The Stillfront Group respects your right to control your privacy. We have put in place security measures for your personal data and manage your personal data in accordance with applicable data protection and data privacy regulations. This Privacy Policy explains how we handle and treat your data when you (a) register or visit our site, www.stillfront.com or associated sites or pages (the ”Website”) or (ii) engage or communicate with us. It also provides information about your rights relating to your Personal Data.
Throughout this Privacy Policy the following terms have the following meanings:
”Data Privacy Laws” means applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (2016/679) (the ”GDPR”).
“Processing” and “Process” means all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
“Services“ means our applications and other products, the Website, email communications, social media accounts and any related services or properties we control.
“Personal Data” means Personal Data that relates to you as an identified or identifiable individual.
All capitalised terms not specifically defined herein shall have the meaning ascribed to such terms in the GDPR.
While operating the Services, we may share your Personal Data with partners we work with. Some of these partners are Controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 4 of this Privacy Policy. Further we may transfer your Personal Data to countries outside the European Economic Area. Such transfers will be done in accordance with section 5 of this Privacy Policy.
Our Services are not directed to children and we do not knowingly collect Personal Data from children under 16 years of age.
1. Who we are
Controller
The Controller responsible for your Personal Data for the purposes of the GDPR is:
Stillfront Group AB (publ)
Kungsgatan 38
111 35 Stockholm
Sweden
www.stillfront.com
hereinafter referred to as the “Company”, ”we”, ”us” or “our”.
The principles set out in this Privacy Policy apply to all instances in which the Company Processes your personal data as a Controller for the purposes described in this Privacy Policy. The Company is part of the Stillfront Group, a global group of gaming studios with its parent company, Stillfront Group AB (publ), incorporated in Sweden and listed on Nasdaq First North Premier Growth Market.
Data protection Officer
The data protection officer of the Controller for the purposes of the GDPR is:
Name: Peter Birgersson, Deloitte AB
Contact details: dpo@stillfront.com
2. What information do we collect from you?
| Source | The information collected includes the following data |
| Information you provide voluntarily when using our Services. | · Your name, email address, or other contact information communicated to us. |
| · Any Personal Data provided in any communication channel available in our Services. | |
| · If you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications. | |
| · If you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so. | |
| · Any other information you choose to submit to us through our Services or otherwise. | |
| Directly from you and/or your device by automatic means.
The Company collects Personal Data directly from you and/or your device (such as your phone or computer) by automatic means when you use our Services or interact with our ads outside of our Services on third-party websites or applications, including through cookies or similar technologies or software development kits (SDKs) For more information regarding the Company’s use of cookies, please view our cookie policy.
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· Your device and browser: Certain information is collected by most browsers or automatically through your device, such as your device type, model, manufacturer, operating system, language, display, processor, the Internet browser type you are using your IP address (including your coarse location). |
| · Your use of our Services: We may track and collect usage data, such as the date and time you access our Services, access status, duration of use of our Services, the site you visited, the information and files that have been downloaded. | |
| · Crash logs or other information related to bugs, errors, or other issues in our Services. | |
| · Inferences we make based on your activity in our Services. |
We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
3. How do we use your Personal Data?
We use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customize our Services to you, these include the following processing activities:
| Lawful basis | Purpose of the processing |
| To perform our contract with you in respect of our Services.
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· To enable you to use our Services and administer the Services. |
| · Providing, maintaining, enhancing and personalizing the Service(s) (including selecting an appropriate language version for you). | |
| · To know your preferences and to try to ensure that the content on our website is presented in the most effective manner for you and your computer or mobile device. | |
| · To send you newsletters or other similar communications if you have subscribed to them (for example, through a subscription form on our Websites) | |
| Based on our legitimate interest to make our Services the best they can be and provide you with the best possible user experience in our Services | · Operate and maintain our Services. |
| · Where available, provide social features or events in our Services or other Services. | |
| · Handle your support requests or otherwise manage our relationship with you. | |
| · Troubleshoot or debug any bugs, errors, or other issues in our Services. | |
| · Measure and analyse the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations). | |
| · Create data that is not identifiable to you (for example, aggregate data), which we may then use and share freely. | |
| · Improve our current Services or develop new Services. | |
| · Analysing how visitors use our Website. | |
| Based on our legitimate interest to safeguard our operations. | · Audit our operations or processes (for example, to verify that they function as intended). |
| Based on our legitimate interest to establish, exercise and defend legal claims. | · E.g. in the unlikely event of a dispute or a criminal investigation |
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
4. Who might we share your information with?
Your Personal Data may (for the purposes described in this Privacy Policy) be transferred or disclosed to third parties, for the processing of that Personal Data on our behalf, such as to:
- Other companies in the Stillfront Group, for example where they help us develop or operate our Services or other Services.
- Persons or companies that provide services to us and process data on our behalf when providing those services (for example, services that help us develop and operate our Services and professional advisors).
- Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers.
- Competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation.
- Any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests.
- Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.
Where required by law, your Personal Data may be disclosed to an applicable governmental, regulatory, sporting or enforcement authority. Your Personal Data may also be disclosed to any regulatory body in connection with prevention and detection of crime and where the Company considers that there are reasonable grounds to suspect that you may be involved in a breach of the law. Those bodies may then use your Personal Data to investigate and act on any such breaches in accordance with their procedures.
5. Appropriate Safeguards to countries outside the EU/EEA-area
In connection with the processing activities described in this Privacy Policy, your data may be transferred to and/or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies or the service providers we use to provide the Services may be located outside of the EU and the EEA. Where the Company transfers Personal Data outside the EU/EEA, The Company will ensure that Standard Contractual Clauses have been entered into between the transferring entity and the receiving external party. Alternatively, other safeguards will be put in place prior to such transfers. You are under Data Privacy Laws upon request entitled receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outside the EU/EEA. You can do so by reaching out to our Data Processing Officer dpo@stillfront.com.
6. How long do we keep hold of your information?
We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you; (ii) as required by legal obligations to which the Company is subject (such as tax and accounting obligations); and (iii) as advisable in light of our legal position (such as applicable statutes of limitations). For more specific information about data retention terms, please contact Our Data Processing Officer dpo@stillfront.com and we will provide the specific data retention terms for your jurisdiction.
7. Security
We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.
8. Your rights
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all the purposes described in this Privacy Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Services, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings.
In relation to our processing of your Personal Data you have, under certain circumstances, the right to exercise the following rights:
Access
You may request confirmation whether or not Personal Data is processed and, if that is the case, access to your Personal Data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal Data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
Object to certain processing
You may object to the processing of your Personal Data on the basis of a legitimate interest, on grounds relating to your particular situation and to the processing for direct marketing purposes.
To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.
Rectification
You have at any time the right to have inaccurate Personal Data rectified, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Data completed.
Erasure
You may have your Personal Data erased under certain circumstances such as when your Personal Data it is no longer needed for the purposes for which it was collected.
Restriction of processing
You may ask us to restrict the processing of your Personal Data to only comprise storage of your Personal Data under certain circumstances, such as when the processing is unlawful, but you do not wish your Personal Data erased.
Withdrawal of consent
You have the right to at any time withdraw your consent to processing of Personal Data to the extent the processing is based on your consent.
Data Portability
You may ask to receive a machine-readable copy of Personal Data processed and ask for the information to be transferred to another Controller (where possible). This only refers to such Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you and only to the extent the Personal Data have been provided to the Company by you (data portability).
Complaints to the supervisory authority
You have the right to lodge complaints pertaining to the processing of your Personal Data to the relevant data protection supervisory authority.
To access your data in our Services or to request its deletion, please use the automatic tools provided in our Services. These tools are specific to each of our Services. You will find them in the game settings under “Terms & Privacy” or a similarly named option. On the same page, you can also opt out of our personalized offers, where applicable. We ask you to primarily use these tools to submit requests, because that helps us validate, process, and fulfil your request more quickly and reliably.
If you have any questions about this Privacy Policy or our data collection practices, please contact us at the address or email set out under section 1 of this Privacy Policy and specify your country of residence and the nature of your question.
9. Changes to the terms of this Privacy Policy
We may update this Privacy Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.