Effective date: 23/07/2018
1. Who are we? We are LIGHTBULB CREW SAS, a company incorporated under the laws of France, with its registered office at 14 rue Vauvenargues, Paris 75018, France; under the Registration Number: 791919376, VAT Number: FR93791919376; duly represented by Anders Larsson – CEO and founder.
2. Our values and what this policy is for:
We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.
3. We use the data according to the GDPR principles:
- Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.
- Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.
- Transparency. The Data Subject must be informed of how his/her data is being collected, processed and used
4. What personal data do we collect and process:
Lightbulb Crew SAS collects several different types of personal data for various purposes. Personal Data may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
You can read more in section A.
5. Who this policy applies to: This policy applies to users of our games,subscribers to our newsletter and people who contact our customer support function.
6. What this policy contains.
A. Collection of your personal information;
B. how we use it;
C. Legal basis for using your personal information;
D. Third Party Advertising, how and why we share your personal information with others?
E. Retention of personal data;
F. Your rights;
H.International Transfer of data/your personal information;
I. Risks and how we keep your personal information secure;
K. Consent and withdrawal of consent, further questions and how to make a complaint;
7. Your rights to object: You have various rights in respect of our use of your personal information, as set out in sectionE. Two of the fundamental rights to be aware of are that:
a) You may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
b) You may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s legitimate interest.
You can find out more information in section F.
- Our Company:
Further in the text, the term “Our Company” refers to Lightbulb Crew SAS, a company incorporated under the laws of France, with its registered office at 14 rue Vauvenargues, Paris 75018, France; under the Registration Number: 791919376, VAT Number: FR93791919376; duly represented by Anders Larsson – CEO and founder.
General Data Protection Regulation Act
- Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed
- Data Processor
Data Processor means any natural or legal person who processes the data on behalf of the Data Controller
- Data Subject
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
- Third Party Advertising & Partners
A list of the third–party partners for advertising and technology companies that we use and may have access to your data.
- Your consent
Your confirmation that you have read this document and agree to all outlined in it. You can read more about your rights in Section F and your consent/withdrawal in section K.
a) Whatd ata/personal information does our company collect about you?
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Data about your device type and model, including the IP address, operating system, OS version and platform
- Data generated when you play our games, such as the game version you are playing, your high score, game progress (for example level attained), log-in method and rankings
- If you participate in any chat activity on our apps, we will collect your handle and any data that you share within your messages posted to that forum
- Data relating to your game play history on our games
- The number of times you have accessed a game via the relevant platform from a particular device and for how long
- Data related to your request for our customer support
b) How do we use this data/your personal information?
b1: General uses
- To provide you with services
- To notify you about changes to our services and/or products
- To gather analysis or valuable information so that we can improve our services
- To detect, prevent and address technical issues
- For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so
- To improve the general user experience
b2: Customer-service related uses
- To provide customer support
- To process any refunds requested by you
- To deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes
b3: Game related uses
- To keep our platform and games secure
- In order to restrict access to harmful, infringing or illegal chat content
- To provide our games to you, and to allow you to access and use them so that you can play our games
- To recognize you when you return to our games, keep your game progress and to store information about your use of our apps (for example the level you have attained on a particular game)
- To evaluate your use of our games and compile statistics to understand the type of people who use our services, who play our games and how they use them. Such details will be anonymized as far as reasonably possible and you will not be identifiable by name from the information collected
- To display your achievements on leader boards within the relevant platform
- To send you push notifications with app-related information for certain of our apps (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting)
- To optimize user experience, for example to ensure we have sufficient technical capacity to support the anticipated volume of players or fixing problems with our games
b4: Marketing and Advertising related uses
- To help us manage and provide you with advertising and marketing that is relevant to you via our platforms, both from us and from our third-party partners, as further described in the section D: “Third Party Advertising, how and why we share your personal information with others?”
- To record your preferences in relation to advertising and marketing communications and send you newsletter with the newest information about our products.
- To send you automation marketing campaigns to enrich our understanding and knowledge of your customer needs
- To send you surveys to understand your behavior and enhance our games and services.
b5: Legal purpose
- To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so
- To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
- You can read more about the legal basis in section C
- We will not use your personal information in any way that is incompatible with the purposes set out in this section B. Please contact us using the details in section K: “Further questions and how to make a complaint” if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.
c) Legal basis for using your personal information
Our company’s legal basis for collecting and using the personal data described in this Data Protection Policy depends on the personal data we collect and the specific context in which we collect the information:
- Lightbulb Crew SAS needs to perform a contract with you in relation to customer support, marketing, advertising or communication.
- You have given Lightbulb Crew SAS permission to do so
- Processing your personal data is in Lightbulb Crew SAS legitimate interests which are:
– run, grow and develop our business (as well as the businesses of our group companies) including funding our business by use of advertising revenues
– operate, maintain and improve our games and our marketing optimization efforts
– understand the way in which our games and services are used
– for internal group administrative purposes.
- Lightbulb Crew SAS needs to comply with the law
- Our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our games)
- In case we share your personal information with others for purposes of legitimate interest of marketing and advertising, please read section D: “Third Party Advertising, how and why we share your personal information with others?” for more information
- You can control and withdraw your consent at any time on our apps/websites.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section K.
D) Third Party Advertising, how and why we share your personal information with others?
d1: What do we mean under “Third Party Advertising”?
We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. To achieve this, we use third-party advertising and technology companies to serve advertising and/or provide aggregated data to assist in serving advertising when you visit our platforms or use our games.
This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our services and games. We also use these companies to automatically collect data from you when you use our services and games in order to help us identify the advertising that are served to you and what you do after seeing advertising elements.
A list of the third–party partners for advertising and technology companies that we use is set, and may have access to your data is outlined below:
- Google LLC (Google Analytics, Google Ads, Google Shopping, YouTube) -Facebook Inc. (Facebook Ads, Instagram)
- Advance Publications Inc. (Reddit), Twitter Inc., Discord Inc., Amazon.com Inc. (Twitch)
- Meltwater Group, Zandesk Inc., Mailchimp, Greenlink Group
- Valve Corporation (Steam)
- Luden Labs (Steam Data Suite)
- LBC Games Publishing
- In case of acquiring a new publisher contract, the Publishing company we legally hold contract to collaborate with has access to your data we collect and the information you share with us by approving your consent to this policy.
- Adjust GmbH, who we use to analyze your use of the apps and help detect fraudulent marketing activity;
- The OS providers of your device, or the providers of the platform from which you downloaded our app(s), in order to verify purchases you make and provide in-app purchase opportunities
- Game Sparks Technologies Limited, who provide you with a method to save your progress in our apps, and provide our apps with multiplayer functionality
- In case of acquiring a new publisher contract, the Publishing company we sign the contract with has access to our data and your information you share with us by approving your consent to this policy.
d2: How and why do we share your personal data with Third Parties, how is it used?
These third-party advertising companies collect, store and use data by integrating cookies and other tracking software on our services. The relevant data collected by these third parties includes:
- Data about your device, location and use of our services, including IP address, a unique device ID, geo-location details and your User ID that we have assigned to you
- Data which you provide to us when using our apps or websites, including information on your interaction with advertising, game progress and certain technical information.
- These third-party advertising companies will collect and use your data to provide you with targeted advertising that is relevant to you and your preferences with your consent. You can control and withdraw your consent if you do not wish that we share the data we gather with third parties for the use of this targeted advertising at any time on our apps/websites. If you do not provide or withdraw your consent to receive targeted advertising that is relevant to you and your preferences, then we will still serve you advertising when you visit or use our apps/websites, but this will no longer be tailored to you or your preferences.
- In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
- As outlined before under the list of Third Parties, we might also share your data with social media or other similar platforms, as well as our advertising and communication partners, so that you and other people can see relevant advertising on that platform. For example, we may use the Facebook Custom Audiences service and share your IDFA with Facebook so that we can: serve relevant advertising to you or include you in a custom audience that we will serve relevant advertising to you on Facebook; or create an audience of other Facebook users based on the information in your Facebook profile. You can opt-out from Facebook Custom Audiences in your Facebook privacy settings, for example, and other similar platforms may have equivalent opt-out settings.
- We may also disclose and use anonymized, aggregated reporting and statistics about users of our services and games for the purpose of internal reporting or reporting to our group or other third parties. None of these anonymized, aggregated reports or statistics will enable our users to be personally identified.
We may share your personal information with our group companies where it is in our legitimate interests to do so:
- To enable them to provide customer support to you
- For internal administrative and management purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
- In case it is in our legitimate interests to do so to run, grow and develop our business
- If we or any of our group companies sell or buy any business or assets (or propose to do so), or we or any of our group companies are or may be acquired, we or our group companies may disclose your personal information to the prospective seller or buyer of such business or assets and to their legal, financial and other professional advisers, and that personal information may be one of the transferred assets; and
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to establish, exercise, enforce, or defend our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity
- To protect the rights, property, or safety of LIGHTBULB CREW SAS, our staff, our customers or other persons.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so by referring to section K.
E) Retention of personal data
- Our company will retain your personal information only for as long as is necessary for the purposes set out in this Data Protection Policy.
- Our Company will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
F) Your rights
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org or refer to Section K of this document.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you
- The right to ask for a copy of your personal information
- The right to ask for a confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA“).
- The right of rectification
- The right to object
- The right of restriction of your information
- The right to withdraw consent
- The right to data portability, to ask us to provide your personal information to a third-party provider of services. This right only applies where we use your personal information based on your consent or performance of a contract; and where our use of your information is carried out by automated means.
If you would like to have any further information on these rights or you would like to exercise any of them, please use the contact in Section K to get in touch with us.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If such exceptions apply, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
- You must be aged 16 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.
- If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
Please contact us at email@example.com if you are aware that we may have inadvertently collected personal information from a child below the age of 16.
H) International Transfer of data/your personal information
- Your personal information will be used, stored and/or accessed by staff operating in and outside the EEA working for us, other members of our group or suppliers, including those located (countries) Further details on to whom your personal information may be disclosed are set out in section D.
- When we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately. These measures may include the following, as permitted in Articles 45 and 46 of the General Data Protection Regulation: (http://www.privacy-regulation.eu/en/article-45-transfers-on-the-basis-of-an-adequacy-decision-GDPR.htm ; http://www.privacy-regulation.eu/en/article-46-transfers-subject-to-appropriate-safeguards-GDPR.htm )
H1: in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see https://www.privacyshield.gov/welcome)
H2: entering into European Commission approved standard contractual arrangements with them.
I) Risks and how we keep your personal information secure
I1: The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
- We are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organizational and technical measures.
- We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you.
- For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorization.
- We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
- Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our games or customer services function and that any such transmission is at your own risk.
- Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.
K) Consent and withdrawal of consent, further questions and how to make a complaint
- Under section F: “Your Rights”, you can see all your rights including the right to withdraw your consent for our use of any data regarding You. To do so, please use the details outlined below to contact us or use the “Unsubscribe” button at the bottom of the email received through our Newsletter.
- If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact firstname.lastname@example.org. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
- In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached. (http://www.privacy-regulation.eu/en/article-77-right-to-lodge-a-complaint-with-a-supervisory-authority-GDPR.htm )