POLICY ON DATA PROTECTION AND CONFIDENTIALITY
WHICH INFORMATION IS PERSONAL DATA
Personal Data is any information relating to a live identified natural person or an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his identity.
When you browse the Company’s Services, the Company may collect information regarding the domain and host from which you access the Internet, the Internet Protocol addresses of the computer or Internet Service Provider you are using, and anonymous site statistical data. This information is collected for the purpose of assessing the effectiveness of the company’s Service and for security reasons.
We also gather store and process information in order to be able to provide you with better services and customized information and communication. For this purpose, we use so-called cookies in several places. The cookies serve to make our service more user-friendly, effective and secure. Cookies are small text files that are filed on your computer and that your browser stores. We use persistent cookies to determine whether there has been communication in the past between your computer and us. Persistent cookies stay on your hard disk until they are deleted or expire automatically. Most browsers automatically accept cookies. You can prevent cookies from being stored on your hard disk by changing your browser settings to “do not allow cookies”. For detailed instructions on how to do this, please consult your browser manual. You may delete cookies that are stored on your hard disk at any time.
Disallowing cookies can negatively affect the performance of features provided by this online service. We therefore recommend allowing cookies. This Service uses Google Inc. technology to collect and store in anonymous form information on the surfing behavior of visitors to this site for marketing purposes. The data stored in cookies is analyzed using an algorithm so that product recommendations in the form of web banners and advertising can be displayed on third party Services.
Please note that in addition to the information collected as described above, you may choose to share additional about yourself throughout the Services, such as on message boards and in games and in that case you have no expectations of privacy. Any actions you perform with other players are considered public, and are in your sole discretion.
You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used in order to be sent unsolicited messages. The Company is not responsible for the personally identifiable information you choose to make public in any of these forums.
If you post a video, image or photo through a Service for public view, you should be aware that these may be viewed, collected, copied and/or used by other users without his consent. The Company is not responsible for the videos, images or photos that Subscribers choose to post through a Service. Please see Company’s Terms of Service at http://www.vitali.gr/app_terms.html or the Application End User License Agreement at http://vitali.gr/terms-of-service.html (as applicable) on this point and for other guidelines about posting content through any Service.
WHAT DATA WE ARE PROCESSING AND WHY
VITALI collects information about its users for the purpose of providing and enhancing the Services and making it easy for users to navigate and enjoy the Services. We collect this information directly when you provide us with personal information. In addition, when you login, we may collect and record information that you voluntarily provide to us through services such as www.facebook.com (“Facebook”) in accordance with Facebook’s policies and terms. The type of personal information collected under these activities may vary from activity to activity. This “personal information” is defined as information about you that can be used to contact or identify you. Personal information may include: (1) your name, (2) Facebook user identification number, (3) or email address, (4) your profile picture. (5) a list of friends who play the game. In addition, we may obtain information from you through (1) your visits to and participation in message boards on the Services (2) your emails to our customer support with questions or (3) your purchases of any type of virtual product. VITALI may also invite you to share non-personal information about yourself, which may include, but is not limited to: (1) your age or date of birth; (2) your gender; (3) information about hardware you may own; and (4) your favorite websites, friend information and fan pages (collectively, “Non-Personal Information”). If Non-Personal Information is collected for activities that also require Personal Information, VITALI may combine your Non-Personal Information with your Personal Information in an attempt to provide you with a better user experience, to improve the quality and value of our games, and to analyse how our games are used. Games will also record game information such as your high scores or the duration of your game session.
In addition to the information collected as described above, you may also choose to share other information about yourself throughout the service, for example in-game or on message boards. Any actions you perform with other players are considered public and are at your discretion.
If you make an in-app purchase, we do not collect or process any information related to your payment method, such as credit card or bank card numbers.
When you access the Services, we may collect aggregate information including, but not limited to, Internet Protocol addresses, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain name, login pages, pages viewed and the order of those pages, time spent on a particular page, and the date and time of this activity. We use this information to better tailor our services to your interests, to provide you with more effective customer support and to enhance our services in general.
In all cases of data access and collection, the information you provide will not be disclosed, rented, leased, loaned, sold or otherwise voluntarily distributed to unaffiliated third parties and will only be used to provide and improve the service to you.
The Services may contain links to other websites or applications. The fact that the Services links to a website or application or presents a banner ad or other type of advertisement does not mean that the Company endorses or authorizes that third party, nor is it a representation of any affiliation with that third party. If you click on a link to a third party site or application, including on an advertisement, you will leave Company’s site and you visit the site or application linked to. These third party websites and applications may place their own cookies or other files on your computer, and may collect data or solicit personal information from you. Other sites and applications follow different rules regarding the use or disclosure of the personal information you submit to them. Because the Company cannot control the activities of third parties, it cannot accept responsibility for any use of your personal information by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as the Company. Any subscriber therefore is encouraged to read the privacy policies or statements of other websites and applications he visits before providing any personal information.
HOW WE PROTECT AND STORE INFORMATION
We store and process your information on our servers, and we protect it by maintaining physical, electronic and procedural safeguards in compliance with the applicable law. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to information only for those employees who require it to fulfil their job responsibilities. The Company shall inform its subscribers in the case that their personal data is legally transferred to third parties.
The subscribers are obliged to protect all the confidential data that are granted to them. Access codes and secret codes are strictly personal and the Company shall not be responsible in case of loss or theft. In case of loss or theft of the above codes, the subscribers are obliged to inform the Company as soon as possible.
ACCESS THROUGH SOCIAL NETWORK SERVICES
The Company may also collect or receive information about you from other Services users who choose to upload their mail contacts. This information will be stored by the Company and used primarily to help the connection between friends.
HOW WE SHARE INFORMATION WITH OTHER PARTIES
We may share information with:
Law enforcement, Financial Supervision Authorities, government officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedures
We need to do so to comply with law
We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or for investigations.
The Company will not sell or rent any of your information to third parties for their marketing purposes and only shares your personal information with third parties as described in this policy.
CHANGING OR DELETING PERSONAL DATA
In all cases of data access and collection, the information the subscribers provide will not be disclosed, rented, loaned, leased, sold or otherwise voluntarily distributed to an unaffiliated third parties and will be used solely for the purpose of providing you with Services. If any Subscriber wish to cancel his account or request the Company no longer use his information should contact the Company at the mail address provided in the address below (“contact us”).
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via e-mail to email@example.com. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must: · provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; The information that we need to know are: (i) the name of the game you are playing, (ii) your username, (iii) your User ID (you can find it in the field “Settings” of the Game and (iv) your registered email for the game (if any). · describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months.
POLICY REGARDING PERSONS UNDER 18
The Services are intended for use by those 18 or older for amusement purposes only. Without derogating from the foregoing, the Company does not knowingly collect personal information from people under the age of 13. If the Company learns that a person under the age of 13 has provided it with personal information, the Company will take steps to delete such information as soon as possible.
The Company’s subscribers have the right to be informed in writing about the purposes of processing of their personal data, by applying to the following address: firstname.lastname@example.org.