Privacy Policy (App Sgame Pro)

In accordance with Article 13 of EU Regulation 2016/679 (hereinafter “GDPR”), Sgame S.A. wishes to inform the users of the mobile application named “SgamePro” (hereinafter respectively “Users and “App”) about the usage of personal data collected through the App.

1. DATA CONTROLLER, DATA PROCESSOR AND DATA PROTECTION OFFICER

The controller of personal data is Sgame S.A. (tax code and VAT no. CHE-455.786.719), with premises in Lugano (Switzerland), via Balestra 33, e-mail dataprotection@sgamepro.com (hereinafter “Data Controller” or “Sgame”).

The updated list of appointed Data Processors may be provided upon request by the data subjects and/or Users.

A Data Protection Officer (DPO) ex art. 37 Gdpr has been appointed;  the contact details of the data protection officer are: dataprotection@sgamepro.com.

2. DATA COLLECTED AUTOMATICALLY BY THE APP

The information system and the software procedures responsible of the operation of the App collect automatically, during its usage, some information which transmission is entailed in the usage of internet communication protocols.

The collected information are the following:

  • IP address or domain name of the device used by you;
  • addresses by a URI (Uniform Resource Identifier) of the requested resources;
  • time of request;
  • method used submitting the request to the server;
  • size of file received in response;
  • numeric code indicating the status of the response given by the server (success, error, etc.);
  • other parameters related to the operative system and to the IT environment of your device.

Such information are collected in order to be associated with identified users and are used exclusively in order to obtain anonymous statistical information concerning the usage of the App and in order to control its correct operation.

3. PERSONAL DATA YOU COMMUNICATE US WILLINGLY BY USING THE APP

The Data Controller  processes your personal data and hence the information through which the Users can be  identified, which includes, without limitation, the name, surname, birth date, address, e-mail address and phone number.

4. FOR WHAT PURPOSES WE PROCESS SUCH DATA

Your data will be processed for the following purposes:

4.1 comply with legal provisions;

4.2 carry out the technical management of the App;

4.3 sign up to the Sgame Pro platform in order to use the services offered by the same (such as: download games and enable users to play such games on the Sgame Pro platform; earn, through the use of games, crypto-token; purchase products and services using such crypto-token; etc.);

4.4 update, upon express consent, the data subject about all sales promotions and marketing initiatives, including direct marketing, of Sgame Pro, also by sending marketing/promotional materials through automated means or traditional means of contact, for instances through push notifications, e-mails or sending sms or mms (the “Marketing”);

4.5 communicate or transfer, upon express consent, the data of the User for specific marketing purposes and third companies pertaining to the following product categories: electronics and IT, clothing, publishing business, finance and insurance, tourism and hosting structures, couponing, gaming, cosmetics and pharmaceutics, gifts.

Giving the consent for the purposes under paragraphs 4.4 and  4.5 is optional and in case it will not be given it only entails the impossibility to carry out direct marketing and profiling activities and the transfer of the data to third parties.

The legal basis for the data processing is Article 6/1/a GDPR.

5. TO WHOM AND IN WHAT AREA WE MAY TRANSFER YOUR DATA

The data of the Users may be communicated, within the EU, in accordance with the provisions of the GDPR, to the following subjects:

(i) to the financial administration and/or other public authorities, in case it is requested by law or requested by these subjects;

(ii) to external structures and/or companies of which the data controller avails himself for the carrying out of connected, instrumental or consequential activities for the performance of services by the App;

(iii) to external advisors (for instance for the management of tax fulfilments), appointed as Data Processors by the Data Controller.

6. YOUR RIGHTS

Please remind that you are entitled to exercise your rights envisaged by Articles 15, 16, 17, 18, 20 e 21 GDPR in any moment, by sending a communication in writing to the contact information under Article 1 above, in order:

  • to obtain confirmation of the existence or non-existence of your personal data with indication of the relevant origin, verification of its correctness, or to request the updating, rectification or amendment of such data;
  • to have access to such data or obtain the rectification, cancellation or a limitation of the processing of such data;
  • to obtain the cancellation, transformation in anonymous form or the blocking of the data processed in violation of the law.

You may also object to the processing of the data you are concerned with.

With reference to the Marketing, we highlight that you are entitled to request the cessation of the processing carried out by automated contacting means, also traditional ones. Moreover, you are also entitled to exercise such right only partially, i.e. requesting the interruption, for instance, of the sending of promotional communications carried out by one or some of the contact means for which you have given your consent.

7. FACEBOOK SOCIAL PLUGINS AND OTHER NETWORKS

The App could contain social network plugins (for instance Facebook, Twitter etc.). If you access one of our websites having such plug-in, the internet browser connects directly to the server of the social network and the plug-in is displayed on the screen thanks to the connection to the browser. The plug-in communicates to the server of the social network which pages the data subject has visited. If the user of a social network visits our web sites, his or her personal data could be associated with the social network account. Also, in case any features of the plug-in are used (for instance, clicking on the “like” button or posting a comment), the information will be associated to the account of the social network. Further information on the collection and the usage of the data by the social networks in general, as well as on the rights and modalities available to protect the confidentiality of the data subject in this context are available on the relevant pages of the social network account. If the data subject does not want to associate the usage of the App to his social network account, he must log out from the social network, before visiting the social networks through the App.

8. INTERACTION BETWEEN THE APP AND THE DEVICE OF THE DATA SUBJECT

The App will not copy the numbers listed in the phonebook of the data subject and will not ask to access it.

9. DURATION OF PROCESSING

Without prejudice to legal obligations, the personal data of the Users will be stored for a definite time period, based on criteria founded on the nature of performed services.

Please note that the data for Marketing purposes will be processed according to the “OPT OUT” model, i.e. until the Users exercise their right to unsubscribe from Marketing activities.

10. SAFETY MEASURES

Through the App, your data are processed in accordance with applicable law and using due safety measures as envisaged by Articles 5 and 32 GDPR.

In this respect, we confirm to, among others, adopt due safety measures aimed at preventing not authorized access, theft, broadcasting, modification or destruction of your data.

11. AMENDMENTS TO THE PRIVACY POLICY

The Data Controller reserves the right to amend the present privacy policy. In such case you will be forthwith informed about it as soon as you use the App thereafter.

12. RIGHT TO LODGE A COMPLAINT EX ART. 77 GDPR

In case our Company does not provide you a feedback by the term envisaged by the laws or if the response to the exercise of your rights is undue, you are entitled to lodge a complaint with the Swiss Privacy Supervisory Authority (Federal Data Protection and Information Commissioner) with the following contact details: website https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html, email info@edoeb.admin.ch, switchboard +41 (0)58 462 43 95.  As a European Community citizen, if You consider that the processing of personal data infringes this Regulation, You can exercise Your rights addressing the request to the supervisory authority in the Member State of Your habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

Privacy Policy (Website)

In accordance with Article 13 of EU Regulation 2016/679 (hereinafter “GDPR”), Sgame S.A. wishes to inform the users and/or visitors to the www.sgamepro.com (hereinafter respectively “Users and Site”) about the usage of personal data, log files and cookies collected through the Site.

1 – DATA CONTROLLER, DATA PROCESSOR AND DATA PROTECTION OFFICER

The controller of personal data is Sgame S.A. (tax code and VAT no. CHE-455.786.719), with premises in 6900 Lugano (Switzerland), street Serafino Balestra n. 33, e-mail dataprotection@sgamepro.com (hereinafter “Data Controller” or “Sgame”). The updated list of appointed Data Processors may be provided upon request by the data subjects and/or Users. In case a Data Processor Officer will be appointed, his or her identification data will be made public through the amendment of the present privacy policy.

  • Data collected automatically by the site
  • Information collected automatically by the Site

Like all websites, our Site also uses log files, in which information collected in an automated manner is kept during your visits. The information systems and software procedures used to operate the Site, in fact, automatically acquire some information during use, the transmission of which is implicit in the use of Internet communication protocols. The collected information is the following:

  • IP address or domain name of the device used by you;
  • addresses by a URI (Uniform Resource Identifier) of the requested resources;
  • time of request;
  • method used submitting the request to the server;
  • size of file received in response;
  • numeric code indicating the status of the response given by the server (success, error, etc.);
  • other parameters related to the operative system and to the IT environment of your device.

Such information are collected in order to be associated with identified users and are used exclusively in order to obtain anonymous statistical information concerning the usage of the Site and in order to control its correct operation.

2 – Cookies

The Site uses cookies. Cookies are text files recorded on IT support, which allow to record some parameters and data communicated to the IT system, through the browser used by you. Therefore, these tools allow an analysis of your habits in using the Site, for different purposes: execution of IT authentication, monitoring of sessions, storage of information on specific configurations regarding users accessing the server, storing preferences, etc. Cookies are distinguished in:

  1. Technical cookies: they are used to make browsing or to provide a service requested by you. Without the use of these cookies, some operations could not be completed or would be more complex and/or less secure.
  2. Profiling cookies: they are used to track your browsing and create profiles on your tastes, habits, choices, etc. In this way, advertising messages can be transmitted to your device in line with your preferences already shown in the previous online navigation.

For the installation of technical cookies, your consent is not required. For the installation of profiling cookies your consent is required: if you do not want your device to receive and store profiling cookies, you can change the security settings of your browser. In fact, through the settings of the browser used to navigate, you can decide whether to delete and/or avoid the installation of cookies on the device used. However, it should be noted that by deactivating the use of profiling cookies you will not be able to take full advantage of certain features of the Site. While browsing the Site, you can also receive cookies on your terminal that are sent from different websites or web servers (hereinafter, “Third Parties“). The Third Parties, who use cookies on our site, are:

  • Google Analytics, a service of the company Google Inc. (“Google“), whose information can be found at https://www.google.com/analytics/learn/privacy.html?hl=it. You can refuse the installation of cookies used by Google Analytics by selecting the corresponding parameters in the specific options of the Google browser.

Through the use of the Site, the use of Cookies is considered accepted and consent to the processing of data collected by Third Parties is accepted.

3 – PERSONAL DATA YOU COMMUNICATE US WILLINGLY BY USING THE SITE

The Data Controller  processes your personal data and hence the information through which the Users can be  identified, which includes, without limitation, the name, surname, date of birth, address, e-mail address and phone number.

4 – FOR WHAT PURPOSES WE PROCESS SUCH DATA

Your data will be processed for the following purposes:

4.1 comply with legal provisions;

4.2 carry out the technical management of the Site;

4.3 take advantage of specific services for which registration is required (for example, the “Ambassador” service or the request for information concerning SGM tokens).

The data provided by you will be processed mainly with IT tools under the authority of the Data Controller, by specifically appointed, designated and instructed to process, pursuant to Articles 28 and 29 GDPR. We inform you that appropriate security measures are observed, also pursuant to Articles 5 and 32 GDPR to prevent the loss of data, illicit or incorrect use and unauthorized access.

5 – NATURE OF THE CONSENT FOR THE PROVISION OF DATA AND THE LEGAL BASIS OF THE PROCESSING

Please be informed that for the purposes referred to the previous Article 3, the provision of your personal data also takes place automatically and is necessary to be able to browse the Site and use the services for which registration is required. Remember that, in any case and at any time, you can request the Data Controller to delete your data through a simple communication to be sent, without special formalities, to the contact details referred to in the previous Article 1. With reference to the purposes referred the previous Article 3, the legal basis of the processing is the fulfillment of legal obligations, as well the execution of the services provided through the Site (pursuant to Article 6, paragraph 1, letter b GDPR).

6 – TO WHOM AND IN WHAT AREA WE MAY TRANSFER YOUR DATA

The data of the Users  may be communicated, within the EU, in accordance with the provisions of the GDPR, to the following subjects:

(i) to the financial administration and/or other public authorities, in case it is requested by law or requested by these subjects;

(ii) to external structures and/or companies of which the data controller avails himself for the carrying out of connected, instrumental or consequential activities for the performance of services by the Site;

(iii) to external advisors (for instance for the management of tax fulfilments) if not indicated in writing by the Data Processor.

7 – YOUR RIGHTS

Please remind that you are entitled to exercise your rights envisaged by Articles 15, 16, 17, 18, 20 e 21 GDPR in any moment, by sending a communication in writing to the contact information under Article 1 above, in order:

  • to obtain confirmation of the existence or non-existence of your personal data with indication of the relevant origin, verification of its correctness, or to request the updating, rectification or amendment of such data;
  • to have access to such data or obtain the rectification, cancellation or a limitation of the processing of such data;
  • to obtain the cancellation, transformation in anonymous form or the blocking of the data processed in violation of the law.

You may also object to the processing of the data you are concerned with.

8 – DURATION OF PROCESSING

Without prejudice to legal obligations, the personal data of the Users will be stored for a definite time period, based on criteria founded on the nature of performed services.

9 – SAFETY MEASURES

Through the App, your data are processed in accordance with applicable law and using due safety measures as envisaged by Articles 5 and 32 GDPR.

In this respect, we confirm to, among others, adopt due safety measures aimed at preventing not authorized access, theft, broadcasting, modification or destruction of your data.

10 – AMENDMENTS TO THE PRIVACY POLICY

The Data Controller reserves the right to amend the present privacy policy. In such case you will be forthwith informed about it as soon as you use the Site thereafter.

11 – RIGHT TO LODGE A COMPLAINT EX ART. 77 del GDPR

In case our Company does not provide you a feedback by the term envisaged by the laws or if the response to the exercise of your rights is undue, you are entitled to lodge a complaint with the Swiss Privacy Supervisory Authority (Federal Data Protection and Information Commissioner – FDPIC) with the following contact details: website www.edoeb.admin.ch, email info@edoeb.admin.ch, switchboard +41 058 462 4395.

Last update: 21st December 2018