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“Personal Data” shall mean any information relating to a Data subject; an identifiable person is one who can be defined, directly or indirectly, notably by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Contact data and Service Data are Personal Data.
“Contact Data” means any names, phone numbers, e-mail addresses and certain financial details held within commercial systems to conduct the Parties’ relationship management and billing transactions between the Parties.
“Controller”, “Data Subject”, “Personal Data”, “Process/Processing” and “Processor”, shall have the same meaning as in the European Union Directive 95/46/EC or the General Data Protection Regulation 2016/679 of April 27th, 2016.
“Third Country” means a country that is: (i) outside of the European Economic Area; and (ii) not the subject of a formal decision by the European Commission, made pursuant to Section 25(6) of the European Union Directive 95/46/EC or under Article 45 (1) of the General Data Protection Regulation 2016/679, stating that that country ensures an adequate level of protection for personal Data.
Information collected through the Platform
CAER SIDI may also collect and process other information when you interact with the Games online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Platform. Such information will be collected and processed irrespective of whether you only access the Platform or if you actually play the Games. CAER SIDI may also collect and process certain information when you as a user with a user account interact with the Games such as the information in your personal profile, the relationships you form in the Games, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.
Information collected through other sources
CAER SIDI may also collect information about you from other sources, such as third party sites or platforms, newspapers, blogs, instant messaging services, and other End Users of the Platform through the operation of the Platform in order to provide you with more useful information and a more personalized experience.
Logfiles. Log files are files that log actions that have occurred on a website. CAER SIDI may collect data in the form of log files and may use such log files to gather statistics about End Users user habits and to assess overall Games activity, including how many "hits" a particular web page is getting and other navigational data. These entries are generated anonymously, and enable CAER SIDI to track interest in specific promotions, troubleshoot technical concerns, and provide End Users with content that may be of interest to them. Log files are used internally only, and are not associated with any particular user, computer, or browser.
Web beacons. The Platform may use a variety of technical methods for tracking purposes, including “Web beacons” etc. Web beacons are small pieces of data that are embedded in images on the pages of the Platform. We may also use these technical methods to analyze the traffic patterns in the Games such as the frequency with which End Users accesses various parts of the Games etc. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML emails that we send our End Users to determine whether our End Users have opened those emails or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.
CAER SIDI will use information about you for the following purposes in accordance with applicable laws:
Information is provided by you or collected in or in relation to the Platform and/or collected from other sources in order to:
Processing of this information is necessary for the purpose of performance of a contract to which you are party in order to support the operation of the Platform facilitate the delivery of requested products and services and enable maintenance and update of the Platform under Article 6(1)(b) of the GDPR and purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR ("the balancing-of-interest rule"). Disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
As a general rule we will not share Personal Data that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
Notwithstanding the forgoing, we may share information about you with certain third parties based on the legal basis in Articles 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR as follows:
When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.
When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of CAER SIDI, the Games, end users etc.
In order to provide certain Games features.
For advertising purposes. We may share your advertising ID with advertising in order to serving behavioral advertisements to you within the Platform if you have given consent in accordance with Article 6(1)(a) of the GDPR.
In order to access the complete Game, certain premium Games functions, levels, content and features etc. you may be required to pay certain fees. When purchasing such features and functions etc. you may be asked to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 16 or older to make purchases in the Games, however children under sixteen may access to the Platform and play the Games under the supervision of a legal guardian.
Once End Users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. CAER SIDI will use the information provided to process the End User’s order and to send order confirmations via email, as well as to make future purchases easier for the End User. CAER SIDI does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate CAER SIDI’ business (e.g. processing orders and payments).
CAER SIDI has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Platform’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Platform, that we store on our systems or that is stored on our service providers' systems.
Please note that CAER SIDI may provide other games that are operated and hosted by third parties who may have their own information collection practices. Those other games are governed by their own privacy policies, which may be substantially different from CAER SIDI’ policies.
We may transfer and share your information to third parties (including the Games providers) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) wh