Our Privacy Policy

1.1 Our Websites offer a diverse, and exciting mix of online games created by SPIL, as well as games created by independent developers and SPIL partners. Players can access our Websites to play games without registering; however, they may choose to register to create a public or private profile and to save games, high scores, and comments on this profile. Also, visitors to the Websites will be able to rate games and browse for the newly added, top-rated, and most-popular games. The Websites may include automated decision making in the form of behavioral advertising.

1.2 Certain games on our Websites are controlled by third parties, including third parties located outside of the European Economic Area (“EEA”). SPIL’s own hosting facilities for the Websites are located within the EEA. SPIL uses commercially reasonable efforts to ensure that any data processing that takes place on the Websites is in line with the applicable data protection laws. Privacy safeguards we take are contractual safeguards with third parties and the employment of technical privacy solutions, such as monitoring and blocking tools. However, as we do not control all games, data may be collected and transferred of which we are not aware. If you have concerns about data processing in a game, please send an e-mail to info@spilgames.com stating your concerns and the URL of the games.

2.1 SPIL collects information when you use or access our Websites. This information relates to how you use our websites including with what device, and may include information that you submit when creating an account with us or through your social network accounts such as Facebook or Google+. We may also collect information from ad network providers and other third parties such as payment service providers.

The information we may collect when you use our Websites includes (among others) the following:

• Your IP address;
• Demographic information (such as age and country);
• Information collected through cookies or similar technologies;
• When you choose to register with us for a better game experience and/or to create a public or private profile for participating in our social gaming network, we collect information such as username, email address, avatar and any information you may choose to provide, such as gender. This can be through a social network account;
• Information that you provide us when you fill in online forms or surveys on our Websites;
• Other information that we receive from you, e.g. your e-mails, chats or other communications and information exchanged with us on our social media channels;
• How you use our Websites, including when you play our games and interact with our advertising network providers;
• Transaction information of payments made;
• User agent of device;

IP address, Cookies, and Web Beacons

2.2 When you visit our Websites, our servers automatically save your computer's IP address via our analytics tracking system. IP addresses will be collected for the purpose of analytical tracking and improving the Websites, along with geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Websites. If you arrive at the Websites via a link from another website, the URL of the linking website and the URL of any website that you link to next will also be collected for the purpose of assessing our main traffic sources, and debugging and tracing.

2.3 In addition, we store certain information from your browser, using “cookies”. A cookie is a piece of data stored on the computer and is tied to information about the user. We will ask you to consent to the use of our Cookies in accordance with this Privacy Policy in case this is required under the applicable data protection laws when you first use our Websites. SPIL may use cookies, web beacons (web bugs), or similar technologies to enhance and personalize your experience on the Websites, including the following:

1. to operate and improve services and features on the Websites;
2. to help authenticate you when you are on the Websites;
3. to remember your preferences and registration information, as applicable;
4. to present and help measure and research the effectiveness of SPIL's offerings, advertisements, and email communications; and
5. to customize the content and advertisements provided to you through the Websites.

If you do not want SPIL to store any cookies on your computer, you can prevent this by changing your browser settings to “do not accept cookies”. Your browser manufacturer will provide you more details on how this works. However, we do inform you that you will not be able to use the Websites including its functionalities as intended. If you want to learn more about SPIL’s use of Cookies, please click here for our cookie policy.

2.4 SPIL uses analytics partners in order to help get insights into the usage of the Websites and services (“Usage Data”). These analytics partners process Usage Data which may include among others your IP address, geographical location, browser type and version, operating system, length of visit, page views and other information about how you use and navigate the Websites. This data is used to analyze the use of the Websites and to improve the Websites and services. Our analytics partners will act as a data processor in relation to the Usage Data. The legal basis for the processing of the Usage Data is legitimate interest.

2.5 SPIL also uses ad network providers, ad exchanges and ad servers (“Advertising Partners”) to help present advertisements on the Websites. These Advertising Partners use cookies, web beacons, or similar technologies for presenting, better targeting, and measuring the effectiveness of their advertisements, using data gathered over time and across their networks of web pages to determine or predict the characteristics and preferences of their audiences (“Advertising Data”). SPIL processes such information in accordance with this Privacy Policy. Our Advertising Partners may act as a data processor or data controller with regards to the Advertising Data, depending on the scope of their services. The Advertising Partners are responsible for their compliance with the applicable data protection legislation. The use of cookies, web beacons, or similar technologies by such third parties as ad network providers is subject to their own privacy policies, not this Privacy Policy. The legal basis for the processing of the Advertising Data is consent.

2.6 SPIL uses Facebook technology to provide certain services on the Websites. The Websites may include the “Facebook Like Button” which is controlled by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304 USA (Facebook). In the event you click on the Facebook Like Button, Facebook will ask you whether you want to log in to Facebook if you are not logged in at that moment, or register with Facebook. If you decide to do so, your personal data will be transferred to Facebook. In the event you are already logged into your Facebook account and you have given SPIL your explicit consent to the sharing of your information with Facebook, your information is shared with Facebook when visiting the Websites or playing games including the “Facebook Like Button”.
The Websites also use the “Facebook Pixel” controlled by Facebook in order to show conversions, create “lookalike audiences” and provide SPIL with relevant statistics about our Websites in order to improve them. When you use our websites and you have given SPIL your explicit consent to the sharing of your information with Facebook, your information is automatically shared with Facebook.
For more information on the “Facebook Like Button” and “Facebook Pixel” and sharing and use of your personal data please consult Facebook’s Data Policy at: https://www.facebook.com/policy.php.

2.7 SPIL may also use third-party payment service providers ("PSP"), offering payment transaction services to SPIL in order to sell a product or service through the Websites. The PSP acts a data controller with regards to the personal data related to the transactions (“transaction data”) processed for the purpose of purchasing the product or service. The transaction data may include your personal details, your payment card details, and the transaction details. Whenever you buy something from the Websites (e.g., a virtual game item), the information that you provide to the PSP is subject to their privacy policies, not ours. The legal basis for this processing is the performance of a contract. You explicitly consent that SPIL may provide personal information collected from you to a PSP for the purpose of the offering of the payment-transaction service whenever you buy something from the Website(s) and that such PSP may use such data for (statistical) analysis of payment transactions. After you have purchased a product or service, SPIL and the PSP have a legal requirement to retain your information for a legally determined period of at least 7 years. SPIL shall be allowed to notify a PSP regarding a user that engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person's rights, or that led to such a user's suspension or termination of use of the Websites.

2.8 SPIL uses third party service providers in order to offer our users customer support services. We may share personal data such as the communication content, IP address, e-mail address, and username (“Correspondence Data”) with these partners. The Correspondence Data may be processed by SPIL and business partners for the purpose of communication with you, blocking users, changing email addresses, reactivating or blocking accounts, adding or removing in-game items and other customer support services. The legal basis for the processing of the Correspondence Data is legitimate interest or consent depending on the service provided.

2.9 Most browsers are initially set to accept cookies, but you can (re)set your browser to refuse all cookies or to indicate when a cookie is being sent. You can opt out of receiving cookies from certain third-party advertising networks by resetting your browser. You may also use the following link to the Network Advertising Initiatives cookies opt-out pag or the link to the European Interactive Digital Advertising Alliance (EDAA) opt-out page. However, some features and services may not function properly if cookies are disabled.

2.10 You may choose to register with us for a better game experience and/or to create a public or private profile for participating in our social gaming network. This includes, for example: overviews of high scores, achievements listings and individual game recommendations on the Websites. When you register with us, you may provide us with certain personal data such as a username, gender, date of birth and your email address (“Account Data”). The Account Data you provide us will be used for the purposes of providing our services, improving our Websites, maintaining back-ups and communicating with you. The legal basis for this processing is consent.

The information you disclose in that respect may also become publicly accessible if you choose this privacy setting. We provide you with privacy settings that restrict other users from accessing your information; namely, our network architecture and your privacy settings allow you to make informed choices about who has access to your information. We allow you to choose the information you provide to friends and networks through our Websites. When your privacy settings permit it, other users may be able to see and supplement your profile (e.g., by posting comments).

2.11 If you decide to disclose information in a public venue or in games, we will consider that information as part of the public domain. This information will be accessible to any person who uses the Websites.

2.12 We only collect email addresses that were provided to us directly by you. Your email address will only be used for the following purposes:

1. the promotion of (new) games if you have given consent for this;
2. service emails (on updates, new design, new features, etc.);
3. administrative purposes, such as notification of violation of our Terms of Use;
4. delivering messages you have allowed us to pass on (e.g., from other people in your social network).

2.13 Without your approval, we will not:

1. use your email address for purposes other than those described in article 2.12 hereof;
2. transfer your email address or other personal information to third parties, except in those limited cases as described in this Privacy Policy.

You can revoke your consent to use your email address for promotional purposes at any time, including the newsletter by changing the privacy settings in your account or sending an e-mail to info@spilgames.com.

5.1 Your personal data may be stored by SPIL and its business partners.
In case the applicable data protection laws provide so, you have the right to access, rectify and erase the personal data we hold about you and to restrict or object to our processing of your personal data. To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time.

5.2 Users with a personal profile on the Websites that wish to exercise these rights, can mostly do so by clicking on the appropriate link in the personal profile. Furthermore, you can send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, The Netherlands, detailing your request, along with a copy of your passport (to prevent misuse of requests for information), or send an email containing this information to: info@spilgames.com. After the verification of your identity, the copy of your passport will be shredded.

5.3 SPIL does not knowingly process personal data from anyone under the age of 16 without parental consent. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data.
Parents of users under the age of 16: If you wish to have access to your child's personal data to view, correct, or delete the information that we have collected about your child, please send a written request to SPIL GAMES BV, Mussenstraat 15, 1223 RB, Hilversum, the Netherlands, detailing your request along with a copy of your passport (to prevent misuse of requests for information), or send an email with all such information to info@spilgames.com. After verification, the copy of your passport will be shredded.

6.1 You post personal data and any other content on the Websites at your own risk. Although we allow you to set privacy options that limit access to such personal data and other content, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you choose to share your profile and information. Therefore, we cannot and do not guarantee that any content you post on the Websites will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. You understand and acknowledge that, even after removal, copies of personal data or content may remain viewable in archived pages.

6.2 We have implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect online. Your personal data visible on the Websites (such as any public comments posted by you and/or any data in your profile) are accessible to third parties, and you acknowledge and agree that such third parties are able to copy such information to their own websites or other locations.

8.1 We reserve the right to amend our Privacy Policy. Amendments will be effective as of the moment of publication on the Websites. You should check the Websites regularly for amendments.

8.2 Our Websites may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave our site to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by us.

8.3 In the event of a transfer of (one of our) Websites to a third party, we may transfer to such third party all personal information that we collected about you in accordance with this Privacy Policy. In such an event, users who have provided email addresses to us will be notified when information about those users is transferred and becomes subject to a different privacy policy.

8.4 We also have Terms of Use that are applicable to your use of the Websites. In the case of a contradiction between the Terms of Use and this Privacy Policy, this Privacy Policy prevails.