EXTENDED PRIVACY POLICY FOR USERS OF SPACE GO GAMES AND WEBSITE USERS:
SPACE GO GAME STUDIO S.L. (hereinafter, "SPACE GO") wishes to provide users (hereinafter, the “Users”) who access SPACE GO games (hereinafter, the “Games” or the “Applications,” referred to collectively) available online and/or on the Apple Store and/or Google Play, as well as Users who access the website https://www.spacego.games (hereinafter, the “Website”), with this additional information on personal data protection (hereinafter, the “Privacy Policy”). In other words, this Privacy Policy applies to all our games, whether played online, on mobile devices, or on other platforms like Facebook. This Privacy Policy provides transparent and straightforward information about how personal data is processed, the purposes, the legal bases, how long data is processed, and the rights that Users can exercise. It will also always be available on the Website and accessible from all our games.
1. WHO IS RESPONSIBLE FOR DATA PROCESSING?
The company responsible for data processing is SPACE GO GAME STUDIO S.L. (hereinafter, “SPACE GO”), a company established under current law, with its registered office at Carretera Castellar, number 338, 08226, Terrassa (Barcelona), holding CIF number B-57.715.054 and registered in the Mercantile Registry of Barcelona, volume 47.666, Folio 146, Sheet B-558753, Entry 10ª.
If Users have any questions about how their personal data is processed, they can contact our Data Protection Officer at the following email address: dpo@spacego.games.
2. WHAT IS PERSONAL DATA AND DATA PROCESSING?
Personal data refers to any information about an identified or identifiable individual. An identifiable individual is someone who can be identified, directly or indirectly, particularly through an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to that individual’s physical, physiological, genetic, mental, economic, cultural, or social identity. Data processing refers to any operation or set of operations performed on personal data, such as collection, recording, storage, use, and communication.
3. THROUGH WHICH CHANNELS DO WE COLLECT PERSONAL DATA?
We collect Users' personal data through the following channels:
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Through access to our Games, available online and/or via the Application:
SPACE GO informs Users that, depending on the game they are accessing, registration as a User may or may not be required. SPACE GO offers Games that can be accessed as a guest, without registration, and others that require registration. Additionally, access to the Games may be possible through a Facebook, Google, or Apple account, in which case a registered user account on that platform is necessary.
From the moment a Game is accessed, SPACE GO assigns a User ID number to the player, allowing SPACE GO to identify and remember them. While a User ID is not directly identifiable as personal data, it can become identifiable when associated with additional information, such as name, email, or other information the User provides through interaction channels set up by SPACE GO.
When accessing SPACE GO via Facebook, Google, or Apple, or by downloading the Game application from the App Store or Google Play, SPACE GO stores the ID assigned by the social network or app, and if the User chooses to add their profile picture to their Game profile, SPACE GO can also access that picture. -
Through the use and enjoyment of the Games and the Website.
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Through User support services via the channels set up for this purpose.
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Through responses to satisfaction surveys.
4. WHAT PERSONAL DATA DO WE PROCESS AND WHAT PROCESSING DO WE PERFORM?
To provide legally required information on how we process Users’ personal data, we have detailed the personal data we process, the processing activities, purposes, legal bases, and retention periods in the following tables.
Conducting satisfaction surveys for statistical analysis:
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PURPOSES:
- Send satisfaction surveys to the User during gameplay.
- Contact Users by phone to better understand their experience and evaluation of our Games, when authorized.
- Analyze and segment responses provided by Users, as well as their gameplay, to create statistics.
- Obtain business values, satisfaction, profitability, quality, and game improvement. This does not involve segmentation or profiling activities of Users; only statistical analysis is performed.
- Understand the Users' experience and attempt to improve it or resolve any issues or complaints related to the services provided.
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PERSONAL DATA PROCESSED:
- Identifying data: IP address; User ID; Facebook ID; Apple or Google Play ID; IP address or device identifier.
- Contact details: phone number, if provided and expressly authorized.
- All information provided by the User when responding to surveys.
- Data related to Users’ gameplay: frequency of game login, levels completed, country or regions where the game is played, rewards enjoyed, and most purchased products.
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LEGAL BASIS:
- SPACE GO's legitimate interest in obtaining business values and understanding Users’ satisfaction with their gaming experience.
- The User's consent to be contacted by phone to better understand their experience and evaluation of our games.
- Users are informed that they can opt out of receiving satisfaction surveys by following the instructions in each communication received or by emailing supportinfo@spacego.games with their request. Likewise, Users can withdraw their consent to be contacted by phone via the same email address.
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RETENTION PERIOD:
- Personal data will be processed by SPACE GO while the relationship between Users and SPACE GO remains in effect unless they exercise their right to opt out of receiving satisfaction surveys, withdraw consent to be contacted by phone, or exercise their right to erasure.
- Subsequently, the personal data provided will be securely stored for the legally stipulated statute of limitations, which is five (5) years.
- After the maximum retention period, SPACE GO will anonymize or delete the User's personal data.
5. WHAT RIGHTS DO USERS HAVE OVER THEIR PERSONAL DATA?
A. Right of access:
Users have the right to know whether we are processing their personal data and, if so, what data we are processing.
B. Right to rectification:
Users have the right to modify inaccurate data and complete any incomplete data. Users must indicate which data they wish to modify and provide appropriate proof if necessary.
C. Right to object:
In legally stipulated cases, Users may object at any time, for reasons related to their particular situation, to the processing of their data. This right can be exercised whenever our legal basis for processing their personal data is the execution of the contract or their consent. If Users object to the processing, we will stop processing the personal data, potentially anonymizing or deleting it unless we can demonstrate legitimate grounds for processing that override their interests, rights, and freedoms. Users can also object to statistical analysis by emailing dpo@spacego.games with their request.
D. Right to erasure:
Users have the right to delete their personal data. This does not mean that their data will be completely erased, but it will be blocked to prevent processing, except for making it available to public administrations, judges, and courts for handling any potential liabilities arising from processing during the statutory period. The data will be permanently deleted or anonymized once this legal period has expired.
E. Right to data portability:
Users have the right to receive and/or transfer their personal data to another data controller other than SPACE GO. This right can only be exercised when the processing is based on the execution of the contract or their consent and is carried out by automated means.
F. Right to restriction of processing:
Users have the right to request that we suspend the processing of their data when (i) they contest the accuracy of the data while we verify it, or (ii) they exercise their right to object to the processing of their data while we determine whether our legitimate grounds override theirs. This right also allows Users to request that we retain their personal data when (i) the processing is unlawful and they object to the erasure of their data, requesting instead a restriction of its use, or (ii) we no longer need their personal data for processing purposes, but they need it for the formulation, exercise, or defense of claims.
Users can exercise their rights free of charge by sending their request in writing to the following email address: dpo@spacego.games, clearly identifying the right they are exercising. If we have difficulty identifying the User, we may request additional data or identification documents to confirm their identity and properly process their request. If Users believe that we have not satisfactorily met their rights, they may file a complaint with the Spanish Data Protection Agency (AEPD) by visiting the website http://www.aepd.es.
6. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
We do not disclose personal information provided by Users unless it is necessary for the fulfillment of a contracted service, such as communication with payment platforms, banks, and companies to facilitate transactions.
Similarly, we may disclose Users’ personal data to companies within the same corporate group and/or to third parties whose involvement is necessary to handle, manage, or resolve any claims regarding services or any other requests for information, inquiries, or petitions that Users have submitted through any of our contact channels, when such communication is necessary for the proper resolution of the request.
Other possible third parties to whom we may disclose data, upon legal request or when the basis for communication is the need to comply with an applicable legal obligation or the satisfaction of a legitimate interest pursued, with such legitimate interest being the initiation of legal actions or the exercise of defense against them, include the following:
- Legal advisors
- Courts and tribunals
- Tax Administration
- Regional Consumer Agencies
- Spanish Data Protection Agency
- Law enforcement agencies
Additionally, we may disclose Users’ personal data to third parties if we or substantially all of our assets are acquired by a third party, in which case the personal data we hold will be one of the transferred assets.
7. WHO CAN ACCESS THE DATA?
We work with service providers whose services are necessary for the proper functioning and usability of the Website and our information systems and who, by virtue of their activity, may have access to Users’ data in the capacity of Data Processors. This includes, for example, providers who help us improve and optimize our Website, technology service providers, or those who offer maintenance services for our databases and information systems. In all cases, these providers are considered Data Processors, and SPACE GO has previously signed data processing agreements with all of them that include appropriate guarantees regarding the processing of Users’ personal data and its confidentiality, integrity, availability, and accessibility.
8. ARE PERSONAL DATA SECURE?
We adopt appropriate procedures and information systems and implement the necessary technical and organizational security measures to ensure a level of security adequate to the risks that may arise from the processing activities described in this Privacy Policy. All information provided will be stored on secure servers. Once we have received all the User's information, we will use strict security procedures to try to prevent any unauthorized access. Likewise, we ensure that our service providers also have adequate security standards for the protection of personal data to which they have or may have access, in compliance with the applicable data protection legislation in force at all times. SPACE GO does not transfer Users' personal data outside the European Economic Area.
9. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may change over time due to possible changes in the criteria followed at any given time by the Spanish Data Protection Agency or other supervisory authorities, legislative amendments that may occur, and judicial rulings applicable to this Privacy Policy. SPACE GO reserves the right to modify this Privacy Policy to adapt it to such criteria, as well as to new legislative or jurisprudential developments.
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