YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
The EU’s General Data Protection Regulation (“GDPR”), gives you certain rights to your Personal Data. These rights can be found (mainly) in chapter 3 of the GDPR and include:
- Right of Access – You have the right to request information concerning if we process your Personal Data and if we do, you have the right to know what kind of Personal Data;
- Right of Rectification – You have the right to request that we correct and rectify any inaccurate or incomplete Personal Data concerning you;
- Right to Erasure – You have the right to request that we delete your Personal Data. Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights and comply with technical and legal requirements and constraints related to the security and operation of our Properties;
- Right to Restriction of Processing – You have the right to request that we temporarily or permanently cease processing of some or all of your Personal Data;
- Right to Data Portability – You have the right to receive a copy of your Personal Data for the purpose of transferring them to another service provider;
- Right to not be the subject of Automated Decision Making – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or otherwise significantly affects you;
- Right to Withdraw Consent – You may at any time withdraw your consent to the processing of any Personal Data based on your consent, without it affecting the lawfulness of any processing done before you withdrew your consent;
- Right to Object – You have the right to object to our processing of your Personal Data for a certain purpose or to object to your Personal Data being used for direct marketing; and
- Right to lodge a complaint with a supervisory authority – If you believe that Friendbase has infringed your rights or otherwise infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular an authority established in your Member State.
Accordingly, we offer transparency and access controls to help users take advantage of those rights, as limited and expected under applicable law:
- Privacy Settings accessed via your account page – allows you to exercise choices about the processing of certain Personal Data.
- Notifications settings accessed via your account page – these settings allow you to choose which marketing communications you receive from us.
If you have concerns regarding the processing of your Personal Data, we hope you can work with us to solve them. However, you can also contact the Swedish Authority for Privacy Protection (“IMY”) or your local Data Protection Authority. The Swedish Authority for Privacy Protection can be reached through the following address:
Phone: 08-657 61 00
Mail: Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm
Email [email protected]
THE DATA WE COLLECT AND USE
Below, we have set out which categories of data we collect, a description of that data, the legal basis we are using for collecting that data, and the purpose of collecting the data. If you have objections or further questions regarding e.g. a purpose for particular processing or would like a more granular description of the data collected, please contact us in accordance with the “contact us” section.
The Personal Data we collect from you
|Categories of Personal Data (ex. in parenthesis)||Description||Legal Basis||Purpose|
|Identity Data (First and last name, social media accounts, gender)||Data which is used to directly identify or address you – names or usernames, titles, avatars.||Necessary for the performance of a contract (Art. 6(1)(b), Consent (Art. 6(1)(a))||Certain Identity Data is necessary for Friendbase to be able to provide the service to you. To an extent, providing such information is optional – this is the case with and social media accounts. In those circumstances, we rely on your consent.|
|Contact Data (email address)||Data stored for us to be able to contact you.||Consent (Art. 6(1)(a), legitimate interest (Art. 6(1)(f))||In certain circumstances you may provide us with contact information, such as when you wish to contact us via our contact form – please note that we save the contact information you provide in such circumstances, to be able to reply to you. We may also need to contact you for the benefit of your interests, and as such will save your email address for that purpose. We deem such a purpose to constitute a legitimate interest.|
|Location Data (country)||Data regarding the location of the user.||Legitimate interest (Art. 6(1)(f))||We use location data to keep track of which country our users reside in (we do not see more granular information than country), and use that data to improve your experience by addressing e.g. latency/ping issues.|
|Time Data (time of login, date of transaction, time of profile creation)||Data indicating date/time of use for certain actions.||Necessary for the performance of a contract (Art. 6(1)(b))||Friendbase requires data on the time of use etc. to be able to provide users with the expected product/experience.|
|Platform Data (Gaming platform used)||Data indicating which platform was used for logging in, or otherwise to use the Properties.||legitimate interest (Art. 6(1)(f))||We collect information on which platform you use to log in to use the Properties. This is for us to better understand how our users engage with our product and thereby provide a better experience, which constitutes a legitimate interest.|
|Aggregated, anonymized Data||Data has been collected and subsequently anonymized for use in aggregated data sets.||Not applicable.||Anonymized data is not subject to GDPR regulations and as such, it may be freely processed. Nevertheless, we wish to inform you that we use anonymized data to better understand customer behavior and how to improve the Properties.|
SHARING YOUR PERSONAL DATA
We share Aggregated Data with third-party partners and service providers. This Aggregated Data does not contain Personal Data and consists of statistics relating to the usage of the Properties. We do this to better understand the experience of our users, and how to improve the Properties. Since the aggregated data we collect is anonymized and thus does not contain Personal Data, it is not subject to GDPR regulations. We may, to the extent required by law, share some Personal Data with government institutions.
DATA WE COLLECT FROM THIRD PARTIES
Certain Personal Data which we collect are sourced from third parties. We only collect data from third parties that you have interacted directly with and indirect connection to your use of the Properties, such as Google Play Store or Apple App Store. The data we collect from those third parties are (1) Device information (such as phone model or operating system); (2) age range (though not your specific age). While we do not believe that those categories strictly speaking constitute Personal Data under the GDPR definition, we nevertheless only process such data to the extent that it is within our legitimate interests. For device information, our legitimate interests consist in the necessity of such information to ensure the Property’s proper functioning, and forage range our legitimate interests consists in analysis for market segmentation. Since it is an age range and not your specific age, we believe that our legitimate interests in being able to properly understand our userbase in a wide sense are reasonable in relation to the extremely limited processing done to your Personal Data. We also collect certain aggregated market data, but since this data is completely aggregated and anonymized, it does not fall within the scope of the GDPR or other relevant privacy legislation.
TRANSFERS TO COUNTRIES OUTSIDE THE EU AND EEA
We do not share or transfer Personal Data outside the EU/EEA, neither internally within Friendbase nor externally to any third parties.
KEEPING YOUR DATA SAFE
We implement the appropriate technical and organizational measures to ensure that your Personal Data is collected, processed, and stored as securely as possible. However, there is no such thing as perfect security and complete online or offline security can never be guaranteed, so you should always be careful when sharing your information online.
DATA RETENTION AND DELETION
The Properties are not directed to children under the age of 13. We do not knowingly collect Personal Data from children under 13 years old in the Properties or in connection therewith. If you are under 13 years, please do not use or access the Properties.
If we learn that we have collected and processed Personal Data of a child under the age of 13 years, we will take reasonable steps to ensure the erasure of the Personal Data from our systems. This may require us to delete the child’s account to the Properties.
HOW TO CONTACT US