GDPR – Privacy-By-Design and Record of Processing Activities
Company name: TSBMV GLOBAL LTD.* Address: WB Corporate Services (Cayman) Ltd., P.O. Box 2775, Artemis House, 67 Fort Street, Grand Cayman, KY1-1111, Cayman Islands Personal Data Processings: Player data Creation date / last update: August 28, 2020 contact persons:* Sebastien BORGET, [email protected]
* Not formally a DPO under the GDPR. Note that the below uses the “you” and “us” pronouns in paragraphs nrs. 1 o 11 to allow inclusion without modification in our information notices provided to data subjects.
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]
1. We process the following (categories of) personal data When you play our games, interact with or participate in our gaming platforms, connect to a social networking site through our games, register an account, enter a promo code, or place an order, we process the following personal data:
Your IP address, your SIM code, and the country where you are located. Your device type (for example, PC or Mac, iPhone 7, Samsung Galaxy S7) and operating system version.
For analytics, most, when you installed and played the game, your progress throughout the game, and events that are connected to your game-play. We generally cannot identify you with this data, but treat it the same as personal data.
2. What (purposes) do we use the data for We use this personal data to perform analytics for our games and allow third-parties to sell, buy and deliver advertising in those games that display advertising. We use your IP address and SIM code to comply with legal obligations, specifically to comply with VAT reporting obligations
We use social network data to show you personalized content and synchronise your online progression across multiple devices. For example, we might show a list with only your friends in it, or show your name or avatar on an in-game object.
We use your email address that you provided when you signed up for our newsletter to send you the newsletter
3. What is our legal basis for the processing For both analytics and advertising we base the processing of personal data on the legitimate interest of TSBMV GLOBAL LTD. For analytics, this is our ability to analyze how players progress through our games to make them better, and to know our player-base on an aggregate level. For advertising, this is our ability to be able to off-set development costs and risk with advertising income. We also process your personal data for the legitimate business interest of complying with a legal obligation -- we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency. For the third-parties we use, their legitimate interest is to be able to offer us their services, and for advertising third-parties and advertisers to be able to show you advertising.
4. Where do we obtain the data from (sources) We obtain data from you (when you provide it directly through the Website) and from our third-party services providers:
- Google Analytics
- Google Tags
5. How long and where do we store data We store the personal data that we collect for up to 5 years, and only aggregate data after that time. Aggregation data means that we can no longer look at data for individual players. We store the data with our third-party services provider, Amazon AWS. When a third-party service provider is a controller, they may keep data as well, either for a shorter or longer period.
6. What safeguards have we taken to protect data Taking into account the nature, scope, context and purpose of the processing, we have taken the following technical and organizational measures:
- Access to our database and user accounts with third-party service providers is protected with access control.
- Access to the database is limited, not all staff in our organization have full access.
- Data sent from our games is encrypted in transit where technically possible. We do not actively monitor the security of our databases and need to rely on our processors to notify us of any data breaches.
7. Who we share data with We may disclose aggregated data and any information that does not identify an individual without restriction.
We may also disclose personal information that we collect or you provide:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, reorganization, dissolution, or other transfer or sale of some or all of TSBMV Global Ltd.’s assets.
- To fulfill the purposes for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We share data with the following third-parties. These are either controllers, or processors acting on our behalf. We have linked to their respective policies and given a basic description of what they do:
- Google Analytics
- Google Tags
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety or TSBMV Global Ltd., our end users, or others.
9. Your Rights You have the right to request access to your personal data that we process. You also have the right to:
- Rectify incorrect personal data or erase it in certain circumstances.
- Restrict or object to the processing of your personal data.
- Receive your data so that you can use it elsewhere (data portability).
If you wish to exercise any of the above rights, please send us an email at [email protected] You may also update your personal data in your profile on The Sandbox via the settings. Finally, you have the right to lodge a complaint with a supervisory authority. If you do not know who your supervisory authority is, please contact us and we will tell you.
Address: WB Corporate Services (Cayman) Ltd., P.O. Box 2775, Artemis House, 67 Fort Street, Grand Cayman, KY1-1111, Cayman Islands Mail: [email protected]
11. Version information: We last updated this notice on August 28, 2020. You can view it at https://www.sandbox.game/en/privacypolicy/