us.
- Internet-Based Online Advertising and Google Analytics – If you have given your consent, Google Analytics, a web analysis service of Google LLC (“Google”) is used on the website https://www.stevenuniversetaptogether.com/. The use includes the “Universal Analytics” operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID (IP addresses will be anonymized) and thus analyze a user's activities across devices.
You may opt out of the automated collection of this data by third-party ad networks for the purpose of delivering advertisements tailored to your interests by visiting the consumer op-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/. You may edit or opt out of your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/. These opt-out and preference control pages are specific to you individual browser used to visit them and are not operated by or affiliated with SPYR. Therefore, SPYR is not able to perform any opt-outs or modify any preferences on your behalf.
- Facebook Pixel – We use Facebook Pixel on https://www.stevenuniversetaptogether.com/. Facebook Pixel is used for conversion tracking, which helps us measure the return on investment of Facebook Ads by tracking and reporting to us the actions people taking after viewing a Facebook Ad. We create pixels that track conversions and track conversions back to ads being run on Facebook. No personal information is contained in or collected as a result of using Facebook Pixel. Facebook is able to connect its pixel data with your Facebook account and use the data for its own advertising purposes, in accordance with Facebook’s Data Use Policy found at https://www.facebook.com/about/privacy/. Facebook conversion tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved on your computer for these purposes. If you would like to opt out of remarketing pixels and technologies, use the following links: https://www.facebook.com/ads/website_custom_audiences/ or http://networkadvertising.org/choices.
- Providing your personal data to others
- We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://www.spyr.com.
- We may disclose your personal data to our insurers and/or professional advisers, including but not limited to our accountants, auditor and attorneys, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, complying with any public company requirements, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may disclose your device IDs, usernames and data about your actions taken within our games to our analytics partners and we may provide your game usage data (times you play and similar information) to our marketing partners insofar as reasonably necessary for analyzing the performance of our games and for maximizing the effectiveness of marketing our games.
- Financial transactions relating to our websites and games are handled by our payment services providers, Xsolla, Apple, Google and Amazon. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
- In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
- We and our other group companies have offices and facilities in the United States Transfers to the United States will be protected by appropriate safeguards, including those set forth in our internal corporate controls.
- The hosting facilities for our websites and games are situated in Germany and the United States. Transfers to the United States will be protected by appropriate safeguards, namely including those set forth in our internal corporate controls.
- You acknowledge that personal data that you submit for publication through our website or in our games may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
- This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- We will retain your personal data as follows:
- Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of material changes to this policy by email or through push notifications for our games. We cannot do so if you have not provided us with your email address.
- Your rights
- In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
- Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
- You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by writing to email@example.com.
- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
- In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
- You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by written notice to us at firstname.lastname@example.org.
- About cookies
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
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- Our details
- This website and/or game is owned, operated or published by SPYR, Inc.
- We are a US company, formed under the laws of the State of Nevada and our primary office is located at 4643 S. Ulster St., Suite 1510, Denver, CO 80237.
- Our principal place of business is at 4643 S. Ulster St., Suite 1510, Denver, CO 80237.
- You can contact us:
(a) by mail to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
- European Data Protection Contact
- Our company contact for questions about data protection in Europe is Mr. Lars Koschin. You can reach our company contact via email@example.com.