Privacy terms

(Effective August 24TH, 2023)

Table of Contents

Introduction
The Spelletjes.com website
Data Controller
Our Legal Framework
General Information
Customer Support
Personal Data Collection
Activity
How we use your Information and Legal Basis
Our Data Processing Activites
Third Parties we use
Data Retention
Data Security
Your Privacy Choices
European Economic Area Users
United Kingdom Brexit Notice
United State California Notice of Collection
Commitment
Business Transfers
Which cookies are used?
Contact Us

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY

Introduction

Thank you for choosing the Spelletjes.com site accessible at or https://www.spelletjes.com (the "Site"), operated by Rovers Webdevelopment. When this Policy mentions Spelletjes.com or Rovers Webdevelopment, it refers to “we”, “us”, or “our”, and we will be acting as your Data Controller.

We require every user on our site to be at least 13 years of age and, if you are under 18, you agree to use the service only with the permission and supervision of your parent or legal guardian.

Our privacy promises:

We value your privacy & data security
We do not use your data for commercial purpose
We comply with the GDPR
We will never sell your data
You control your data.

After that, you’re all set to use our Service. By accessing the website, you hereby consent to our Privacy Policy and agree to the terms described herein. Please notice that this Privacy Policy and Cookie Policy only applies to the above-mentioned Services.

For Spelletjes.com processing of your personal data in our games, please review the applicable privacy policy which can be found the Spelletjes.com website. We reserve the right to change this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and re-post the policy in the "Privacy" section of our website. Depending on the specific changes, we will provide you with additional notice or require a renewed consent.

Please review this Privacy Policy and Cookie Policy from time to time in order to stay informed about how we process your personal data and use cookies

Data Controller

Spelletjes.com, a company duly incorporated under the Netherland Laws, bearing Chamber of commerce number: {17155973}, with registered address at Vliegerthof 2, Postal Code: 5424 VZ, City: Elsendorp and Country: Netherland (hereinafter “Spelletjes.com”, “Rovers Webdevelopment”, “us”, “we”, or “our”), is responsible for the collection of personal data via the site https://www.spelletjes.com/, (“our site”).

When this Policy mentions Spelletjes.com it refers to your Data Controller. You can always contact us if you have questions about the processing of your personal data, or if you have any requests in regard to your rights under the General Data Protection Regulation ("GDPR"). We encourage you to primarily contact us through Customer Support (paul@rovers.nl), where you will get the fastest response

Our data privacy officer may also be contacted at paul@rovers.nl

Our Legal Framework

This policy has been drafted on the basis of the Netherland laws and guidance that seeks to protect children, including but not limited to:

The Children Act 1989 and 2004
The Data Protection Act 2018
The United Convention of the Rights of the Child 1991
The Protection of Freedoms Act 2012
The Sexual Offences Act 2003
All relevant governmental guidance on safeguarding children
All relevant Netherland laws.

We recognise that, the welfare of a child is important in today’s society, as provided in the Children Act 1989 and 2004. All children, regardless of their age, gender, disability, religious belief, racial heritage, sexual orientation or identity, have a right to equal protection from all types of child harm or abuse.

General Information

The terms “We”, “Us”,” Our” mean Spelletjes.com. The terms “You” and “Your” refer to You, as a user, or visitor of our website provided Services. The term “personal data” refers to all information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person, as set out in the GDPR. In addition, personal data comprises data of legal persons.

The Spelletjes.com website

To access and use the Spelletjes.com platform is free, however, to save your favorite game, you will be required to register an account with the platform, in such cases, we will request that you provide us important information about yourself, i.e, email address, date of birth etc. If you choose not to share certain information with us, we may not be able to offer you our Service. Any information you provide to us that is not required is voluntary.

We use technologies such as cookies and web beacons for specific purposes: such as to understand how you interact with our platform and services, and to provide a better experience.

Customer Support

Spelletjes.com collects information you voluntarily submit when using our Customer Support. The type of processed data, the purpose and legal basis for the processing When engaging with our Customer Support, we may ask you to provide general personal information voluntarily in order to respond to your inquiry. This information may include your name, email address, contact details, payment related information), device ID and the nature of your request or communication. We request that you do not provide sensitive information (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a person’s sex life or sexual orientation), or personal identification numbers. Such data will immediately be deleted.

We collect this information in order to better assist you with any issues you might encounter with our products. We reserve the right to use this information in any manner permitted by law, to respond to Your communication. The processing of your personal data for feedback or customer support processing is based on Art. 6, para. 1, d) or f) of the GDPR. Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services by providing Customer Support, see Article 6(1)(b) of the GDPR.

We will not disclose your personal data to third parties, but we may use data processors who process personal data on our behalf.

Personal Data Collection

We take processing of your personal data very seriously. We ensure a reasonable and transparent processing in accordance with the rules on processing of personal data. For the purpose of clarity, we have separated the description of our processing activities into different categories.

You agree to provide only true and correct information about yourself. When you use and interact with our services. We may collect, and use some personal identifiable data ("Personal Data") such as;

Personal Information: Such as your email address, date of birth, or unique online identifier, or similar identifier.
Your Usage Data. We may automatically collect certain details of your access to and use of the site, including traffic data, logs and other communication data and the resources that you access and use on or through the site.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the platform and website.
Usage Data includes data about how you use our website, products and services.

These personal data is neccessay to provide a better experience of our products and services. We only store your information for up to 6 months after which we will delete or anonymize it

Activity

When You use the platform, We receive and store certain information which may include Your Personal Information and anonymous information, regarding Your use of the Services. We also collect data around usage of the Services such as a user activities, their performance on games and activities, in order to send you reports and recommend the most appropriate games and activities.

If you do not want us to collect these information, you can request to remove it by sending us a message via our email, or use the contact us option on the site.

How we use your Information and Legal Basis

Any processing of data requires a legal basis. If the processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the request of the data subject, the processing may be based on Art. 6, para. 1, b) of the GDPR.

Our processing of personal data is necessary to safeguard our legitimate interests as a data controller. We process and use the information we collect in various ways, in addition, We may also collect, hold and use your personal information for:

Providing our service. We use your information to provide and maintain our Services, to process and fulfill your requests or orders, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service and business administration purposes.
To Improve Our Services. We use your information to understand and analyze our user base and how you use the Services, to improve and enhance the Services, and to develop new products, services, features and functionality.
Communication: we use your information to send you offers and other communications such as product updates, notices, support, and administrative communication that may be of interest to you,
Data Security and fraud prevention: we use your data to protect our website user data and our server from malicious or dangerous activity;
Investigation: Prevent and investigate unauthorised access to the Services, including other illegal activities;
Legal Obligation; Comply with specific legal obligations, and enforcing our agreements.

We also process data that cannot be assigned to any person. These are data that do not personally identify you, including anonymous information and aggregated data. This information helps us better understand how our visitors use the Services, analyze demographics, interests and behaviors of our visitors, improve the Services, provide customized services and information to visitors, and similar purposes. You hold the right to opt out of receiving any of these communications as described under "Your Privacy Choices" section below.

Our Data Processing Activites

DATA PROCESSING	LEGAL BASIS
Providing services. We need to provide services via the Website	Contract
Providing newsletters/offers/updates which may be interesting to you	Legitimate Interests
Registering you as a user	contract
Compliance with applicable anti-money laundering and know your client rule	Legal obligation
Keeping the Website running (managing your requests, remembering your settings, hosting, and back-end infrastructure)	Legitimate Interests
Preventing frauds, illegal activity, or any violation of the terms or Privacy Policy. We may disable access to the Website, erase or correct personal data in some cases	Legitimate Interests
Improving the Website (testing features, interacting with feedback platforms, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this)	Legitimate Interests
Customer support (notifying you of any changes to the Website, services, solving issues, any bug fixing)	Legitimate Interests

Third Parties we use

We use the information that we collect from our users in a number of ways: for instance we will use your email address and date of birth details to save your favorite game, register you on the platform and improve our services. Below are information about the third-parties we may share or use your information to operate our platform:

Advertising partners. We may include an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads within the website, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities. For more information on how to limit or opt-out from personalized advertisement.
Cloud service providers who rely on for data storage, i.e. Google Cloud (Google Web Server) and/or AWS (Amazon Web Server).
Analytics providers. We work with a number of analytic providers, segmentation and usage measurement services who help us understand our user-base. These includes Google Analytics, etc.
Google Analytics: This is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy
Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
Business transfer or Change of ownership. If we are involved in a merger, acquisition, bankruptcy, re-organisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

We will not share your data with any third parties for the purposes of direct marketing. We have contracts in-place with these thirdparties. This means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any organization apart from us. They will hold it securely and retain it for the period we instruct.

Data Retention

For the sake of the GDPR, we are entitled to keep your Personal data only for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to erase any Data that we hold from you, where:

we no longer need the Data for the purposes for which it was collected and we are not otherwise entitled to retain such data; and
we are not required or obligated by law, regulation or court order to retain the data.

If certain data has been provided to third parties in accordance with this Privacy policy, retention of that data will be subject to the policies of the relevant third party.

Data Security

We have put in place numerous technical, organizational and physical safeguards measures designed to protect the personal data of users. However, no online security measures are guaranteed. You agree that your use of The site is at your own risk

Your Privacy Choices

Under the General Data Protection Regulation {GDPR}, you are entitle to the choices below;

Exercise of Rights: You can exercise your rights as defined in GDPR, please send a request via e-mail paul@rovers.nl, to exercise your rights.
Revocation of Consent: You hold right to revoke your consent for processing of your data in the future at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation.
Right of Access: You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) request for more specific data on the Data.
Right to Rectification: You have the right to obtain from us the rectification of inaccurate Data concerning you. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification.
Right to Erasure: Should you decide that you do not want us to process your data any further, please send a request via e-mail to paul@rovers.nl. We will erase your Data immediately and inform you of this process. Should mandatory provisions of law prevent such erasure, we will inform you without undue delay thereof.
Right to Restriction of Processing: You have the right to obtain from us a restriction of processing of your Data;
Right to Data Portability: You have the right to (i) receive your Data in a structured, commonly used and machine-readable format and (ii) transmit those Data to another controller without hindrance from us.
Right to Object: You have the right to object at any time to the processing of Data.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, if you think that the processing of Data infringes applicable law, especially the GDPR")

Learn more about these rights, and find out how you can exercise your rights by sending us a message.

European Economic Area Users

If you are a resident of the European Union (“EU”), United Kingdom, Australia or Netherland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

Spelletjes.com will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers (e.g. educational institutions) , in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Please note that, we process your personal data in reliance on the legal bases below. Where the purpose of processing is:

To provide and improve our Services and the Site: We process your personal data as necessary to perform the contract under which we provide our Services to you or to allow you to access our Site.
To comply with the law: We process your personal data as necessary to comply with applicable laws and our legal obligations.
For compliance, fraud prevention, and safety: We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights. We also process your personal data as necessary to comply with our legal obligations.
To send marketing communications; or for research and analytics: We have a legitimate interest in processing your personal data, as described in this Privacy Policy, and our reasons for doing so outweigh any prejudice to your data protection rights.
With your consent: We process certain of your personal data with your consent. You may withdraw your consent at any time in the manner indicated when you provided consent to the collection of your personal data through your interactions with the Services or the Site.

United Kingdom Brexit Notice

Based on the agreement between the UK and the EU, until 2025 all the personal data transfers from the EU to the UK are not considered as transfers to a third country. For the transfer from the UK to the EU, UK finds this transfer as transfer with adequate protection, so currently there are no additional requirements needed for such personal data transfers.

United State California Notice of Collection

If you are a User in the United State, who In the past 12 months used the platform, we may have collected the following categories of personal information enumerated in the California Consumer Privacy Act (CCPA). We collect and use these categories of personal information for our business purposes described in the “Data Collection and Personal Information Use and legal basis” section, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Commitment

We take the responsibility to protect the security and privacy of our users seriously. We have established effective policies that define our commitment to data security and the information technology we manage. We are continually reviewing policies and procedures to assure that they are appropriate and effective in meeting our commitments to our community, our users, customers and ourselves. Any suspicious attempt to breach our terms and policies, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. All suspicious computer mischief will be reported to the appropriate authorities.

Business Transfers

In connection with, or during negotiations of, sale of company assets, any merger, financing, or acquisition of all or a portion of our business. We may share or transfer your data (including your personal data) for business transfer purposes. You will be notified via email and/or a prominent notice on the website of any change in ownership or related uses or disclosures of your data, as well as any choices you may have regarding your data in such circumstances.

Which cookies are used?

We use first party cookies from the website itself in order to facilitate and optimize the use of the website and for traffic measurement. These cookies are persistent cookies. We also use third party cookies belonging to Google Analytics and social networks in the form of Facebook, Twitter, Youtube, Google+, etc. The purpose is to guide the webpage visitor to social networks that have more information and videos regarding Spelletjes.com. These companies are based in the USA and in compliance with Privacy Shield.

How to delete and avoid cookies

You can always choose to opt-out of cookie or disable them entirely on your device via plugins or from your browser settings. Alternatively, you can set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use our Services.

It is also possible to deactivate cookie through a consent tool such as http://www.youronlinechoices.com/uk/your-ad-choices (serviced by EDAA).

Contact Us

We hope that we can satisfy any queries you may have about the way in which we process your personal information, so we encourage you to submit your claim to our Data Protection Officer at; paul@rovers.nl

However, if this does not satisfy you, you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.