Effective date: Feb-18-2020
Reflection IT BV ("us", "we", or "our") is a game development studio that creates applications, websites, and other digital properties (collectively “Properties”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Properties, and the choices you have associated with that data.
We use your data to provide and improve our Properties. By using these, you agree to the collection and use of information in accordance with this policy.
Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data: Usage Data is data collected automatically either generated by the use of our Properties or from our technical infrastructure (for example, the duration of game session or delivery of an advertisement).
Cookies: Cookies are small files stored on your device (computer or mobile device).
Data Controller: Data Controller means the natural or legal person or entity who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person or entity who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively and to operate our Properties.
Data Subject (or User): Data Subject is any living individual who is using our Properties and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Properties.
Types of Data Collected
Personal and Usage Data
While using our Properties, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
- IP Address
We may collect information that your device or browser sends us whenever you visit or access our Properties, or when you interact with a Property ("Usage Data").
This data may include, but is not limited to, information such as your computer's Internet Protocol address (e.g. IP address), operating system version, browser type, browser version, the Property you interact with, the pages that you visit, the time and date of your visit to those pages or Properties, the time spent on those pages or Properties, unique device identifiers, and other diagnostic data. This data may also be combined and linked with data from other sources, devices, and Properties that you use.
Cookies and Similar Tracking Technology Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as device identifiers, beacons, tags and scripts to collect and track information and to improve, analyze, and deliver our Properties.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Properties.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Properties.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests. Opting out of interest-based advertising or changing the privacy settings in your browser may reduce the relevancy of the ads you see, but not the number or frequency of ads. To learn more and to opt out of interest-based advertising, as delivered by partners of ours who participate in the following organizations, please follow the instructions at:
Use of Data
We use the collected data for various purposes:
- To provide and maintain our Properties.
- To provide advertising, including but not limited to interest-based, contextual, and cross-device or application ad targeting.
- To notify you about changes to our Properties.
- To allow you to participate in interactive features of our Properties when you choose to do so.
- To provide customer support.
- To gather analysis or valuable information so that we can improve our Properties.
- To monitor the usage of our Properties.
- To detect, prevent and address technical, security, or fraud issues.
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
We or one of our Service Providers may collect and/or process your Personal Data because:
- We need to perform a contract with you.
- You have given us, as a Data Controller or Data Processor, consent in compliance with applicable laws to do so.
- The processing is in our legitimate interest, except where such interest is overridden by your data protection interests or fundamental rights or freedoms.
- To comply with the law.
IAB Europe Transparency & Consent Framework
We participate in the IAB Europe Transparency & Consent Framework and comply with its Specifications and Policies. We use the Consent Management Platform provided by Consent Desk LLC.
Retention of Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Properties, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation.
- To protect and defend our rights or property.
- To prevent or investigate possible wrongdoing in connection with our Properties.
- To protect the personal safety of users of our Properties or the public.
- To protect against legal liability.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA) or the United Kingdom, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or the United Kingdom.
We may employ third party companies and individuals to facilitate the delivery and operations of our Properties ("Service Providers"), provide the Properties on our behalf, process Personal Data, perform Property -related services or assist us in analyzing how our Properties are used.
We may provide these third parties with access to your Personal Data only to perform these tasks on our behalf as a Data Processor and are obligated not to disclose or use it for any other purpose.
These third parties may also collect data directly from you for their own use and subject to their own privacy policies.
Other Sites and Digital Properties
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Properties do not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
Our Properties will not contain any indecent, obscene or pornographic material, hate speech, subject matter that a reasonable person would consider highly objectionable, any material which improperly references illegal activities. It can contain third party advertisments which content we can not control. Notwithstanding the foregoing, we will have no liability for any claim when third parties uses content in our Properties, as described above.
By email: firstname.lastname@example.org
Reflection IT BV
5721 JG Asten
To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO) who is contactable using the details provided above.