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Updated June 22, 2020
Thank you for playing with us!
In this document we detail what personal information we collect, how we do it and for what purposes, and explain how to exercise your rights and choose your choices.
In addition, we establish the Terms of Contract that govern GENERA GAMES’ relationship with you.
For any questions, clarification or additional information do not hesitate to contact us.
- IDENTIFICATION DATA – LEGAL NOTICE
- POLICY OF COOKIES AND DEVICES OF LOCAL STORAGE AND DATA RECOVERY
- GENERAL CONTRACTING CONDITIONS
Identification data of the owner of the App and the Data Controller, in compliance with Spanish Law of Information Society Services and Electronic Commerce (LSSICE), European General Data Protection Regulation (GDPR), and Spanish LOPDyGDD 3/2018.
BUSINESS NAME: GENERA GAMES SA (“GENERA GAMES”) CIF: A91284240
ADDRESS: C/ Cardenal Bueno Monreal 50, 2nd – 41013 SEVILLA (SPAIN)
Registered in the Commercial Register of SEVILLA (SPAIN) T4101, F158, S8, H SE52642
Contact Form: https://generagames.com/contact/
DPO Contact Form: https://dp-control.es/
Data Protection Officer (DPO): Onudatos Consultores SL (“DP-CONTROL”)
DPO contact: [email protected]
Welcome to the GENERATE GAMESPrivacyPolicy. This policy describes how GENERA GAMES and the group’s companies (collectively described as “GENERAGAMES”)and their third-party marketing and advertising partners collect, use, process and share information. Werefer to our games, websites, marketing and advertising activities and other services collectively as our “Services”.
We collect information in order to improve your experience and our relationship, always in an open, loyal and legitimate way.
This data collection is essential to give you access to the service, support you, attend to your requests, wishes and queries and ensure the operation but always based on respect for your privacy and your rights and we offer you all the information and our collaboration to guarantee your privacy.
2.1. What data do we collect in the App?
All our forms have the symbol * in the required data. If you do not supply them to us, or if you do not give us the permissions to access certain elements of the smartphone; we may not register the user or deny some or all of the service, on which that data depends.
You are free to complete the optional data, such as profile settings, photo, nick, etc. And you can modify certain information that you give us through the control panel of the application, in the settings, or in the permissions within the settings of your smartphone.
The Android or IOS system itself will ask you for authorization for permissions, such as access to geolocation to offer services to your region. If we ask for any extra permission, it will also give you the specific authorization message. Your refusal will mean that such service cannot be provided, or its usability is reduced.
a) User data
When you install the App, a user ID is generated through the market you use. The APP creates its own folders when installed, where it stores its contents when used. ID data is, in principle, anonymous.
We may collect your date of birth or age, email, username and password, and avatar.
b) General facts when using the Games
We may collect open profile and chat data. In addition, if you choose to invite your friends,we can collectthe email from your friends. Make sure you have permission from your friends before sharing this information with us.
c) Statistics data when using games
Once you access the app, we will develop analytics, statistics and measurements to improve the App: Differentiate users through a unique and anonymous ID for the device, what the user sees, the O.S. of the device or when the app is used. This data is stored locally and sent in batch to the analytics tool, every 30 minutes on Androids and every 2 minutes iOS. You can configure it to optimize your battery.
IDs are retained if the application is updated, but if it is uninstalled and reinstalled, another ID is created.
Identifiers, IP address, device and app ID, city/province/country location data, and player connections can be collected through Appsflyer.com.
On the device, you can collect the model, the brand, the operating system.
Information about the use of the Games, such as the date and time stamps of game events, interactions with our teams and advertising commitment and support to content developers, and transaction logs, or evidence of cheating software usages, or modified versions of the Games.
d) Surveys about your experience
We may collect your interests and habits, your opinion about the different products and services and what you would like to be offered in the future. We also collect your grades, opinions, preferences, questions, images, and answers associated with that survey.
e) Information received from third parties
If you link the app to external platforms or social networks (Apple, Facebook or Google Play), you may post certain activities or share content in them. We can identify your in-game profile with the platform, and receive your third-party ID, name, avatar and location at the city level. If you give permission to our Game, we may also collect your email address, friend list and date of birth.
When you pay in games, we receive information from our payment processors about transactions, including your Apple ID number for Apple, your zip code and status for Google, and user ID, and transaction data through the Amazon Store.
We use analytical software from Delta DNA, Apps Flyer, Fire Base and Google Ads advertising, Iron and Unity Technologies that include the user ID and information about your interactions with advertising displayed in our Mobile Games.
The information will be on EU servers, but when using American market and analytics applications, they can use U.S. servers if they meet a level of demand similar to that of the EU, when eligible for the Privacy Shield.
We receive information from our mobile measurement partners to measure the performance of marketing campaigns, or detect fraud in marketing campaigns. This includes advertising ID, IP address, location and information for each transaction.
2.2. What data do we collect on the Web?
- Data stored by browsing and using the Website
By simply browsing the Website, GENERA GAMES will collect information regarding:
- IP address
- Browser version
- Operating system
- Duration of the visit or navigation on the Website
The information we handle will not be related to a particular user and will be stored in our databases, in order to perform statistical analyses, improvements on the Website, on our products and/or services and will help us to improve our business strategy. The data will not be communicated to third parties.
- Data provided in the contact form
You can contact us directly through the “Contact Us” section. To do this, it is necessary for the User to identify himself and enter his/her personal data, so that GENERA GAMES can contact the user, if necessary, to fulfill their request for information. The necessary and mandatory data to be provided by the user to carry out such registration are marked with the text (required). In the event of not providing such fields, your request will not be allowed to be sent.
Such personal data will be incorporated into the databases of GENERA GAMES, which will keep them to respond to your request and / or request for information and, after that, will be deleted within 3 years.
The legal basis for the processing of such data is the consent of the user requesting information, or has the need to maintain contact with GENERA GAMES
The purposes of the processing shall be as follows:
- Manage inquiries or requests for information you send us through the Website, email or phone
- Sending communications, special promotions, news, or actions that are of interest to you or you request us even by electronic means. As it is an accessory purpose to the main one, you must check the box enabled for this purpose.
The personal data you provide us by this means will not be communicated to third parties, being GENERA GAMES who directly gives response to this type of queries.
- Work with us
In the event that you provide us with your resume, either through the Website, email or physically at home or any headquarters of GENERA GAMES, it will be incorporated into its database. The curriculum will be stored for the period of 1 year, after which, in the case of not contacting you, it will be deleted.
The legal basis for the processing will be based on the express consent granted by the data subject for the processing of the data contained in the curriculum by sending it and checking the box enabled for this purpose.
The purpose of the processing will be to incorporate you into present and future selection processes of GENERA GAMES.
If finally, the data subject joins as an employee of GENERA GAMES his data will be incorporated into a database owned by it, in order to manage internally the employment-employer relationship. In this regard, we refer to the treatment related to employee contracts, which is listed below.
- Social Media
When becoming a fan, follower or analogue of our company in the aspect of the different social networks, in the context of this treatment you should take into account that GENERA GAMES can only consult or unsubscribe your data in a restricted way by having a specific profile. Any rectification of your data or restriction of information or publications must be made through the configuration of your profile or user on the social network itself. By default consents:
- a) The processing of your personal data in the environment of that social network and in accordance with its Privacy policies: Facebook, Twitter, Pinterest
- b) GENERA GAMES access to the data contained in your profile or timeline. Depending on your privacy settings on each network, these will be more or less extensive.
- c) To have the published news about our events, or our comments, appear on your wall or timeline.
- d) To receive communications about our products/events.
If you want to stop following us, just click the “Stop being a fan” or “unfollow” option.
2.3. Exclusion of minors
The games are not aimed at children, although they can be used, according to their qualification in a family environment with the supervision of the adult owner of the device. When children under the age of 16 use our Games, we recommend that they obtain permission from a parent or guardian, and we recommend that parents or guardians remove cookies from their browser and take all other steps outlined in our policies to minimize the data collected. In some of our games, you will have reduced functionality if you are under 13, or if you are between 13 and 16 years old.
The PEGUI rating indicates the suitability of the game for certain ages according to the content of the game, but that a game is suitable for minors (for example, that does not contain violence), does not mean that it is addressed to them. The table below shows a list of legal deadlines by country:
- Chile: more than 14
- Colombia: more than 14
- United States: 13
- Peru: more than 14
- Venezuela: more than 14
- South Korea: more than 14
- Vietnam: more than 15
- Aruba: more than 16
- Dutch Caribbean: more than 16
- Curacao: more than 16
- Saint Martin: more than 16
- Austria: more than 14
- Belgium: more than 13
- Bulgaria: more than 16
- Croatia: more than 16
- Republic of Cyprus: more than 13
- Czech Republic: more than 13
- France: more than 16
- Germany: more than 16
- Greece: more than 15
- Hungary: more than 16
- Ireland: more than 16
- Italy: more than 14
- Lithuania: more than 14
- Luxembourg: more than 16
- Netherlands: more than 16
- Poland: more than 16
- Romania: more than 16
- San Marino: more than 16
- Serbia: more than 15
- Slovakia: more than 16
- Slovenia: more than 16
- Spain: more than 14
2.4. For what purposes will we process your personal data?
- Access to the service of the application or game, identify yourself in it, and support you.
- In-game purchases.
- Blocking in case of breach of conditions.
- Answer inquiries, requests, or process your requests, and inform you electronically.
- Sending Push notifications, which can be ads, if you turn them on.
- Commercial or event information by electronic means, provided that it has been expressly authorized.
- Perform analysis and measurements in the App, in anonymized and dissociated or aggregated, and share that information with the company that facilitates the analytical application in the market, to optimize our products and services.
- We will make basic profiles of users, based on their interests, habits, geography, or payment history.
- We interact with our newsletters and advertising campaigns to create anonymous and aggregated data and create user segments that show particular features or interests; and perform predictive analytics on your interests to promote new services or products.
- Ensure technical operation, improve user relationship (engagement) and business strategy by developing new services or improvements.
- Moderation of inappropriate comments, or abusive or unauthorized use.
- Perform the appropriate transactions. Appropriate tax return.
2.5. What is the legitimacy to process your data?
- Your acceptance and consent when you download the app, accept this policy through a contractual relationship and authorize certain uses of data, ticking the corresponding boxes or buttons.
- Our legitimate interest in improving the application and profiling, analysis, reporting our games, newsletters and advertising campaigns, and any interactions therein
2.6. Do we include personal data of third parties?
We only process the data of the holders. If you provide data from third parties you must, in advance, inform and request their consent from such persons.
2.7. What security measures do we apply?
We have an optimal level of security with means and technical measures to prevent the loss, misuse, alteration, unauthorized access and theft of Personal Data, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.
We will not be liable for technical problems or errors in computer services, that occur during the connection to the internet network or that may be caused by third parties through unlawful intrusions beyond our control.
Your personal information will be encrypted when transmitted
2.8. To which recipients will your data be communicated?
They will not be transferred to third parties except legal obligations such as the Tax Authority. The collection management is carried out by the Market as the processor, the means of payment that you have supplied.
To developers or autonomous service providers always for specific tasks, and who have signed a service delivery contract that obliges them to maintain the same level of privacy as us.
Any international data transfer when using American applications will be adhering to the Privacy Shield agreement, which ensures that American software companies comply with European data protection policies regarding privacy.
There are several developers who design games and publish them with Genera. We will share information with the developer of each game to help you improve and grow. The list of developers currently working and are part of Genera are:
- Besoccer Games SL
- Redvel Games SL
- Tale Studios SL
- One Man Band SL
- Genera Indie Games SL
- Digital Arts Games SL
- Play Gate SL
- Koron Studios SL
- Unico Games SL
- Genjoy Games Studio SL
- My Talking Toys SL
- Advertising partners
We work with advertising partners, who help us implement analytics and advertising in our games. All are in the European Union, or in the United States and adhered to the Privacy Shield agreement, which allows the transfer of information between the USA and Europe.
Our partners are:
We also connect the games with the following social networks, with which we share information:
2.9. Your Rights
- Whether we are processing your data or not.
- To access your personal data.
- To request the rectification of your data if they are inaccurate.
- To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw the consent granted to us.
- To request the limitation of the processing of your data, in some cases, in which case we will only keep them in accordance with current regulations.
- To carry your data, which will be provided to you in a structured, commonly used or mechanically readable format. If you prefer, we can send them to the new manager you designate. It is only valid in certain cases.
- To file a complaint with the Spanish Data Protection Agency, if you think we have not taken care of you correctly.
- To revoke consent for any processing for which you have consented, at any time.
If you change any data, we appreciate you informing us to keep them updated.
2.10. Form for the exercise of rights
We have forms that you can ask us for and send by any way in the addresses we provide.
They must be electronically signed or accompanied by a photocopy of the ID.
If you are represented by someone, you must also attach a copy of their ID to us, or sign it with their electronic signature.
2.11. Rights response period
A month from your application. Two if it’s hard and we’ll let you know we need more time.
2.12. Timeline of app data maintenance
They will be kept as long as you remain linked to us. Once you disassociate yourself, they will be deleted, except for that information or communications regarding the provision of the service, while the administration can request it or to respond to complaints.
If you give us consent to send advertising by other means, they will be maintained until you revoke it for us.
A cookie is a small file that is downloaded to the user’s device in order to store data that can be updated and recovered to optimize your user experience..
The App creates folders and can save analytical data that it is sending periodically, as we explain in the data uses.
|Limit the percentage of requests||HTTP Cookie||End Session|
|Dist. unique users||HTTP Cookie||End Session|
|Dist. unique users||HTTP Cookie||Persistent|
|generagames.com||__cfduid||Functionality – Own||Sec – Ident IPAdress||HTTP Cookie||29 days|
|generagames.com||PHPSESSID||Functionality – Own||Session variable data||HTTP Cookie||End Session|
|generagames.com||catAccCookies||Functionality – Own||Verific Acept Cookies||HTTP Cookie||29 days|
a) Technical storage
To make the App work better (e.g. language, volume, lighting, purchases…)
b) Statistical and analytical analysis on the use of the service
That’s how we improve the App. It is done by means of tools provided by third parties, and that access such content because they provide us with the tools. Learn more here.
We try to locate the device situation to, anonymously, provide you with more appropriate content and services.
They match your ad content based on your use of the App and your browsing profile.
e) Registration cookies
The ID identifies your user account, when the App was installed, and the services associated with the ID. It can be used in combination with analytical data to individually identify preferences or ads to personalize the ads you see.
f) Other third-party tools
They allow you to manage and improve the services of the third party, such as social networks that allow us to share our content, or that can then display advertising related to the user.
How do I set my preferences?
If you use these technologies,we will ask for consent to their use when installing the application. In the event that you blocks these files, certain services that need their use may not be available, or that the advertising and content you see are more general, but you will receive the same amount of advertising.
You can find the list of technologies used in the following table:
How can youset or set las Cookies?
- Microsoft Edge : Settings > Advanced Settings > Privacy and Services > Cookies.
- Mozilla Firefox: Tools > Options > Privacy > History > Custom Settings.
- Google Chrome: Settings > Show advanced options > Privacy > Content settings.
- Safari (Apple): Preferences > Security.
- Opera Software: Settings > Options > Advanced > Cookies
If you useyour browser other than the above, pleaseconsult its policy of installation, use and blocking of cookies.
Options to disable cookies and opt-out
Using the www.youronlinechoices.com tool, you can find useful information and configure, provider by provider, your preferences about cookies.
There are more third-party tools that allow users to detect cookies every website you visit and manage their deactivation. For example:
- Add-on to disable Google Analytics cookies
- Disable advertising cookies from companies subscribed to the NAI (Network Advertising Initiative)
- Learn more about cookies at: org and AllAboutCookies.org
By downloading and installing the application, using the app or accessing our services by any means, you agree to the General Terms and Conditions detailed below that govern your relationship with GENERA GAMES with respect to your use of games, websites and other services.
IF YOU DO NOT AGREE TO THESE TERMS OF SERVICE, PLEASE DO NOT INSTALL, USE OR OTHERWISE ACCESS THE SERVICE.
USE OF THE SERVICE WHERE PROHIBITED IS NOT ALLOWED.
Access to the App is via download through the Google Inc. APP STORE, or from Apple’s Apple Store; or through any other device App reseller we provide. In no case will any license or download through unauthorized third parties be valid.
Apps consist of games with in-app purchases, of different themes.
Acceptance of the conditions, and use implies their express, full, and unreserved agreement to them. Otherwise you must leave the App, having the services offered. The services are used under your sole and exclusive responsibility.
The developer may unilaterally delete or modify the terms of service and its content at any time. You can also prevent access to the service. It will inform the user of such change if possible, through the platform. The new conditions will be valid from the moment of publication, you will have to accept the changes, or stop receiving the service.
These conditions have been set out as prior to the contracting and processing of personal data. You can check them again at any time. If any clause is declared null, it will be not set without affecting the other conditions.
We do not control or approve the content you post. You are responsible for everything you post and do with your account.
4.2. License to use
When you agree to the Terms, we grant you a license to use and use the App on your device with the features and services provided in the current version of the game, and that they will be able to change in the future.
You agree not to use the service in any way not expressly permitted under the terms.
Intellectual and industrial property rights over the App correspond to the developer, including the graphic design, content and databases that may include it.
The license is limited and non-exclusive, and the user will in no case:
- Assign rights, sublicense, lease, distribute or grant rights to third parties in the license granted.
- Eliminate technical protection measures from the software.
- Perform or allow any modification, translate, decompile or any type of reverse engineering.
- Separate the services or components of the App for use on different devices or in further development.
- Delete, hide, or obscure any notice relating to the copyright or intellectual property of the Application.
- Use the application for commercial purposes, or simply different from the services provided, or in an unauthorized manner, or in a way that causes interference to accounts, networks, data or people.
- In any way, dispose of, duplicate or copy, publish, distribute or provide the services, source code or any part of the software; unless expressly authorized.
- We reserve the right to make modifications and improvements to the application, you will have available updates for its proper functioning. We recommend that you keep the application up-to-date.
- The unauthorized use of information contained in the PPP, as well as the damages caused to intellectual and industrial property rights, may give rise to the exercise of the actions that legally correspond and, where applicable, to the responsibilities arising from such exercise.
The rights of the contents are the property of the company that owns the App, or third parties with permission to operate it; and are protected by law. The content includes trademarks, logos, trade names, distinctive signs, services, content, texts, photographs, graphics, images, software, links or any information.
Any reproduction, distribution, public communication, marketing or transformation; unauthorized content, constitutes an infringement of those rights. The damages caused will result in the exercise of legal actions and civil and/or criminal liability.
We are authorized to manage the purchase and collection of the product to the consumer through the portals or Market where you download the App.
With regard to content posted or provided by the user that may be copyrighted; You grant us permission (free, unlimited, worldwide, non-exclusive and perpetual) to use, copy, distribute and display such content on other websites, including social networks.
4.3. Coming of age
4.4. Terms of services offered
To access you must click on the logo of the application. There are no keys, you are responsible for the custody of your smartphone, we recommend using a lock key or fingerprint, and keep it in the absolute and strictest confidentiality. Never use patterns. If more fields are needed, they will ask for them.
The service is free but has in-app purchases through your Google Play account or the Apple Store, or in other stores we use in the future. They confirm the payment immediately and on the spot we provide you with the purchased products.
You are responsible for any false or inaccurate statements you make and any damages you cause.
It is forbidden to:
– Post any content that contravenes the law of your country, malicious, of which you have no rights, or that is inconsiderate towards animals.
– Use malicious or virus-containing software or software that contains unauthorized access to third-party computers or servers, or interrupt, destroy or limit the functionality of any software.
– Defame, threaten, harass, impersonate users or violate their privacy.
– Send spam, or chains, etc.
4.5. Prices, applicable taxes and tariffs
The prices applicable for in-app purchases are listed in the Euro app, and are inclusive of taxes. The Market Manager automatically translates it to your local currency, and the corresponding taxes are added to you.
4.6. Cancellation of the Right of Withdrawal
By law there is the right to withdraw from the contract for 14 calendar days from the moment you make a purchase, but it is not applicable for software and applications with online download since, due to its nature, the files are installed on the user’s computer immediately and for permanent use, as long as it does not connect to the Internet.
4.7. Returns for malfunction
Google allows you to return the purchase for 2 hours, for appraisal reasons. Apple returns it if the content is not installed. For both portals, the only supported cause of legal return is that the app didn’t work, even if you downloaded it, played and then purchased it, we understand that it worked correctly in advance. In addition, Google scans your device before downloading to see if it will work or not. Apple knows that it is its models and that the apps work.
Therefore, we will ask you for information to verify that it has not worked for you since you made the purchase, denying those unwarranted or abusive requests. In case you don’t get the products purchased in-game, contact us and we’ll study what happened. We will try to provide you with the product, and only if it is impossible for us, we will refund the amount paid.
You can uninstall the App anytime. We may unsubscribe or stop providing the service without notice, simply by informing you, and without incurring any liability. In-app purchases will not be returned, although while you have the App installed on your device, you can still use it offline.
The application is displayed in its current state of development and with the functionalities that it has at any time always appropriate to the services offered. We guarantee only and exclusively your suitability for the services offered and for the platform or operating system for which it has been developed.
In no case do we ensure the availability of the services or the veracity of the advertisements that may be offered through the App, since it depends on circumstances beyond our control, such as the availability or proper functioning of the device or terminal in which it is installed or the telecommunications networks. We will not be liable for damages of any kind that may be due to such lack of availability, accessibility, and operation of the services when due to the reasons set out above.
We do not make commitments of evolutionary maintenance or continuity, so at any time you can replace it or simply cease it in making it available, without obligation or liability with respect to users.
4.10. Applicable law, jurisdiction and validity
These Terms are governed by Spanish law and the Spanish-Spanish language. In case of doubt, the Spanish version prevails over any translation defect.
By enjoying the consumer’s protection regulations, they may claim or sue from the jurisdiction of their domicile. Both parties submit, expressly waiving any other jurisdiction, to the Courts and Tribunals of Seville (Spain), in the following cases:
– If the buying party is domiciled outside the European Union and there is no bilateral or multilateral agreement with Spain in that country that prevents the possibility of establishing the express submission of the jurisdiction.
– If it is a sale made by a company that acts in the framework of its business or professional activity.
4.11. Online Dispute Resolution
If you are an EU citizen, in accordance with EU Regulation 524/2013 on Online Dispute Resolution (ODR), we inform you that as a consumer, you have at your disposal a procedure for resolving the various disputes arising from online sales in the EU.
– See more information here
We reserve the right to delete content (photos, videos, text, etc.) if we believe that it violates any applicable law (right to privacy, intellectual property, industrial property, etc.).
If a user publishes criminal content (paedophile, racist, insulting, defamatory…), the content will be deleted and the account of the person responsible will be immediately and definitively deleted. It shall also bring to the attention of the competent authorities.
You can enable channels to report content.