PRIVACY POLICY
1. Introduction
When using our services, you’re trusting us with your private information. We are committed to protect the privacy of our users and we take our data protection responsibilities with the utmost seriousness, in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”) and any other data protection regulations applicable.
As one of the key principles of the legal framework established by GDPR is transparency, we have prepared this legal document to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to our Product through our website or mobile app.
THUNDER DATA S.R.L S.R.L, a legal entity under Romanian law, with registered office in Cluj-Napoca, 125 Septimiu Albini Street, Cluj county, with Unique Registration Code RO46085218, registered at the Cluj Trade Register under no. J12/2522/2022 is the data controller for your personal information collected when you interact with us in relation to our Product and through our website or mobile app.
This Privacy Policy applies to all Personal Information processing activities carried out by us, across platforms, websites and our departments.
To the extent that you are a user of our Product, this Privacy Policy applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.
To the extent that you are not a relevant stakeholder, customer or user of our Product, but are using our website, this Privacy Policy also applies to you together with our Cookie Policy.
This Privacy Policy should therefore be read together with our Cookie Policy, which provides further details on our use of cookies on the website.
This Privacy Policy does not apply to third-party websites, online properties or systems to which our Product may link or through which our Product may be accessed, and you accept that we are not responsible for the security or privacy practices of any such third-party websites, properties or systems.
If you do not agree with this Privacy Policy, in general, or any part of it, you should not use the Product through our website or mobile app.
2. The personal information we process. The purposes of the processing. The legal basis for the processing of your personal information.
We collect Information about you from you and from other sources. As set out below in more detail, we use and in specific cases combine that information to operate, tailor content, personalize, adjust and improve your experience when using our Product. The information may be used in order for us to improve our Product, keep track of your scores and gameplay time and implement new features and more, including for marketing and promotional purposes. In addition, we use your Information to operate our business, including to analyse our performance and meet our legal obligations.
I. Information provided by you
We collect information you may provide to us by filling in forms on our website or through our mobile app. This includes information you provide when you register to use the Product such as name, phone number, login e-mail address, password.
With regard to each of your visits to our website or our Product we also collect login information such as the Internet protocol (IP) address used to connect your computer to the Internet, device information, screen resolution, location of your device or computer.
As set out in more detail in the following, we may collect information from you when you (A) create an account within our Product and when you (B) use our Product.
A. Creation of an account within our Product
We will collect certain information from you when you register within our Product. Personal information collected during registration includes your name, email address, username, password and, in specific cases, your phone number. This personal information is combined with other Information such as your date of birth, country and information about your interests in and use of various products, programs and services and marketing preferences. Additionally, we collect and combine Information when you link a third-party account to our Product (e.g. Facebook, Google, Apple, Steam etc.).
Purposes
– Provide, troubleshoot and improve our Product. We use your personal information to provide functionality, analyse performance, fix errors and improve the usability and effectiveness of our Product.
Legal basis
– Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you (para. 6 point (a) of GDPR). You will always be prompted to take clear, affirmative action so that we can ensure that you agree with the processing of your Personal Data. This action may, for example, take the form of a checkbox. If you have given us your consent for processing operations, you may always change your mind, and withdraw your consent at any time and easily.
– Performance of a contract when we provide you with the Product, or communicate with you about it (para. 6 point (b) of GDPR). This includes when we use your personal information to take and handle orders, and process payments.
– Our legitimate interests and the interests of our users when, for example, we detect and prevent cheating in order to prevent the gaming experience for our users to suffer. (para. 6 point (f) of GDPR).
B. Use of the Product
When you interact with the Product, through our website or our mobile app, we collect, process and/or combine information about your use of the Product, such as websites you visited before and after using the Product, browser type and language, IP address, hardware and software information, third party account information, advertising IDs, gameplay data, usage data, purchase history and social media data. We use cookies and/or similar technologies (collectively called “Cookies”) to do this. In addition, we and our partners also use Cookies and advertising IDs to serve ads in our Product. Please see our Cookie Policy below for more details.
Purposes
– Improve our Product. We process personal information to improve our Product and for you to have a better user experience;
– Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalize your experience with our Product;
Legal basis
– Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you (para. 6 point (a) of GDPR). You will always be prompted to take clear, affirmative action so that we can ensure that you agree with the processing of your Personal Data. This action may, for example, take the form of a checkbox. If you have given us your consent for processing operations, you may always change your mind, and withdraw your consent at any time and easily.
– Our legitimate interest to improve our product (para. 6 point (f) of GDPR).
II. INFORMATION PROVIDED BY OTHER SOURCES
We may also obtain Information, such as contact details, country, IP address, purchase history, marketing preferences, cookie information, hardware and software information and other technical information about you from other sources, such as our partners and social media services and combine that Information with Information we have collected from or about you. We only collect information from other sources where they have confirmed to us they are legally entitled to share it with us.
3. We may share your Personal Data with third parties
a. We may share your Personal Data with third parties (including our entities or subsidiaries) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. When sharing your Personal Information with our entities, we will use our best endeavors to ensure that such entities are either subject to this Privacy Policy, or follow practices at least as protective as those described in this Privacy Policy.
b. We may also share personal information with the following entities:
– Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content. These third-party service providers only have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
– Legal Authorities: We may be required by law or by Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.
– Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the user consents otherwise).
– Our personal Protection or of others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect our rights, property or safety, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
– In order for us to provide you with the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.
4. INTERNATIONAL TRANSFERS OF PERSONAL INFORMARION
To facilitate our global operations, we may transfer your personal information outside of the European Union.
In cases where we intend to transfer personal data to third countries or international organisations outside of the European Union we put in place suitable technical, organizational and contractual safeguards, to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the personal information is transferred has already been determined by the European Commission to provide an adequate level of protection.
5. Storage and protection of your personal data
We store your personal information securely throughout the life of your registered account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.
Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe or retract your permission to receive marketing info.
When Personal Data is no longer necessary for the purpose for which it was collected, we will remove any details that identify you or we will securely destroy the records.
6. Your rights regarding your personal data
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your personal information.
Right to access: you have the right to obtain confirmation that your personal information are processed and to obtain a copy of it as well as certain information related to its processing;
Right to rectify: you can request the rectification of your personal information which are inaccurate, and also add to it. You can also change your personal information in your Account at any time.
Right to delete: you can, in some cases, have your personal information deleted;
Right to object: you can object, for reasons relating to your particular situation, to the processing of your personal information. For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes;
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your personal information by us, provided there are valid grounds for doing so. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law;
Right to portability: in some cases, you can ask to receive your personal information which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your personal information on your behalf directly to another data controller;
Right to withdraw your consent: for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter;
Right to lodge a complaint with the relevant data protection authority: We hope that we can satisfy any queries you may have about the way in which we process your personal information. However, if you have unresolved concerns, you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
7. Changes to the Privacy Policy
Our Privacy Policy is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration and that it remains compliant with the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Policy.
The Privacy Policy visible on our website will always be up to date and considered the most recent version.
8. Contact information
To contact us, you can send us an email at support@thunderpubl.com, and we will work to address any questions or issues that you have with respect to the collection and processing of your personal information.
9. Cookies
We use cookies and similar tools to enhance your user experience, provide our Product, enhance our marketing efforts and understand how customers use our Product so we can make improvements. Our cookie policy is available below.
COOKIE POLICY
When you visit websites, they may store or retrieve data in your browser. This storage is often necessary for the basic functionality of the website. The storage may be used for marketing, analytics, and personalization of the site, such as storing your preferences. Privacy is important to us, so you have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website. Blocking categories may impact your experience on the website.
You will be prompted to take a clear, affirmative action so that we can ensure that you agree with the processing of your personal data. This action may, for example, take the form of a checkbox in your online tool. Before obtaining your consent, we will systematically inform you of the names of the organisations implementing the cookies, the consequences of your consent or refusal to consent, the purposes of the processing, and your right to withdraw your consent. You can choose to consent to certain uses that we or our partners will make of your data and to refuse others.
What are cookies?
Cookies are small text files that are placed into user’s device when you visit a website, downloaded to your computer or mobile device when you visit a site and allow a site to recognize your device. Cookies stores information about the user’s visit, which may include content viewed, language preference, time and duration of each visit and advertisement accessed.
Why do we use cookies and similar technologies?
Cookies are a useful mechanism that do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can help to ensure that the advertisements you see online are more relevant to you and your interests and enable us to identify your preferences. There are different sets of cookies, and we will explain that later in this document.
What data do we collect thanks to cookies?
Cookies allow us to collect personal data relating to you, and to transmit technical information about the devices you use, the clicks you make, and the content you view. We combine this information with personal data that you have already provided us in accordance with our Privacy Policy.
The cookies we place on your terminal give us access to the following personal data relating to you:
– Identifiers of the equipment you use (IP address of your computer, Android identifier, Apple identifier, etc.);
– Browsing data on our services, content viewed;
– Information relating to your use of our sites and applications;
– Information relating to the presence of cookies on your terminal, the time and date of viewing a page, and a description of the page where the web beacon is placed;
Do we use any cookies from third party companies?
Some cookies and other tracking and storage technologies that we use are from third party companies (third party cookies) to provide us with web analytics and intelligence about our sites which may also be used to provide measurement services and target ads.
What if you don’t want cookies or similar tracking technologies?
You can adjust your preferences about cookies through our cookie setting center. If you want to remove existing cookies from your device, you can do this using your browser options.
If you want to block future cookies being placed on your device, you can do so by modifying the settings at our cookie setting center. Nevertheless, please consider that deleting and blocking cookies may have an impact on your user experience.
What types of cookies does the site use?
The cookies used on our sites have been categorized as described below.
Strictly Necessary cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.
Marketing
These items are used to deliver advertising that is more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. Advertising networks usually place them with the website operator’s permission.
Personalization
These items allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For example, a website may provide you with local weather reports or traffic news by storing data about your current location.
Analytics
These items help the website operator understand how its website performs, how visitors interact with the site, and whether there may be technical issues. This storage type usually doesn’t collect information that identifies a visitor.
If you have any questions now or during your visit, please submit your request at support@thunderpubl.com
You can adjust your cookie settings at any time from our cookie settings centre.