EXTENDED PRIVACY POLICY FOR USERS OF SPACE GO GAMES AND USERS OF THE WEBSITE:

SPACE GO GAME STUDIO S.L. wishes to make available to users (hereinafter, the «Users») who access SPACE GO games (hereinafter, the «Games» or the «Applications» referred to together) available online and/or in the Apple Store and/or Google Play; as well as to Users who access the Website https://www.spacego.games (hereinafter, the «Website»); the present additional information on personal data protection (hereinafter, the «Privacy Policy«). In other words, this Privacy Policy applies to all of our games, whether they are played online, on mobile devices or on other platforms such as Facebook. This Privacy Policy provides in a transparent and simple manner all the information about the processing of personal data, the purposes, the legitimate bases, how long the data is processed and the rights that Users may exercise. Likewise, it will always be available on the Website and will be accessible from all our games.

1. WHO IS THE DATA PROCESSOR?

The company responsible for the processing is SPACE GO GAME STUDIO S.L. (hereinafter, «SPACE GO»), a company constituted in accordance with current legislation, with registered office at Carretera Castellar, number 338, 08226, Terrassa (Barcelona), SPAIN holder of tax number ESB-57.715.054 and registered in the Companies Register of Barcelona, volume 47.666, Folio 146, Page B-558753 Inscription 10ª.

In the event of having any doubts about the processing of personal data by us, Users may contact our Data Protection Delegate by e-mail at: dpo@spacego.games.

 2. WHAT IS PERSONAL DATA AND DATA PROCESSING?

Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is any person whose identity can be established, directly or indirectly, in particular by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements of that person’s physical, physiological, economic, cultural or social identity. A personal data processing operation is any operation or set of operations that we perform on personal data, such as collecting, recording, storing, storing, using and disclosing the data.

3. THROUGH WHICH CHANNELS DO WE COLLECT PERSONAL DATA?

We collect personal data from Users in the following ways: 

  • By accessing our Games, available online and/or on the App.

SPACE GO informs Users that, depending on the game they are accessing, it may or may not be necessary to register as a User. SPACE GO makes available to Users Games that can be accessed as a guest, without the need to register, and others in which it is necessary to register as a guest. It is also possible to access the Games from your Facebook, Google or Apple account, in which case you must be registered and have a user account on that social network or platform.

Either way, from the moment the Game is accessed, SPACE GO assigns a User ID number to the player, which allows SPACE GO to identify and remember the player as a User. For better reference, although an ID number is not a piece of information that directly identifies a physical person, it is a piece of information that allows the user to be identified or identifiable if it is associated with additional information, such as name, email address or any other additional information that the User provides through the interaction channels that SPACE GO has enabled for this purpose.

When accessing SPACE GO via Facebook, Google or Apple account or having downloaded the Game application through the App Store or Google Play, SPACE GO stores the ID that the social network or application has assigned and if the User wants to add the profile picture to their Game profile, SPACE GO can also access that picture. 

  • Through the use and enjoyment of the Games and the Website.
  • By means of the User service through the channels provided for this purpose.
  • By answering satisfaction surveys.

4. WHAT PERSONAL DATA DO WE PROCESS AND WHAT IS ITS PROCESSING PURPOSE?

In order to provide the legally required information on how we process Users’ personal data, we have detailed in the following tables the personal data that we process, the processing that we carry out, the purposes, the basis on which we are authorised to do so and how long we keep it for. All of this is shown individually for each processing operation in the following tables.

1. Manage access, use and maintance of the Games:

PURPOSES
  • Manage access to the Game, either as a guest or by registering.
  • Manage the account opening and registration as a User, in the event that it is necessary for you to register in the game and, if necessary, manage the account deletion process.
  • Manage the User’s interaction with the Game.
  • Enable interaction between Users through the Game chat and the multiplayer game option or mode.
  • Take the necessary measures to maintain the security of the Game and ensure compliance with the applicable regulations and the Terms and Conditions, such as prohibiting the use of photographs, profile usernames that are offensive or violate the dignity of persons, offensive messages in the chat and the creation of multi-accounts for fraudulent purposes, as well as the use of more than one account per User.
  • Crediting free rewards to the User’s account or profile.
  • To store the User’s progress and the passing of levels in the Game.
  • To send service communications (non-commercial) to those Users who provide their e-mail address when registering and this is linked to their personal User account.
  • To provide the User with a customer service through the means and channels enabled for this purpose at all times (such as e-mail supportinfo@spacego.games or application forms enabled for this purpose) in order to attend to and resolve any request for information, incident or query related to the products offered by SPACE GO.
  • To comply with applicable laws, prevent and avoid fraud, ensure compliance with our Terms and Conditions or, when necessary, defend or exercise the necessary legal actions in defense of our interests.

 

PERSONAL DATA PROCESSED
  • Identifying information: Full name or alias; gender; age; photograph in the case of Facebook account login or avatar in the case of Google or Apple and include such photograph or avatar in the Game profile account; user ID; Facebook ID; Apple or Google Play ID; IP address or device identifier. In the event that it is necessary for you to register for the game and create your own user account, we will also have access to your user name.
  • Contact details: Email address, if applicable.
  • Other personal data: country or region in which the User is playing.
  • Any other information that Users may provide when contacting us by any means or channel.
  • Data relating to the User’s game: frequency of game logins, levels passed, interactions and conversations between Users via chat or multiplayer gameplay.

LEGAL BASIS
  • The execution of the contractual relationship that binds SPACE GO with Users by accepting the general contracting conditions or terms and conditions.

CONSERVATION PERIOD
  • SPACE GO will process the personal data of Users while the contractual relationship with them is in force and while they maintain their User account or until the User communicates that they wish to unsubscribe or delete their account through their User profile.
  • Once the aforementioned periods have elapsed, SPACE GO will keep the personal data duly blocked for the legally stipulated period and/or the statute of limitations for any actions that may arise from the existing relationship, i.e. five (5) years for the exercise of personal actions.
  • Once the maximum period has expired, SPACE GO will anonymize or delete the personal data.
  • In the case of chats between Users, SPACE GO will keep the history of the conversations for the last three months, after which it will delete or anonymize them.

2. Manage the purchase of virtual products:

 

PURPOSES
  • Manage the purchase and payment of virtual products available in the Game (such as coins, among others) through Google Play and/or App Store.
  • To process the delivery of the products purchased so that they appear in the profile of each User.
  • To attend to and resolve any incident related to the contracted products.
  • Comply with the obligations legally required of SPACE GO.
  • Detect and prevent fraud or any other illegal action or event.

 

 

PERSONAL DATA PROCESSED
  • Identifying data: User ID; Facebook ID; photo in case of Facebook account login or avatar in case of Google or Apple account login and include such photo or avatar in the Game account; Apple or Google Play ID; IP address or device identifier. In the event that it is necessary for you to register for the game and create your own user account, we will also access your username.
  • Contact details: email address, if applicable.
  • Data relating to the contracting of services: purchase history, processing of complaints and returns, details of purchases made.
  • Data relating to the payment methods used, in the event of acquiring virtual products through the website of the Game that allows this method.
  • Any other information that the User may provide when contacting us.

LEGAL BASIS
  • The execution of the contractual relationship that binds SPACE GO with Users by accepting the general contracting conditions or terms and conditions.

CONSERVATION PERIOD
  • SPACE GO will process the personal data of Users while the contractual relationship with them is in force and while they maintain their User account or until the User communicates that they wish to unsubscribe or delete their account through their User profile.
  • Once the aforementioned period has elapsed, SPACE GO will keep the personal data duly blocked for the legally stipulated period and/or the statute of limitations for any actions that may arise from the existing relationship, i.e. three (3) years in consumer matters.
  • Once the maximum retention period has been reached, SPACE GO will anonymize or delete the personal data.

3. Conduct satisfaction surveys for statistical analysis:

PURPOSES
  • Send satisfaction surveys to the User during the enjoyment of the Game.
  • Contact Users by telephone to learn more about their experience and assessment of our Games, when authorized to do so.
  • To analyze and segment the answers provided by Users, as well as their game, in order to produce statistics.
  • Obtain business values, satisfaction, profitability, quality and improvement of the Games. This does not involve carrying out segmentation or profiling activities on Users. Only statistical analyses are carried out.
  • To know the experience of the Users and try to improve it or resolve any incident or complaint they may have had in relation to the services provided.

PERSONAL DATA PROCESSED
  • Identifying data: IP address; User ID; Facebook ID; Apple or Google Play ID; IP address or device identifier.
  • Contact details: telephone number, if provided and expressly authorised.
  • All information provided by the User when answering surveys.
  • Data relating to Users’ game play: frequency of game login, frequency of levels passed, country or regions from which the game is played, prizes enjoyed and most purchased products.

LEGAL BASIS
  • Legitimate interest of SPACE GO to obtain business values and to know the conformity and satisfaction of the Users in relation to their gaming experience.
  • The consent of the User to contact him/her by telephone in order to better understand his/her experience and assessment of our games.
  • In any case, we inform the user that he/she may object to the sending of satisfaction surveys by following the instructions available in each communication received, as well as to the statistical analysis by sending an email to supportinfo@spacego.games, indicating the request.
  • Similarly, through the same email address, the User may also withdraw the consent given to be contacted by telephone. 

CONSERVATION PERIOD
  • Personal data will be processed by SPACE GO for as long as the existing relationship between Users and SPACE GO is in force, unless Users exercise their right of opposition to the sending of satisfaction surveys; withdraw their consent to be contacted by telephone; or until they exercise their right of deletion.
  • Subsequently, the personal data provided will be kept duly blocked for the legally stipulated period of limitation of the actions that may arise as a result of the processing of their personal data, i.e. five (5) years.
  • Once the maximum period of data retention has been reached, SPACE GO will anonymise or delete the user’s personal data.

4. Analysis of the use, operation and improvement of the Website and our Applications:

PURPOSES
  • To adapt the Website and the Game to the type of devices used.
  • Adapt the Website and the Game to the personalization criteria chosen by Users and remember them.
  • To analyze the use and navigation made by Users, to detect the dates/times of greatest affluence and to detect navigation patterns.
  • Study possible improvements to optimize the usability experience and implement them..
  • To show personalized advertisements to Users based on their browsing habits and use of our Games.

PERSONAL DATA PROCESSED
  • Identifying data: IP address; device identifier.
  • Usage and browsing information: login data, browsing data, duration of the visit or session, browser data used, device data used, application version and operating system.

LEGAL BASIS
  • Consent of the Users.
  • SPACE GO’s legitimate interest to provide the Website and the Applications and to keep their functionalities operational in the case of technical and personalization cookies.

CONSERVATION PERIOD
  • We will process Users’ personal data for the periods specified for the different purposes in the or, where applicable, until the User withdraws his/her consent or exercises his/her right of deletion.
  • Subsequently, we will keep the data duly blocked for the legally stipulated period and/or the statute of limitations for any actions that may arise as a result of the processing of the personal data, namely two (2) years.
  • Once the maximum period of data processing has expired, we will anonymize or delete the data.

5. Deletion and blocking of personal data:

PURPOSES
  • Maintain an updated list of all those Users who have requested the deletion of their data or who at any time have objected to any of the processing that we carry out.
  • To comply with the obligations legally required of SPACE GO.

PERSONAL DATA PROCESSED
  • Identifying data: full name; User ID; Facebook ID; Apple or Google Play ID; Device ID.
  • Contact details: Email address.
  • Effective date of deletion or objection.

LEGAL BASIS
  • Compliance with a legal obligation, namely 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, which obliges SPACE GO to respect the rights of Users and to maintain evidence of compliance with the request to exercise the right of erasure and objection. The processing of personal data is necessary for SPACE GO to fulfil its legally enforceable obligations.

CONSERVATION PERIOD
  • We will process the data for as long as the relationship with the User is maintained or until he/she exercises his/her right to oppose or delete the data processing.
  • Subsequently, we will keep the data duly blocked for the legally stipulated period and/or the statute of limitations for any actions that may arise as a result of the processing of the personal data, namely three (3) years.
  • Once the maximum period of data processing has expired, the personal data will be anonymized or deleted.

5. WHAT RIGHTS CAN USERS EXERCISE OVER THEIR PERSONAL DATA?

A. Rights of access

Users have the right to know whether or not we are processing their personal data and, if so, to know what data we are processing.

 B. Right of rectification

Users have the right to modify data that is inaccurate and to complete data that is incomplete. In order to do so, Users must tell us which data they wish to modify and provide appropriate proof of this, if necessary.

C. Right of opposition

In the cases provided for by law, Users may object at any time, on grounds relating to their particular situation, to our processing of their data. This right may be exercised provided that our legitimate basis for processing their personal data is the performance of the contract or their consent. If Users object to such processing, we will stop processing their personal data and may anonymize or delete them, unless we can demonstrate legitimate grounds for the processing that override their interests, rights and freedoms. In any case, we remind the User that , as well as statistical analysis by sending an e-mail to dpo@spacego.games, indicating the request.

D. Right of deletion

Users have the right to cancel their personal data. This does not mean that their data will be completely deleted, but will be kept blocked in such a way as to prevent their processing, without prejudice to their being made available to public administrations, judges and courts for the attention of possible liabilities that may have arisen as a result of the processing during the period of limitation of the latter, being definitively deleted or anonymized once this legal period has elapsed.

 E. Right of portability

Users have the right to receive and/or transfer their personal data that they have provided to us to a data controller other than SPACE GO. It is only possible to exercise this right when the processing is based on the performance of the contract or on your consent and the processing is carried out by automated means.

F. Right of processing restriction

Users have the right to ask us to stop processing their data where (i) they have challenged the accuracy of the data, while we verify its accuracy; or (ii) they have exercised their right to object to the processing of their data, and while we verify whether our legitimate grounds override their legitimate grounds as a data subject. This right also allows you to ask us to retain your personal data where (i) the processing is unlawful and you as a data subject object to the erasure of your data, requesting instead a restriction on its use; (ii) we no longer need your personal data for the purposes of the processing, but need it for the formulation, exercise, or defence of claims.

Users may exercise their rights free of charge by sending us their request in writing to the following email address dpo@spacego.games always clearly identifying the right they are exercising. If we have difficulties in identifying the User, we may request that they send us some additional information or identification document in order to confirm their identity and correctly process their request. In the event of considering that we have not correctly satisfied the exercise of their rights, the User may file a complaint with the Spanish Data Protection Agency (AEPD), by contacting the website http://www.aepd.es.

6. TO WHOM DO WE COMMUNICATE THE DATA?

We do not disclose personal information that Users have provided unless it is necessary for the provision of a contracted service such as communication to payment platforms, banks and companies so that transactions can be carried out.

Likewise, we may communicate Users’ personal data to companies of the same corporate group and/or to those third parties whose intervention is necessary to process, manage or resolve any complaint about the services or any other request for information, query or request that Users have sent through any of our contact channels, when such communication is necessary as a result of said request for the correct resolution of the same.

Other possible third parties to whom we may communicate the data, subject to prior legal requirement or when the basis that legitimates the communication is the need to comply with an applicable legal obligation or the satisfaction of a legitimate interest pursued, said legitimate interest being the filing of legal actions or the exercise of defense before the same, are the following: 

  • Legal advisors
  • Courts and Tribunals
  • Tax authorities
  • Regional consumer authorities
  • Spanish Data Protection authorities
  • Government security forces.

We may also transfer Users’ personal data to third parties if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us will be one of the transferred assets.

7. WHO CAN ACCESS THE DATA? 

We work with suppliers whose services are necessary for the correct presentation and usability of the Website and our information systems and who, by reason of the exercise of their activity, may have access to Users’ data as Data Processors. This is the case, for example, of suppliers who help us to improve and optimize our Website, technological service providers or those who offer us maintenance services for our databases and information systems. In any case, these suppliers are considered to be Data Processors and SPACE GO has previously signed with all of them the corresponding processing contracts that include the due guarantees regarding the processing of Users’ personal data and their confidentiality, integrity, availability and accessibility.

8. IS PERSONAL DATA SECURE? 

We adopt the appropriate procedures and information systems and implement the necessary technical and organizational security measures to ensure a level of security appropriate to the risks that may be involved in the processing described in this Privacy Policy. All information provided will be stored on secure servers. Thus, once we have received all the User’s information, we will use strict security procedures to try to prevent any unauthorized access. We also ensure that our service providers also have appropriate security standards for the protection of personal data to which they have or may have access, in accordance with the applicable data protection legislation in force at any given time. SPACE GO does not transfer Users’ personal data outside the European Economic Area..

9. CHANGES TO THIS PRIVACY POLICY  

This Privacy Policy may vary over time due to possible changes in the criteria followed at any given time by the Spanish Data Protection Agency or other supervisory authorities, any legislative changes that may occur and any jurisprudential pronouncements that may be applicable to this privacy policy. SPACE GO reserves the right to modify this Privacy Policy in order to adapt it to such criteria, as well as to new jurisprudential or legislative developments.

Latest version: 27th September 2023