August 3rd, 2022

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In this Privacy Policy we explain:

The ways we collect personal data about you and why we do so

How we use your personal data, and

The choices you have about your personal data.

This Privacy Policy applies to all of Rightspot’s applications, games, websites and other related services, collectively the “Services”. Please note that we may from time to time update this Privacy Policy by posting a new version on rightspot.fi.

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HOW TO CONTACT US

If you have questions about data protection or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through our applications and games so we can reply to you more quickly.

Name of the company collecting the personal data (the controller): Rightspot Oy / Rightspot Ltd

Address: Pihlajatie 20, 25360 PERTTELI, Finland

Email: rightspot(at)rightspot.fi

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THE PERSONAL DATA WE COLLECT

Data you provide us directly.

Contact information (such as name and email address or phone numbers)

User name and password

Profile information (such as profile photo)

Country

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Data we collect automatically

Data about your use of the Service, such as application data, purchases made

Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address and IMEI)

Data about your device, such as device name and operating system, browser type and language

Data we collect with cookies and similar technologies (see more below)

Coarse location data (country or city-specific)

Accurate GPS location upon your consent

We also may create a Rightspot and/or application specific ID for you when you use the Services

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Data we collect from our partners

Data we receive if you link a third-party tool with the Services (such as login using your Facebook or Google account)

Demographic data (such as to determine the coarse location of your IP address)

Data to fight fraud (such as refund abuse in games)

Data from platforms that the games run on (such as to verify payment)

Data for advertising and analytics purposes, so we can keep improving our games

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WHY WE COLLECT YOUR DATA

To make the Services functional (performance of contract)

We process data necessary to

Create accounts and allow you to use our applications, play our games and use our Services

Operate the Services

Verify and confirm payments

Provide and deliver products and services you request

Send you communication related to the Services

To make the Services more enjoyable for our users (legitimate interests)

We collect and process necessary data to

Develop and improve the Services and user experience

Manage our relationship with you

Provide social features as part of the Services

Customize your Service experience

Respond to your comments and questions and provide customer support

Provide you offers in the Services related to other Rightspot products and services

Send you related information, such as updates, security alerts, and support messages

Enable you to communicate with other users

To keep the Services safe.

In order to keep the Services and their social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Services and its social features

Take action against fraudulent or misbehaving users or players

To show personalized advertisements (consent)

With your separate consent we collect, process and transfer to our third-party partners personal data to:

Track the content you access in connection with the Services and your online behavior

Deliver, target and improve our advertising and the Services

To analyze, profile and segment anonymized data

In all of the above cases and purposes, we may analyze, profile and segment all collected data in anonymized form.

With your consent

With your consent, we may process your data for additional purposes, such as using your location based on GPS position or your IP address to show you local events.

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WHO CAN ACCESS YOUR DATA

Apart from Rightspot, your data can be accessed by others in the following situations:

Other players and users

Accurate location data is core component in some of our applications. Other users may upon your consent, for example, see your anonymous location or name/nick name and location.

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

International data transfers

Our Services are 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 Privacy Policy. Adequate safeguards to ensure your rights include utilizing and enforcing the Standard Contractual Clauses approved by the EU Commission.

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YOUR RIGHTS AND OPTIONS

Your rights regarding your personal data

You may terminate your account at any time and for any reason by sending a signed request with account identity details to rightspot(at)rightspot.fi or by using the “Delete account” function available in some applications.

You have the right to a copy of your personal information to be supplied to you in an electronic format upon request.

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and the right to restrict how we use or share your data. If certain personal data is processed based on consent given by you, such consent can also be withdrawn by you at any time, for example in the applicable game’s settings.

We will respond to all requests within a reasonable time frame. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority within the European Economic Area for unresolved complaints.

You can contact us at rightspot@rightspot.fi or by using the “Contact support” feature available in some of our games’ settings.

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Opt-out of targeted advertising

You can always opt-out of directed advertising in our games by checking the privacy settings of your device. Please review your device’s user manual on how to do so.

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COOKIES AND SIMILAR TECHNOLOGIES

Some of our online Services use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser or device’s settings, but some parts of the Services may then not function properly.

HOW WE PROTECT YOUR DATA

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Services.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your personal data may be deleted or anonymized after two years of account inactivity. Certain data such as payment data may be stored for periods longer than this in accordance with applicable accounting laws.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, such as your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete such data without delay. If you believe that we might have any data from or about a child under the age of 13, please contact us.