APRIL 16TH 2019

Privacy Policy

Introduction

Our Privacy Policy is designed to help you understand what personally identifiable information we collect at VEA Games, how VEA Games uses it and what rights you have.

For the purposes of applicable data protection legislation, VEA Games, (“VEA Games”) is the controller of personal data provided by you and determines how and why your personal data will be processed.

Please note that this Privacy Policy applies to the following internet sites:

www.veagames.com

Should you have any questions about VEA Games’s processing of personal data or about this Privacy Policy, please refer to the last section on how to get in touch.

When we talk about the “Services” in this policy, we are referring to our websites, softwares and copyright assets and other services which we have licensed to our Customers. When we talk about “Personal Data” in this policy, we are referring to personally identifiable information you provide when using our Services or in any other contact with VEA Games, except for any anonymised Personal Data. When we talk about “Affiliated Parties” in this policy, we are referring to our partners, affiliated companies and third parties.

PLEASE READ THIS PRIVACY POLICY BEFORE USING VEA GAMES SERVICES. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

What Personal Data we collect?

We collect and process the following types of personal data about you:

Identification Data such as your name, street address, postal code, city, country, email address and project name.
Contact Data such as your billing address, and email address.
Financial Data such as your payment card details.
Transaction Data such as details about payments between you and VEA Games and other details of purchases made by you.
Technical Data such as your login data, internet protocol addresses, browser type and version, operating system and platform and other technology on the devices you use to access our Services.
Profile Data such as your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Usage Data such as information about how you use our website, products and Services.
Marketing and Communications Data such as your preferences in receiving marketing communications from us and your communication preferences.

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

VEA Games only collects Personal Data that it deems to be reasonably necessary to fulfill your online requests and our legitimate business objectives.

How we collect your Personal Data?
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by email or otherwise, including when you:
  - Order our products or Services;
  - Create an account on any of our sites;
  - Subscribe to our Services or publications;
  - Request resources or marketing be sent to you;
  - Enter a competition, prize draw, promotion or survey; or
  - Give us feedback.
- Automated technologies or interactions: As you use our Services, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and Google Analytics. Please see our cookie policy at VEA Games Cookie Policy for further detail
How and why we use your Personal Data?

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. The Type of Data in the chart below refers to the definitions described under section 1.

The most common legal/lawful grounds of our processing of your personal data are:

Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at info@veagames.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of Data

Lawful Basis for Processing

To register you as a new customer

Identification Data
Contact Data

Performance of a contract with you

To process your order including:

Manage payments, fees and charges
Identification Data
Contact Data
Financial Data
Transaction Data

Performance of a contract with you

To manage our business relationship with you which will include:

Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
To send you product and company updates
Identification Data
Contact Data
Profile Data
Marketing and Communications Data
Performance of a contract with you
Necessary to comply with a legal obligation, i.e. due to product liability, data protection legislation or accounting legislation.
Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

To enable you to partake in a prize draw, competition or complete a survey

Identification Data
Contact Data
Profile Data
Usage Data
Marketing and Communications Data
Performance of a contract with you
Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
Based on consent from you

To administer and protect our business and our Services (including troubleshooting, testing, system maintenance, support, reporting and hosting of data)

Identification Data
Contact Data
Technical Data

Performance of a contract with you

To use data analytics to improve or develop our website, products/Services, marketing, customer relationships and experiences

Technical Data
Usage Data

Necessary for our legitimate interests to define types of customers for our products and Services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about our different goods or services that may be of interest to you

Identification Data
Contact Data
Technical Data
Usage Data
Profile Data
Marketing and Communications Data

Necessary for our legitimate interests to develop our products/services and grow our business

Marketing communications

You will receive marketing communications from us if you have:

Requested information from us or purchased goods or Services from us; or
If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications, e.g. when you purchased goods or Services, or when you registered for subscription; and
In each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email.

You have the right to withdraw consent to marketing at any time. You can ask us to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by emailing us at info@veagames.com

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/Service purchase, product/Service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@veagames.com

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Cookies and Logs

A cookie is information a website places on your computer’s hard drive so that the website is able to remember your preferences and/or which pages you visited on the website and make your visit more efficient and enjoyable.

VEA Games may use cookies to determine the number of unique visitors to our Service over a given period, or to remember user account details, etc. so that the need for multiple log-ins is eliminated. We may combine information collected through cookies to any personal information submitted online when using the Service to help personalize your access to and use of the Service. Cookies may be disabled on your computer by indicating this in the preferences or options menus in your browser.

VEA Games may collect data in the form of logs. Log data collected on web servers supplies us with aggregate information about the number of visits to different pages on the Service and other navigational data. The variety of technical information we may log is:

IP address
Device information, including device name and IDs, hardware model, operating system and version, and mobile network information
Browser information
Cookie information
Date/time of access
Requested page(s)
Referring page(s)

For details you can take a look at our Cookie Policy here.

Your Rights on the Collection, Use and Distribution of Personal Data
1. Opt In/Opt Out

VEA Games allows you to monitor the way in which we use the personal information we obtain. Any promotional materials which VEA Games may send to you (e.g. "newsletters" or "information bulletins") contain internal mechanisms that allow you to block future mailings (Opt-out).

VEA Games also allows you to control if you want to share app usage data related to our Mixer and Bridge apps. These apps have built in mechanisms that allow you to opt out of sharing this information with us.

Right to Access, Rectify, Modify, Erase and Object

You have the right to request access, rectification, or erasure of your data that VEA Games has collected.

You also have the right to object or restrict, for legitimate purposes, the processing of your Personal Data, as well as the right to data portability. In case of restriction VEA Games may not be able to provide certain Services to you.

You may also withdraw your consent on receiving marketing communications and on sharing your data with us.

End Users who wish to deactivate their account may do so in accordance with the terms in the EULA (End User License Agreement). Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other End Users of the Software.

Removed information is retained for our own internal accounting purposes along with furnishing customer requests for old invoices.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please email us at info@veagames.com. Furthermore, you have a right to lodge a complaint regarding our processing of your data with the supervisory authority in the EU member state of your residence, place of work or place of the alleged infringement.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for accounting and tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Sharing and Disclosure of Personal Data.

We do not sell your data to any third party for marketing purposes. As a general rule, we will not forward your Personal Data to third parties without your permission. However, since we work in conjunction with partners, affiliated companies and third parties for the provisioning of our Services, we may have to share your personal data with them.

We may also disclose or share your data with:

Service providers who provide IT and system administration services.
Subsidiaries or other group companies.
Affiliated Parties.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions and applicable data protection law.

Legally Compelled Disclosures

We may disclose your Personal Data if required to do so by law or if we believe that such action is necessary to (a) conform to the law, comply with a judicial or court order or comply with legal process served on us or Affiliated Parties; (b) protect and defend our rights and property, the services, the users of the services, and/or our Affiliated Parties; or (c) act under circumstances to protect the safety of users of our services, us, or third parties.

International Data Transfers

VEA Games is based in Sweden, and your Personal Data is collected and processed in accordance with Swedish privacy laws and EU General Data Protection Regulation.

We strive to process all your data inside the EU/EEA (European Union/European Economic Area). However, VEA Games may share, store and process your information with third parties, out of which some may be located in countries outside the EU/EEA, such as the United States and any other country in which VEA Games maintains its facilities. When personal data is shared or transferred under these circumstances, VEA Games will ensure that the transfer will be subject to appropriate safeguards in accordance with applicable data protection legislation and that the level of protection is equivalent to that applicable in the EU/EEA.

In case of transfers to third parties with operations located in the US, for instance as regards VEA Games's use of services provided by Amazon, Google, Stripe, MongoDB and Mailchimp, VEA Games has ensured appropriate safeguards through these parties' accession to the EU-US framework, Privacy Shield, in accordance with Article 45 of the General Data Protection Regulation. You can read more about the framework here.'

VEA Games has taken steps to ensure that the Personal Data we collect is secure. We have also taken a range of technical and organizational measures to protect the confidentiality, security, and integrity of the Personal Data collected from you including protecting your data from unauthorized access, loss, change or deletion. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees, consultants and/or service providers.

We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. Such actions include, but are not limited to, physical controls, encryption, eligibility restrictions, policies, etc.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Privacy of Minors

VEA Games Services are not meant to be used by anyone under the age of 13. We do not knowingly collect Personal Data such as name and email address from children under 13 years old in the Service, unless expressly permitted by parent or guardian. We believe it is important to safeguard the privacy of children and encourage parents to regularly take an interest in their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has used the Service and provided Personal Data to us, please contact us at info@veagames.com and we will delete your child’s account and any related Personal Data.

Changes to our Privacy Policy

This Privacy Policy may be subject to change from time to time. If substantial changes are made to the Privacy Policy, VEA Games will notify you of these material changes by posting them on the Service and/or informing you by e-mail sent to the address provided by you to us, or if possible in some other manner. You are encouraged to check back and review this Privacy Policy from time to time so that you will always know what information is collected, how it is used and to whom it is disclosed. Your continued use of the Service subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.

VEA Games AB is the data controller of personal data provided by you. If you have any questions about this Policy, please contact us at info@veagames.com

APRIL 16TH 2019

Privacy Policy

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Introduction