Updated 10.10.2024
This document titled Privacy Policy describes how Game Lounge Limited manages the information and personal data you provide to us, which is essential for maintaining a productive relationship with you.
This policy is relevant to all of our websites, applications, products, and services that reference this policy either directly or do not have a separate one (collectively referred to as Our services). Its purpose is to clarify what data we collect, the motivation behind our data collection, how we handle this data, whom we may share your personal data with, your rights concerning the collection and processing of this data, as well as other important aspects related to privacy and security.
All personal data that you share with us, as well as any data we already possess, will be processed according to the guidelines detailed in this Privacy Policy. This information may be collected through any of the Game Lounge websites (referred to as 'The Website') or other channels that we may provide from time to time.
By engaging with this policy, you acknowledge and agree that your personal data may be processed as described herein. If any part of this Privacy Policy does not align with your views, we kindly ask that you refrain from using our website or providing us with your personal data.
References in this policy to Game Lounge , 'Us', 'We', or 'Our' pertain to the Data Controller, which is Game Lounge Limited , a Maltese company with registration number C 53144 . The registered address for the company is Level 5, Spinola Park, Triq Mikiel Ang. Borg, St Julians, SPK 1000, Malta , and it owns the website jannetridener.com.
All the processing of personal data as described in this Privacy Policy will be conducted in accordance with the following standards:
- The Maltese Data Protection Act (referred to as the 'DPA' – Chapter 586 of Malta's Laws), along with any related legislation that may be updated over time; and
- Regulation (EU) 2016/679 from the European Parliament and the Council dated April 27, 2016, concerning the protection of individuals regarding the processing of personal data and the free circulation of such data, which repeals Directive 95/46/EC (commonly known as the General Data Protection Regulation, or 'GDPR').
Collectively, the DPA and GDPR will be referred to as the 'Data Protection Laws'.
Game Lounge is accountable for determining how and why personal data is processed, thus acting as the 'Data Controller' under the relevant Data Protection Laws.
Definitions
Cookies
'Cookies' refer to small sets of data stored on the user's device.
'Game Lounge Group' refers to any entity that owns shares in Game Lounge directly or indirectly, or in which Game Lounge has shares, directly or indirectly, or that is owned (either directly or indirectly) by the same shareholder, where 'ownership' means holding at least one share in the entity or any affiliate within the group.
The Data Controller
Game Lounge Limited, registered under C53144, is located at Level 5, Spinola Park, Triq Dun Mikiel Ang Borg, St Julians, Malta.
DPO contact Email:
The Data Processor
'The Data Processor' signifies a natural or legal person, public authority, agency, or any other organization that processes personal data on behalf of the Data Controller.
The Data Subject
'The Data Subject' refers to the individual to whom the personal data pertains.
Personal Data
'Personal Data' encompasses any information that can identify you or relates to an identifiable person.
Usage Data
'Usage Data' refers to information collected automatically through the website (or via third-party services used by Game Lounge), including IP addresses, various visit details, and information regarding the sequence of pages visited, alongside other technical parameters concerning the user’s device and operating system.
User
'User' denotes the individual who utilizes jannetridener.com, who, unless noted otherwise, corresponds with the Data Subject.
Security
Game Lounge securely stores your Personal Data on encrypted hard drives.
Personal Data Protection
We employ the highest industry standards for security to safeguard the Personal Data we hold. Our commitment extends beyond stringent quality measures; we also ensure compliance with legal frameworks. We will only process personal data if it's underpinned by a legitimate legal basis as defined by the GDPR.
Personal Data You Give Us
You may give us your personal data by:
- Subscribing to our newsletter
- Filling the contact Us forms
In the next section, we will detail the types of information we collect from you, whether it is mandatory or optional, depending on the specific processes you engage with.
| Process Name | Mandatory personal data | Optional personal data |
|---|---|---|
| Contact form services | We may collect your name, email address, usage data, and cookies data. | None |
| Subscribing to our newsletter | We may gather your email address, usage data, and cookie data. | None |
This includes the Personal Data we gather from your devices.
We utilize usage data and cookies to effectively operate our website, ensuring that the content displayed is relevant and efficient for you and your device. To learn more about cookies, please refer to our Cookie Policy.
Lawful Basis for Processing Personal Data.
| Process Name | Lawful basis for processing |
|---|---|
| Subscriptions | Consent |
| Contact form services | Legitimate interest and Consent |
Processing Based on Our Legitimate Interests.
A legitimate interest exists when we have a business purpose for processing personal data. In these cases, we commit to safeguarding your personal data and ensure that such processing does not unfairly impact you or your interests.
Processing Based on Your Consent.
While consent is one basis for processing your personal data, it is not the only one we may rely upon. We will only process your data based on your consent when other legal grounds (such as compliance with a legal obligation or legitimate interest) cannot be used. If we process your personal data based on your consent, you reserve the right to withdraw that consent at any time and in the same manner you provided it. Should you choose to withdraw consent, we will examine whether we can process your personal data on a different legal ground, and will inform you accordingly. Withdrawal of consent does not affect any processing done prior to the withdrawal.
To be clear, we want to emphasize that in limited scenarios where we are unable to rely on another legal justification (e.g., our legitimate interests), your personal data will be processed based on your consent.
In instances where we rely on your consent (which we will obtain clearly and transparently from you), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME , using the same method through which it was granted.
If you decide to withdraw your consent by contacting us at the addresses provided below, we will check whether an alternative legal basis exists for processing your personal data (for instance, legal obligations that require us to process your data) where we would be authorized or even required to continue processing without your consent and will inform you accordingly.
When we request your personal data, you can always refuse to provide it. However, if you opt not to share the data necessary for us to provide requested services, we may be unable to fulfill those requests, especially if consent is the only legal basis available.
For clarity, consent is not the only basis for processing your personal data . In the preceding section, we detailed various grounds that allow us to process your personal data for specific objectives.
Other Purposes
We may need to use and keep personal information for purposes like preventing losses, or to protect our own rights, privacy, safety, or property, or that of others, based on our legitimate interests.
Data Retention
We keep your personal data in accordance with our Data Retention Policy. Since the GDPR does not specify retention time limits for personal data, the duration we hold onto your data depends on the specific types of data involved. Typically, we will check if any EU or national laws require us to retain specific data for a defined period, in which case we will maintain that data for the maximum duration mandated by those laws. If no such laws exist, we will evaluate if there are any laws or contracts that might be invoked against us, and from there we will determine the relevant periods for those actions. In such instances, we will keep the necessary personal data to defend against any claims or disputes.
After the retention period specified in our policy has lapsed, your personal data will be securely deleted or anonymized without the possibility of recovery. Any personal data we hold for the purpose of service notifications will remain until you inform us that you wish to cease receiving such notifications. For more details on retention durations, please reach out to us.
We retain data for limited durations when necessary for valid business or legal reasons. We strive to ensure our services protect information against accidental or intentional deletion. Thus, there may be delays from the time you delete content until copies are removed from our active and backup systems.
Do We Share Your Personal Data?
To ensure you receive top-notch service, we may need to share your personal information with external suppliers.
| 3rd Party | Service | Place |
|---|---|---|
| Google Ireland Limited | Using Google Analytics, we monitor and analyze how the jannetridener.com website is used. Additionally, we employ Google Tag Manager for managing our tags and rely on Google Drive for storing and organizing backups. | Ireland |
| Xtremepush | Xtremepush functions as an analytics and engagement platform across multiple channels, which we utilize for gathering insights, enabling web push notifications, filling out online forms, and executing marketing activities. | Ireland |
Transfer of personal information to other related recipients.
As necessary and compliant with Data Protection Laws, relevant data may be shared with Game Lounge members and personnel, as well as with other divisions within Game Lounge (adhering to legal requirements) and affiliated organizations or subcontractors for various objectives:
- To administer offers and promotion;
- To evaluate and interpret marketing tactics, industry trends, market research, and training needs.
- To address your requests for access to your information and answer your inquiries related to GDPR.
- In situations where we genuinely believe that sharing your personal data is essential for protecting your rights, ensuring the safety of others, investigating fraudulent activities, or complying with governmental requests.
- To guarantee secure access to our website and provide necessary maintenance.
- To formulate, uphold, and defend our legal entitlements.
- To meet our legal responsibilities to regulatory bodies, while also complying with applicable laws and mandates from other jurisdictions.
- To investigate, prevent, and pursue misconduct.
- To offer support to customers in response to their inquiries and concerns.
The categories of individuals or entities receiving personal data may encompass:
- Marketing Affiliates : This category includes social media platforms and various partners that engage in marketing tasks such as advertising initiatives, optimization processes, and market analysis on our behalf.
- Marketing Advisors : Specialists who provide us with guidance on marketing matters.
- Providers of Communication/Marketing Services : Agencies that assist us in communicating with you via email, chat, SMS, and phone calls.
- Providers of Technical Support : Vendors that ensure the functionality of our website and technical systems, covering both front-end and back-end operations.
- Database Managers : Technical personnel charged with maintaining our organizational database.
- Cloud Service Providers : Companies delivering cloud-based solutions, such as data storage and hosting.
- Data Analysis and Business Intelligence Providers : Organizations that help us with data analysis and business intelligence tasks.
- Companies within the Game Lounge Group : Other enterprises in the Game Lounge Group that contribute various support services to our operations.
- Consultants : Legal experts, bankers, auditors, and insurers providing services in consultancy, legal affairs, banking, insurance, and accounting.
- Payment Processors : Organizations that handle payment transactions on your behalf.
Additionally, the Company may disclose your personal data to:
Other external parties when necessary to: (i) fulfill government requests, court orders, or applicable legislation; (ii) prevent misuse of our website or violations of its terms and privacy policies; (iii) protect ourselves against claims from third parties; and (iv) aid in fraud prevention or investigation.
To any additional third parties if you have provided us with your permission to do so.
Corporate Changes : We may share your personal data with third parties, including those within our corporate family, to facilitate our business operations or in cases where we sell, transfer, or merge parts of our business, assets, or operations. In the event of a merger, acquisition, or sale, your personal data will typically be part of that transaction. Similarly, if we acquire or merge with another company, your information may be utilized by the new proprietors in accordance with the guidelines in this privacy statement. Should these circumstances occur, you will be notified via email and/or updates will be posted on our website, or as mandated by relevant regulations. We will also implement contractual conditions with these parties to ensure that your data remains confidential, protected by appropriate security protocols, and is not misused by them.
Authorized Sharing of Personal Information with Third Parties
As outlined in this Privacy Policy, any personal information pertaining to you may be disclosed to authorized third parties, whether located within or outside the EU/EEA, as long as such sharing complies with Data Protection Laws or relevant regulations. These authorized entities may include but are not limited to Game Lounge personnel, various third parties, and organizations such as law enforcement agencies, accounting firms, regulators, and digital marketing companies. Additionally, personal data may be shared with entities that have introduced you to us or with third parties you have permitted us to share your information with, or any other necessary third party that we must share your personal information with to deliver the products and/or services you requested. The type of personal data shared will align with the products and/or services you opt for.
If your personal data is to be transferred outside the EEA, we will ensure that adequate safeguards are adhered to protect your information. We may also share personal data with associated companies and business partners or successors of our business. The process concerning data transfer outside the EEA is outlined below. Rest assured, your personal data will not be used for marketing purposes by third parties without your explicit consent.
Any authorized disclosures (regardless of whether they happen within or outside the EU/EEA) will comply with Data Protection laws (for instance, all our processors have binding agreements that enforce compliance with these laws, including strict confidentiality obligations). Our service providers (processors) are also subject to numerous other responsibilities, specifically those articulated in Article 28 of the GDPR.
Your personal data will not be used for third-party marketing purposes unless we receive your explicit consent.
Internet Communications
It is important to note that data transmitted over the internet may travel across international borders even when the sender and the receiver are both located within the same country. We cannot be held accountable for any actions taken by you or any third parties concerning your personal data before we receive it, including any transfers from you to us via locations where data protection standards may be lower than those in effect within the European Union, and this applies to any technological means (such as WhatsApp, Skype, Dropbox, etc.).
Moreover, we do not accept responsibility or liability for the security of your information while it is being transmitted over the internet unless our liability is directly mandated by Maltese law.
Accuracy Of Personal Data
We make every reasonable effort to ensure that any personal data we hold about you remains current and accurate. You can inquire about the information we possess about you at any time by contacting us through the methods outlined below. If you identify any inaccuracies, we will correct them and delete any information as necessary. To protect your privacy and security, we shall also take appropriate measures to verify your identity before giving access or making corrections. For more details, please refer to your legal rights under applicable data protection laws listed below.
Links To Third Party Sites
We clearly label links to third-party websites, and we cannot be held responsible for or imply endorsement of any content on those sites (including their respective privacy policies and data handling practices). We recommend that you review the privacy policies presented by any such third-party sites.
Transfer Of Data Outside Of The EEA
Your personal data will only be sent outside the EEA or to any non-EEA country that the European Commission has recognized as offering adequate protection (sometimes referred to as “white-listed countries” – see the list here https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) in the following instances: when you explicitly consent to it; when it is necessary to form or execute a contract between you and Game Lounge; or in compliance with any legal obligations or responsibilities.
In cases where personal data is transferred beyond the EEA, either within the Game Lounge network or to our business partners, we guarantee to implement appropriate measures to ensure that the same level of protection is maintained and the same standards are upheld as those within the EEA. You have the right to request copies of such protective measures by reaching out to us via the provided contact information.
We will utilize contracts that incorporate the EU Standard Contractual Clauses, also known as the EU Model Clauses. These stipulations require any entity that receives personal data to adhere to the same standards that are obligatory within the European Economic Area (EEA). Transfers of personal data to the United States will occur only under two specific conditions: firstly, if the receiving entity is compliant with the EU-U.S. Data Privacy Framework, which is designed to safeguard personal data, and secondly, after we perform a thorough due diligence process to confirm their adherence to the Principles of the framework.
Data Subject Rights
Game Lounge is committed to providing you with the best possible assistance if you decide to exercise any of your rights concerning your Personal Data. In certain situations, it may be necessary for us to confirm your identity before we can process your request to access your rights. Your key rights in this context include several important aspects, but be aware that some of these rights may have certain limitations or exceptions.
- Access to your Personal Data
- You are entitled to receive an electronic copy of your Personal Data, or to arrange for its transfer to another entity (data portability). This should be provided in a structured format that is commonly used and machine-readable.
- You have the right to correct your Personal Data if it is found to be either incomplete or inaccurate.
- In certain situations dictated by applicable laws, you can request the deletion or limitation of your Personal Data.
- You possess the right to restrict the processing of your Personal Data or to object to its processing altogether.
- The right to withdraw consent
- There are specific rights associated with automated decision-making processes and profiling that you need to be aware of.
The Right to Lodge a Complaint
You hold the right to file complaints with the relevant Data Protection Supervisory Authority. Since our main establishment in the EU is located in Malta, the Maltese Information and Data Protection Commissioner (IDPC) is designated as our primary supervisory authority. While we encourage you to first attempt to address any issues directly with us, you can also reach out to the appropriate authority at any time, as previously mentioned.
Information We May Require From You
When you contact us to exercise your rights, we may request certain information to verify your identity, allowing us to confirm your right to access your Personal Data or fulfill any other rights you wish to exercise. This measure is implemented to ensure the security and preventing unauthorized access to personal data. Additionally, we may reach out for more details related to your request, which can help us respond more efficiently.
Response Time Limit
We strive to address all legitimate requests within one month, unless legal stipulations require a shorter timeframe. In cases where your request is particularly complicated or if there are several requests made at once, it could take longer than a month to provide a response. In such instances, we will keep you informed about the delay and the steps being taken.
Other info about user data storage
To improve user experience, we have implemented various features on our website, such as a comparison tool and a sticky banner. When you engage with these features, we collect certain non-personal information, like your interactions and what items you have added to the comparison tool, utilizing session storage in your web browser. We assure you that no personal data is processed through these functionalities. Furthermore, we retain the visual state of the comparison toolbar, indicating whether it is 'open', 'closed', or 'minimized', to maintain your preferences for future visits.
Changes to this Privacy Policy
Game Lounge maintains the right to modify the privacy policy at any time. We advise you to regularly check this page for updates and refer to the last amendment date. If any changes affect activities conducted based on User consent, we will seek renewed consent from the User where necessary.