Privacy Policy
Who is the controller of my data?
What type of data are we processing?
We only collect information that You provide directly to us, for example by creating an account, managing Your user profile, participating in interactive features of our Services, requesting any marketing communications, participating in a promotion or survey, requesting assistance or any other communication with us. We may also retrieve information from the Squingle videogame and combine it with information collected through our Multiplayer Services. The personal data provided (such as your user ID, user profile, and user age group, etc..), will in any case be processed and stored in electronic or paper files within a structure that takes all appropriate security measures imposed by the Privacy Code and the Privacy Regulation. Such data will be processed manually and/or digitally. No personal data of a particular or criminal nature will be processed.
How and for what purposes is my data processed?
Is the provision of data compulsory or optional?
Will you also process my data for marketing purposes?
Your data may also be processed, where specifically authorized by You, for the purpose of sending You communications regarding new applications, new web services, and other activities of the Controller, for promotional, commercial, marketing, and direct sales purposes. Such processing may take place either in paper form (e.g. filling in forms, coupons and similar paper documents) or by automated/computerized means, for secondary promotional, advertising or marketing purposes related to the promotion of services or Promotional Initiatives, by way of example but not limited to, sending newsletters via email with promotional or advertising messages (hereinafter “Processing for Marketing Purposes”). By giving consent, the interested party specifically acknowledges these Marketing Purposes in the broad sense of the treatment (including the management and administrative activities resulting from them) and expressly authorizes, once consent has been given in accordance with the procedures provided, said treatment both pursuant to Articles. 23 and 130 of the Privacy Code and pursuant to Article 6, paragraph 1, letter (a) of the Regulation. To proceed with the Processing for Marketing Purposes, it is mandatory to obtain a specific, separate, express, documented, prior, informed, free and completely optional consent. In the interests of absolute transparency, we therefore inform You that the data will be collected and subsequently processed on the basis of specific consent:
- to send to the subjects who have given conscious consent advertising and informative material (e.g. Newsletters), of a promotional nature or in any case of a commercial solicitation, in accordance with articles 23 and 130 of the Privacy Code;
- to carry out direct sales activities or placement of services of the Controller;
- to send commercial information; to carry out interactive commercial communications also pursuant to article 58 of Legislative Decree 206/2005, through the use of email;
- to process studies, research, and market statistics and carry out surveys by electronic means of communication;
- to send unsolicited commercial communications, pursuant to Article 9 of Legislative Decree no. 70 of April 9 2003 implementing the so-called Directive on Electronic Commerce 2000/31/EEC, which provides that unsolicited commercial communications must be immediately and unequivocally identifiable as such and must contain an indication that the recipient of the messages may object to the receipt of such communications in the future.
Therefore, by giving optional consent, the interested party specifically acknowledges and authorizes such further, possible secondary processing. We specifically and separately inform You, as required by Art. 21 of the Privacy Regulation, that if personal data is processed for direct marketing purposes, the person concerned has the right to object at any time to the processing of personal data concerning him/her carried out for such purposes and that if the person concerned objects to the processing for direct marketing purposes, personal data may no longer be processed for such purposes.
In this case, is the provision of data compulsory or optional?
The provision of personal data to VRAL Games and the provision of consent to the processing for marketing purposes for the purposes and in the manner described above is absolutely discretionary and optional (and in any case revocable without formality, even after the service, by sending an e-mail to privacy@vralgames.com) and failure to provide such data will not result in consequences other than the impossibility for the Controller to proceed with the marketing treatments mentioned. In case of refusal of consent to the processing for marketing purposes, there will be no interference and/or consequence regarding the possibility of using the Services.
Will my data be communicated to third parties?
The data processed for primary purposes may be communicated to any other third party when the communication is required by law. With reference to Art. 13, paragraph 1, letter (d) of the Privacy Code and Art. 13, paragraph 1, letter (e) of the Privacy Regulation, we proceed to indicate the subjects or categories of subjects who may come to know the personal data of the visitor as managers or agents and we provide below a list by category:
- VRAL Games personnel, appointed as data processors;
- third parties involved with VRAL Games’s processing activities and appointed as data processors;
Will my data be used for analytics?
VRAL Games processes the user’s information to derive its own statistics and enable the statistical services offered by third parties. We use analytics to support business analysis and operations, business intelligence, product and service development and improvement, content customization, and the provision of advertising and recommendations. VRAL Games may also work with third parties, such as Analytics or Unity, to analyze Your use of the Services. In any case, the data subject to statistical studies will be anonymous or pseudo-anonymized. For further information on Game Analytics or Unity, please refer to the respective websites:
https://gameanalytics.com/privacy
https://unity3d.com/legal/privacy-policy
Personal data will not be disclosed.
What about other marketing purposes?
For marketing purposes, Your data may be communicated to the following third parties who are subject to the Privacy Policy:
- VRAL Games personnel, appointed as data processors;
- third parties which are associated with VRAL Games’s processing activities and appointed as data processors;
The data will not be subject to further dissemination or communication. The updated list of subjects to whom the data may be communicated is available at VRAL Games.
How long will you keep my data?
Your personal data will be kept for the time strictly necessary to carry out the primary purposes already described.
Subsequently, the data will be stored in the VRAL Games database for sending communications relating to the applications You have subscribed to and for legal obligations. Furthermore, the five-year or ten-year terms for the storage of documents and related data of a civil, accounting, and fiscal nature, as provided for by the laws in force, remain unaffected. With reference, however, to personal data subject to processing for marketing purposes, the same will be kept for 5 years or less if the specific consent of the person concerned is revoked. The data collected are processed within the registered office and operational headquarters of the Data Processors. Pursuant to Art. 13, paragraph 1, letter (f) of the Privacy Policy, we inform You that all data collected will not be transferred to a third country or an international organization, either within or outside the European Union.
What if I want to delete my personal data?
If you wish to delete your personal data, please reach out to our team at privacy@vralgames.com. We will promptly remove any collected data and relevant information stored in our database at no cost.
What are my rights?
Pursuant to Article 7 of the Privacy Code and pursuant to Articles 13, paragraph 2, letters (b) and (d), 15, 18, 19 and 21 of the Privacy Regulations, we inform You that:
- a) You have the right to ask the Controller for access to Your personal data, the rectification or cancellation of the same or the limitation of the processing that concerns You or to oppose their processing, as well as the right to data portability;
b) You have the right to make a complaint for the protection of personal data
c) any corrections or cancellations or limitations to the processing carried out upon Your request – unless this proves impossible or involves a disproportionate effort – will be communicated by the Controller to each of the recipients to whom the personal data have been transmitted.
The Controller may notify You of such recipients if You request so. The exercise of the rights is not subject to any form constraint and is free of charge. For the sake of convenience, article 7 of the Privacy Code is reproduced in full below, while articles 15 to 23 of the Regulations can be consulted by following this link: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN
THE TEXT OF THE ARTICLE 7 OF THE PRIVACY CODE
Art.7
(Right of access to personal data and other rights)
- The data subject has the right to obtain confirmation of the existence or otherwise of personal data concerning him/her, even if not the party is not yet registered, and their communication is in an intelligible form.
- The data subject has the right to obtain the information on:
– the origin of personal data;
– the purposes and methods of processing;
– the logic applied in the case of processing carried out using electronic tools;
– the identification details of the owner, managers, and representative appointed under Article 5, paragraph 2;
– the subjects or categories of subjects to whom personal data may be communicated or who may become aware of it through their position: representative in the territory of the State, managers, or persons in charge. - The data subject has the right to obtain:
– the update, correction or, where relevant, integration of data;
– the cancellation, transformation into an anonymous form, or blocking of data processed in violation of the law, including the data the retention of which is not necessary for the purposes the data was collected or processed further;
– a certification that the operations referred to in letters a) and b) have been notified, also with regard to its content and to whom the data have been communicated or disseminated, unless this requirement proves to be impossible or involves the use of means manifestly disproportionate with respect to the right protected. - The data subject has the right to oppose, in whole or in part:
– for legitimate reasons to the processing of personal data concerning him/her, although pertinent for the purpose of collection;
– the processing of personal data concerning him/her for the purpose of provision of advertising material, direct selling, carrying out market research, or any commercial communication.
