Privacy Policy

1. BASIC INFORMATION ON DATA PROTECTION

Tangelo Games Spain SLU, Calle Amigó nº 11, primera planta, 08021 Barcelona, with Tax ID (NIF) B65596744 (hereinafter, the “Controller”) informs you about its privacy policy (hereinafter, the “Privacy Policy”) regarding the processing and protection of the personal data of users (hereinafter, “Users”) that may be collected through browsing its website (hereinafter, the “Website”).

In this regard, the Controller guarantees compliance with the applicable personal data protection legislation, namely Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and, with regard to the use of cookies, Spanish Law 34/2002, of 11 July, on information society services and electronic commerce (LSSI).

• CONTROLLER: Tangelo Games Spain SLU, Calle Amigó nº 11, primera planta, 08021 Barcelona, with Tax ID (NIF) B65596744 or the Controller.
• PURPOSE: To ensure the security and proper functioning of the Website, to manage the User’s preferences regarding the installation of cookies and to respond to enquiries sent to our contact email address.
• LEGAL BASIS: Legitimate interest and compliance with the Controller’s legal obligations, and consent.
• RECIPIENTS: Service providers acting as data processors and, if you accept the relevant cookies, Google as the third party owning those cookies. No data will be disclosed to other third parties, except where legally required.
• RIGHTS: Access, Rectification, Objection, Erasure, Restriction of Processing and Portability of Personal Data.

You may exercise the rights set out in this Privacy Policy at any time.

This document will help you understand:

1. Basic information on data protection
2. Who are we?
3. Our principles
4. What information do we collect? For what purposes do we process your personal data? The legal basis on which we process your data
5. Whether we transfer or disclose your data to third parties
6. How we store and secure this information
7. How long we keep your data
8. Your rights
9. Updates to the privacy policy

This Privacy Policy covers the information we collect from you when you browse our Website (please see the Cookie Policy if you wish to know more about this point).

2. WHO ARE WE?

The controller of your personal data is: Tangelo Games Spain SLU, a Spanish company with registered office at Calle Amigó nº 11, primera planta, 08021 Barcelona, and Tax ID (NIF) B65596744.

3. OUR PRINCIPLES

With regard to the processing of your personal data, the Controller will apply the following principles in accordance with the GDPR:

• Principle of lawfulness, fairness and transparency: the Controller will process your personal data lawfully, fairly and transparently, for one or more specific purposes of which you will be informed in advance.
• Principle of data minimisation: the Controller will only request the data strictly necessary for the stated purpose or purposes.
• Principle of storage limitation: data will be kept for as long as strictly necessary for the purpose or purposes of the processing.
  The Controller will inform you of the applicable retention period according to the purpose.
• Principle of integrity and confidentiality: your data will be processed in such a way as to guarantee its security, confidentiality and integrity. Please note that the Controller takes the necessary precautions to prevent unauthorised access to, or misuse of, its users’ data by third parties.

4. WHAT INFORMATION DO WE COLLECT ABOUT YOU? PURPOSE OF THE PROCESSING AND LEGAL BASIS

When you browse the Website, the Controller may process personal information for which it is responsible.

The data collected are as follows:

• Technical and browsing data, such as the IP address.
• Data obtained through cookies, as described in the Cookie Policy.

The Controller processes your personal data for the following purposes:

• To ensure the security and proper functioning of the Website. In this case, the legal basis for the processing is the Controller’s legitimate interest.

• To manage your cookie consent preferences. In this case, the legal basis for the processing is compliance with a legal obligation.
• To respond to enquiries you send us through the email address published on the Website. In this case, the legal basis for the processing is the Controller’s legitimate interest in responding to the communications it receives or, where the enquiry relates to a possible contractual relationship, the implementation of pre-contractual measures taken at your request.
• To manage the Controller’s presence on social media. If you follow the Controller on social media, the processing of personal data will be governed by this section, as well as by the terms of use, privacy policies and access rules of the relevant social network, which you have previously accepted. The legal basis for the processing is your consent, given by following or interacting with the Controller’s profile, which you may withdraw at any time by unfollowing it.
• To install non-essential cookies, where you have accepted them. In this case, the legal basis for the processing is your consent, which you may withdraw at any time through the cookie settings panel.

Under no circumstances will the Controller use the profiles of social media followers to send individual advertising. Advertising will in any case only be sent after obtaining your explicit consent.

5. TRANSFER AND DISCLOSURE OF DATA TO THIRD PARTIES

The Controller will not transfer your personal data to third parties, except in the cases indicated in this section or where required by a legal obligation or a court order.

However, for the proper provision of the services, we use third-party providers who will act as Data Processors. These providers will only access your personal data to fulfil the specific purposes for which they have been engaged, always acting under our instructions and having entered into a data processing agreement that guarantees compliance with the applicable legislation.

These processors fall into the following categories:

• Web hosting and technology service providers.
• Cookie consent management providers.

Any subcontracting by our processors will require our prior written authorisation, ensuring that sub-processors are subject to the same data protection obligations as the main processor.

Some of the cookies used on the Website are third-party cookies (such as Google’s), which process the information obtained as independent controllers, in accordance with their own privacy policy (policies.google.com/privacy). If you accept the relevant cookies, the information obtained through the third-party cookies used on the Website will be disclosed to that third party.

Some of these third parties or providers may be located outside the European Economic Area, in particular in the United States. In such cases, international data transfers will be carried out with the appropriate safeguards provided for in the GDPR, such as adequacy decisions of the European Commission (including Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 on the EU-U.S. Data Privacy Framework) or the standard contractual clauses approved by the European Commission.

6. HOW WE STORE AND SECURE THE INFORMATION

We implement effective technical and organisational security measures designed to protect your data and information. These measures are reviewed periodically to ensure a level of security appropriate to the risk. In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

7. RETENTION OF YOUR DATA

The personal data provided will be kept for as long as necessary to fulfil the purpose for which they were collected and to determine any liabilities that may arise from that purpose, in addition to the periods established in the legislation on archives and documentation. Data obtained through cookies will be kept for the periods indicated in the Cookie Policy.

In particular, technical and browsing data (including the IP address) recorded for security purposes will be kept for a maximum of 90 days from the date they are recorded, unless they are needed to investigate a security incident, in which case they will be kept for as long as the investigation lasts. Likewise, data from enquiries received by email will be kept for as long as necessary to respond to them and, thereafter, for a maximum of 12 months.

Once these periods have elapsed, the data will remain blocked for the limitation period of any liabilities arising from the processing, in accordance with Article 32 of the LOPD, and will then be deleted.

8. YOUR RIGHTS

You may exercise your rights of access, rectification, erasure and portability of your data, restriction of and objection to its processing, as well as the right not to be subject to decisions based solely on automated processing of your data, by contacting our DPO (Data Protection Officer) at the following email address: dpd@tangelogames.com, specifying which right or rights you wish to exercise. You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos), C/Jorge Juan, 6, 28001 Madrid, or at the email address dpd@aepd.es.

Where the processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

In order to comply with the principles of information and transparency, basic information on the rights provided for in the GDPR is briefly set out below:

9. UPDATES TO THE PRIVACY POLICY

We may change this Privacy Policy from time to time to reflect new services, changes in our personal data practices or in the applicable laws. The “Last updated” notice at the top of this Privacy Policy indicates when it was last revised. All changes will take effect when we publish the revised Privacy Policy. We may provide you with information and alerts regarding the Privacy Policy or the personal data collected by means of publications on our Website.