Interactive 360 SL This privacy policy applies to personal information that Interactive 360 S.L., (hereinafter ‘COMPANY’ or ‘Us’ or ‘We’ or 'Interactive 360') processes in accordance with the COMPANY’s application, software and associated services, which are provided by the COMPANY. We respect your privacy and are committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how the COMPANY collects, store and share your personal data, and it applies whenever you visit the COMPANY’s sites, install the COMPANY’s apps or play its games, interact with Us or otherwise access or use any of the COMPANY Services.

1) WITH WHAT PURPOSE WILL INTERACTIVE 360 SL PROCESS THE USER’S PERSONAL DATA AND FOR HOW LONG?

Your collected personal data will be processed by Interactive 360 SL in conformity with the following purposes:

  • 1. Reception, management and giving response when you report a problem, contact or communicate with Us.
  • 2. Maintenance, support and updating of the Services, as well as of the contents
  • 3. Resolution of possible technical incidents or of those of any other nature that may arise in relation to the Apps or Services.
  • 4. Draw-up of anonymous statistical reports on access habits and the activity developed by Users.
  • 5. To use certain features in Our Services, You may allow Us to access Your camera or the microphone. Depending on Your device, Apple and Android systems will ask for Your permission before allowing Us to access these features.

In the event that the User provides data from third parties, he/she declares to have their consent and undertakes to transfer the information contained in the Privacy Policy to the interested party, the holder of said data, exempting Interactive 360 SL from any liability in this regard. However, Interactive 360 SL may carry out the necessary verifications to confirm this fact, adopting the corresponding due diligence measures, in accordance with applicable legislation on data protection.

The data will be treated during the time necessary for the realization of the objectives, differentiating between the data necessary for the management of the contracted service and the collection of those treated for reasons of publicity or customer service, unless the User requests its cancellation to Interactive 360 SL, opposes or revokes its consent.

2) WHAT DATA WILL WE DEAL WITH?

We will process Your data that are necessary to provide You the required service, among others:

  • 1. Usage Information. We collect information about Your activity on Our Services, for instance how you use them (e.g., date and time you logged in, time spent in the App, features you’ve been using, advertising that You click on).
  • 2. Geolocation data (in some of our apps), which is any information which indicates the geographical position of Your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some apps may collect this data when the app is not open or actively in use.
  • 3. Information on your wireless and mobile network connection, like your service provider and signal strength.
  • 4. Hardware and software information such as IP address, device type, App crashes, app version, advertising IDs (such as Google’s Advertising ID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

3) WHAT DATA INTERACTIVE 360 SL DOES NOT DEAL WITH?

Your security & safety comes first. That’s why in Interactive 360 SL your sensitive information is not collected or stored under any circumstances. You will always be in possession of your personal information.

Exactly, the COMPANY does not keep or archive:

  • 1. Name & Surname. Your identification is private at all times, Interactive 360 SL does not have access to this matter.
  • 2. Email. Interactive 360 SL does not receive your email. The company will only have access to this matter if there were any will on the user’s behalf to get in touch via survey or form.
  • 3. Phone number. Interactive 360 SL does not use this information for any of its operational purposes, and therefore the COMPANY does not authorize the use of phone credentials, nor its storage.
  • 4. Passwords of any kind. All passwords are fully encrypted, your access credentials are under the most strict algorithm security methods.
  • 5. Address. None of Interactive 360 SL apps, request or collect specific address codes. In the event that the location permissions are required for its operation, the COMPANY tracks anonymously the essential geolocation data for the correct running of the app.
  • 6. Credit card or any billing or payment details. All sensitive data regarding payments such as; credit card and/or banking information is handled & processed by Google or Apple for any digital products consumed through our apps. Interactive 360 SL does not have access to this information or related banking elements.

4) WHAT IS THE LEGITIMACY OF DATA PROCESSING?

The legitimacy of the data processing will be:

The execution of the Agreement for:

  • 1. Management of the Services selected by the User

The User’s consent to:

  • 1. The management of queries, requests of information, complaints and claims.

The legitimate interest of Interactive 360 SL for:

  • 1. The creation of anonymous statistical reports..

You may revoke Your permission for any of the treatments, although this will not affect the lawfulness of the treatments carried out previously To revoke this consent, the User may contact Interactive 360 SL at the following e-mail address: legal@newry.es.

5) FOR HOW LONG WILL WE KEEP USER’S DATA?

The data will be processed during the time interval necessary to accomplish the purposes they have been collected for, unless the User requests to withdraw from Interactive 360 SL, opposes or revokes his consent.

The data will be processed during the time interval necessary to accomplish the purposes they have been collected for, unless the User requests to withdraw from Interactive 360 SL, opposes or revokes his consent.

6) WHO THE DATA WILL BE SHARED WITH?

User’s data may be communicated to:

  • 1. Entities in charge of managing the corresponding Services, as the case may be.
  • 2. Other group companies to assist us in technical processing operations.
  • 3. We may disclose Your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; or (iii) to protect and defend the rights, property or safety of Our company, Our users, Our employees, or others.
  • 4. Additionally, the data may be accessible by Interactive 360 SL suppliers, being the said access necessary for adequate meeting of legal obligations and/or the provision of services for the aforementioned purposes. The said suppliers will not process your data for their own purposes that have not been previously informed by Interactive 360 SL.

The recipients indicated in this section may be located within or outside the European Economic Area; in the latter case, International data transfers are duly legitimate.

7) EXERCISE OF RIGHTS

The User may at any time and free of charge send a letter to the address indicated in the heading of this Policy or send an e-mail to the address legal@newry.es with the Reference “Data Protection”, attaching a photocopy of his identity document, to:

  • Revoke the granted consent
  • Obtain confirmation of whether at Interactive 360 SL are processed personal data concerning the User or not.
  • Access Your personal data.
  • Rectify inaccurate or incomplete data.
  • Request deletion of Your data when, among other reasons, the data are no necessary for the purposes they were collected for.
  • Obtain from Interactive 360 SL the limitation of data processing when any of the conditions provided in the data protection regulations is met.
  • Obtain human intervention, to express your point of view and to challenge the automated decisions adopted by Interactive 360 SL, in the cases foreseen in the regulations.
  • Allows User´s to move, copy or transfer personal data easily.
  • Rectify inaccurate or incomplete data.

Your personal information belongs to you, and We will make sure your rights are respected. You can contact Us at legal@newry.es at any time to ask for a copy of your data, to withdraw your consent, or to obtain the deletion of the information We keep for you.

Consent withdrawal and opt-out of sale of information

You can change your consent status at any time from the Privacy Settings available in Interactive 360 SL mobile games and applications. Please note that if Interactive 360 SL does not sell the personal information of its users, We may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services.

Adjusting your consent settings within Interactive 360 SL apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

Access right

Upon request, Interactive 360 SL will provide you with information about whether We hold any of your personal information. You may access or request deletion of your personal information directly in Interactive 360 SL mobile apps or by contacting Interactive 360 SL Data Protection Officer as indicated in the “Contact” section below. We will respond to your request within a reasonable timeframe.

Rectification and erasure

You may request Interactive 360 SL the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request Interactive 360 SL to erase without undue delay your personal data when it is no longer necessary for Interactive 360 SL to retain such data. In order for your data to be erased or rendered inaccessible you can either:

  • Reset your mobile advertising identifier (IDFA on iOS, GAAID on Androïd) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
  • Contact Interactive 360 SL Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by Interactive 360 SL on you and/or your device permanently erased or anonymized Portability Upon request, Interactive 360 SL will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract. Right to lodge a complaint You may lodge a complaint with a Data Protection Authority. Interactive 360 SL being a Spain company, our supervisory authority is in Spain.

8) SECURITY MEASURES

Interactive 360 SL will at all times treat the User’s data in an absolutely confidential manner and will keep the secret thereof, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical-organizational measures that guarantee the security of Your data and prevent their alteration, loss, unauthorized treatment or access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed.

9) MINORS AND INCAPABLE PERSONS

In the case of persons under 14 years of age or incapable, the consent for the processing of personal data must be given by the father, mother or guardian of the minor or incapable person. If you are a minor, and are not sure to understand everything in this Policy, please make sure to speak with a trusted adult before using Interactive 360 SL Apps and Games. Please also remember that [COMPANY’s] Apps and Games are not meant to be used if you are under 16.

10) SPECIAL ATTENTION

  • DUE TO THE SPECIAL GAMEPLAY AND SOCIAL FUNCTIONS OF THIS GAME, YOU NEED TO CALL YOUR FRONT CAMERA AND MICROPHONE THROUGHOUT THE USE OF THIS GAME. YOU CAN TURN OFF THE MICROPHONE FUNCTION THROUGH [SETTINGS], BUT THE FRONT CAMERA WILL ONLY PAUSE FOR A PERIOD OF TIME. IF YOU CANNOT ACCEPT IT, YOU CAN CHOOSE TO UNINSTALL THE GAME AND TERMINATE THIS SERVICE AGREEMENT.
  • THIS GAME IS PROVIDED TO USERS OVER 13 YEARS OLD (USERS IN THE EU ARE OVER 16 YEARS OLD). IT IS ONLY AVAILABLE TO USERS BELOW 13 YEARS (AND USERS IN THE EU BELOW 16 YEARS), PROVIDED THAT THE USER HAS OBTAINED THE EXPLICIT CONSENT OF THEIR GUARDIAN THERETO BEFORE REGISTERING OR USING THIS GAME. IF THE GUARDIAN HAS OBJECTIONS OR QUESTIONS, PLEASE CONTACT US. (admin@interactive360.info).

You'll find in this policy information about the following:

  • 1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

    • What information we hold will depend on our relationship with you. Typically, this may include the following:

    Customers/players We will collect some information about you to enable you to play our games, to improve or optimise your gaming experience, to provide customer services, to improve the services we provide and for marketing (see below for more details). This includes: •Your contact information such as name and(if you choose to provide them) your phone number and email address; • Your player username and password; • Your game profile – including your profile picture and any information needed for the game to function, such as an inventory of in-game items; • Other data you choose to give us such as data to identify a lost or lapsed account such as the answer to a special question we may ask you in order to permit you to unlock or recover a lost or lapsed account; • Your game user account or role ID(s) – Interactive 360-specific ID(s) generated by our game server for you; • Analytics ID – a randomly generated anonymous identifier used to distinguish activity from one game account versus another in our analytics data; • Third party account ID – for example your account with Facebook, Xbox, Game Center, VK, WeChat, Google, Steam or PSN which you may use to sign into your game account, leverage your social graph, or integrate with third party features (such as achievements); • Usage data including information about how you use our website, products and services and your game progress; • Your internet protocol (IP) address and mobile device identifiers (such as for example your device ID, advertising ID, MAC address, IMEI); • Data to fight fraud (such as refund abuse in games or click fraud in advertising); • Data about your device, such as device name and operating system, browser type and language; • Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences and it is at your full own discretion and control to adjust the settings on your device to turn off the function. • Your third-party social account information • Front camera, microphone permissions • Extensive geographical location
    Our suppliers We will collect contact information so that we can manage our relationship with you, and, where applicable we may collect bank account details (to enable payment for services). When you provide services to us we may collect other information from you which is relevant to the provision of those services.
    Job applicants If you apply for a job with us, or send us your CV, we will collect information relevant to the position that you apply for and will keep a copy of your CV for as long as is necessary in order to assess your suitability for a position with us. This will be explained in more detail at the time you make any application.

  • 2. HOW WE COLLECT INFORMATION ABOUT YOU

    • We will collect this information in a variety of ways depending on how we interact with you.

    Direct interactions You may give us your identity, contact or other information by filling in online forms or by corresponding with us by post, phone, in-game, email or otherwise. This includes personal data you provide when you: • Use our products or services; • Create a game account in one of our games or on our website, if any; • Interact with our Customer Services department or our Privacy Office; • Subscribe to our mailing lists; • Enter a competition, promotion or survey; • Give us feedback; • Provide services to us.
    Third parties • We may receive personal data from a third party if you link a third party with the Service or make it available to us via your privacy settings. This may include your third party account ID, game profile and user ID – for example from your account with Facebook, Game Center, VK, WeChat, Google, Xbox, Steam or PSN which you may use to sign into your game account, leverage your social graph, or integrate with third party features (such as achievements). • Technical data from advertising networks and • search information providers. • References and other information if you apply for a position with us.

  • 3. HOW WE USE YOUR INFORMATION

    • We use different information in different ways: • To send you communications related to our services and games, answer your enquiries or deal with your complaints; • Providing and managing our services including our games; • Allowing you to participate in our website features; • Verifying and confirming payments (where relevant interacting with third party payment providers); • Account verification and clearance; • Direct marketing letting you know about products and services that may be of particular interest to you; • Administering surveys and opinion polls; • Managing competitions and/or promotions and your registration for the same; • Technical and usage information/analytics to help us develop games that our customers want to play and to improve them and to detect cheating and activities that ruin the experience of players using our games, security risks, fraud and other unlawful activity; • Business and website analysis and improvement; • The provision of social features as part of our services; • Customising your personal experience; • To send you related information such as updates, security alerts and support messages; • On-site and in-app advertising and promotion of our goods and services and those of our service providers and trusted third parties; • Website, system administration and account verification; • Leader boards, Discord and community information, nicknames and club name/club information; • To moderate communications between players either automatically or manually; • To answer or satisfy legal or regulatory requirements; and • When you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks (we encourage you to review the privacy notices/policies of these social networks to enable you to opt out of such activities).

  • 4. LEGAL BASIS FOR PROCESSING

    • There are a number of different legal grounds for processing personal information. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that: • You have provided your consent to us using your personal information in that way (for example where you provide us with consent to send you marketing communications about our products and services); and/or • Our use of your personal information is in our legitimate interest as a commercial organisation. For example, we currently are not but may at some point in the future use cookies to track information about how our website is used in order to continually improve its layout based on how you and other users interact with its content, and to personalise it to the user (for example, by showing content or a language which is relevant to your geographic location), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights; and/or • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to manage your account); and/or • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation. We generally do not collect or process any 'special categories' of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life and sexual orientation). If this would apply, we will generally rely on obtaining additional specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.

  • 5. CHILDREN

    • Protecting children’s privacy is of high importance for us. Our websites and our games are not intended for children under 13 years old and we do not knowingly collect data relating to children under 13. In respect of games that are not directed at children but which may nonetheless appeal to them, we take additional steps to limit access to the Services based on the player’s age.

  • 6. SHARING YOUR INFORMATION

    • The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or our affiliated companies if this is necessary to provide you with our services, respond to your inquiries or for any of the purposes described in this policy. This may include: • Our business partners and suppliers; • Sub-processors who store or process information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be 'personal data'; • Our auditors, insurers, lawyers and other professional advisers; • Credit reference agencies; • Law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; • Other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

  • 7. SOCIAL FEATURES

    • Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted. Our games and services may include features from our partners, if any, such as social media interaction tools (and albeit not currently, in the future may also relate to in-game advertising). These partners, if any, may in such case, following your consent, access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices and opt out where you deem relevant.

  • 8. INTERNATIONAL DATA TRANSFERS

    • Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this policy. Our relevant group entities and partners will use adequate safeguards, which may amongst others include EU-approved standard contractual clauses.

  • 9.YOUR RIGHTS

    • Under US or EU data protection laws you have a number of rights in relation to your personal data. We respect and honour these rights and will help you to exercise them insofar as we are able. You have the right: • To request access to or receive a copy of any personal data which we hold about you; • To rectification of your personal data, if you consider that the information we are holding is inaccurate; • To ask us to delete your personal data, if you consider that we do not have the right to hold it; • To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent); • To ask us to stop or start sending you marketing messages as described below in the marketing section; • To restrict processing of your personal data; • To data portability (moving some of your personal data elsewhere) in certain circumstances; • To object to your personal data being processed in certain circumstances; and • To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data. Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with. Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject. We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, you have the option to fully control the data you shared with us, and you may update your information directly under your profile or adjust the settings on your device. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our Swedish EU GDPR Representative legal@newry.es. or contact your local data protection authority within the European Economic Area respectively the Swedish data protection authority.

  • 10. MARKETING

    • If you have accepted to receive notifications for a certain game, we may use your personal information to send you tailored suggestions, offers or auction information about the game. For personalised in-game offers opt-out, you can use the options provided in the game settings. You can easily turn off the notification in each different category within the game or opt out from receiving notifications or alerts on your device. You can opt-out of interest-based advertising on mobile applications, if any, by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).

  • 11. HOW LONG WILL WE KEEP YOUR INFORMATION?

    • We will only keep the information we collect about you for as long as required for the purposes set out in this notice or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required. By law we have to keep basic information about our customers (including contact, identity data, (and financial and transaction data relating to transactions via our store, if any)) for six tax years plus the current tax year after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see "Your rights" for further information. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. If you opt out from marketing, we may retain the necessary information to enable us to respect your wishes to not be contacted for marketing purposes.

  • 12. SECURITY

    • We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.

  • 13. LINKS TO OTHER SITES

    • Our websites may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

  • 14. CONTACT

    • Questions, comments and requests regarding this policy are welcomed and should be addressed to admin@interactive360.info

  • 15. CHANGES TO THIS POLICY

    • Any changes we make to our policy in the future will be posted on this page and, where material and appropriate, will be notified to you by in-game message. We urge you to check regularly to see any updates or changes to our policy.

11) CONTACT

Interactive 360 SL You can contact our DPO at: admin@interactive360.info Paseo Castellana, 123 - 28046 Madrid