BLACKOUT LAB SL PRIVACY

POLICY

(A) Who we are: We are Blackout Lab SL, an

entertainment company delivering games for mobile
devices. If you need it, our registered office is Ronda
Sant Pere, 33 Ppal. 3ª y 4ª, 08010 Barcelona, Spain.
Blackout Lab SL is the controller of your personal
information, and is responsible for your personal
information. All references in this policy to "Blackout
Lab", "our", "us" or "we" refer to Blackout Lab SL, or our
group companies, as appropriate. All references in this
policy to "apps" are to our apps that are available to
download on mobile devices from time to time.

(B) 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.

In line with these values, this privacy policy tells you

what to expect when we collect and use personal
information about you. We have tried to make it easy for
you to navigate so you can find the information that is
most relevant to you and our relationship with you.

We are always looking to improve the information we

provide to our customers and contacts, so if you have
any feedback on this privacy policy, please let us know
using our contact details in section 10.

(C) Who this policy applies to: This policy applies to

users of our apps and people who contact our customer
support function.

(D) What this policy contains: This privacy policy

describes the following important topics relating to your
information (you can click on the links to find out more):
1. Collection of your personal information and how
we use it:
2. Our legal basis for using your personal
information;
3. How and why we share your personal
information with others;
4. How long we store your personal information;
5. Your rights;
6. Children;
7. Where we may transfer your personal
information;
8. Risks and how we keep your personal
information secure;
9. Changes to this privacy policy; and
10.Further questions and how to make a complaint.

(E) Your rights to object: You have various rights in

respect of our use of your personal information, as set
out in section 5. Two of the fundamental rights to be
aware of are that:
1. 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.
2. 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 5.

(F) What you need to do and your confirmation to

us: Please read this privacy policy carefully to
understand how we handle your personal information.
By engaging with us in the ways set out in this privacy
policy, including downloading and using any of our
apps, you confirm that you have read and understood
the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be

aware of

1. Collection of your
personal information
and how we use it
1.1 What personal information we collect about you
(a) Our apps collect the following information about
you (and we use the information in the ways explained
below):
(i) if you agree to receive personalized ads,
data about your general location and the Identifier for
Advertising (IDFA) of the device;
(ii) 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 chat;
(iii) if you choose to use the Facebook
connection functionality and depending on your
Facebook privacy settings, your basic Facebook profile
information.
(b) If you contact our customer support function, we
will collect your e-mail address (as well as any other
information you include in your correspondence with
us), including any updates to any of that information.

1.2 How we use your personal information

We will collect, use and store the personal information
listed above for the following reasons:
(a) to help us manage advertising and provide you
with advertising and marketing via our apps that is
relevant to you, both from us and from our third party
partners, as further described in the 'Third party
advertising' section below;
(b) to record your preferences in relation to
advertising and marketing communications; and
(c) to receive and respond to customer support
enquiries we receive from you.

1.3 Other uses of your personal information

(a) We also collect, use and store your personal
information for the following additional reasons:
(i) 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;
(ii) 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;
(iii) 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; and
(iv) 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.
(b) We will not use your personal information in any
way that is incompatible with the purposes set out in
this section 1. Please contact us using the details in
section 10 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.

2. Legal basis for

use of your personal
information
2.1 We consider that the legal bases for using your
personal information as set out in this privacy
policy are as follows:
(a) 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 apps); or
(b) you have provided us with your consent to do
so. This applies in relation to the advertising and
marketing materials delivered via our apps that are
tailored to you and your preferences. You can control
and withdraw your consent at any time on our apps.
(c) where (a) or (b) does not apply, our use of your
personal information is necessary for our legitimate
interests or the legitimate interests of others. Our
legitimate interests are to:
(i) run, grow and develop our business (as well
as the businesses of our group companies) including
funding our business by use of advertising revenues;
(ii) and operate, maintain and improve our apps
and our marketing optimisation efforts;

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 10.

3. How and why we

share your personal
information with
others
Third party advertising

3.1 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 or use our apps. 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 apps. We also use these companies to
automatically collect data from you when you use our
apps in order to help us identify the advertising that are
served to you and what you do after seeing those
advertising. In addition, we share data with providers of
analytics tools, such as Adjust, which we use to analyse
your use of the apps. A list of the third party advertising
and technology companies that we use is set out below.
(a) Admob, Inc.
(b) AppLovin Limited
(c) Facebook, Inc.
(d) Unity Ads (Unity Technologies Finland Oy)
(e) Vungle, Inc.

3.2 These third party advertising companies collect,

store and use data by integrating cookies and other
tracking software on our apps. The relevant data
collected by these third parties includes:
(a) data about your device, location and use of our
apps, including IP address, a unique device ID, geo-
location details and your User ID that we have assigned
to you;
(b) data which you provide to us when using our
apps, including information on your interaction with
advertising and certain technical information.

3.3 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 to this targeted advertising at any time on our
apps. 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 but this will no longer be
tailored to you or your preferences.

3.4 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.

3.5 We might also share your data with social media or

other similar platforms, as well as our advertising
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.

Other third parties

3.6 We will share your personal information with the

following third parties or categories of third parties:
(a) Amazon Web Services, who store all our data
and may access personal data stored within that
storage solution when providing support and
maintenance purposes;
(b) 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. This includes
Google, Amazon and Apple;
(c) Google, Inc. (trading as Firebase), who provide
analytics of bugs and issues with our apps, so that we
can fix, stabilise and improve our apps;

3.7 We may share your personal information with our

group companies where it is in our legitimate interests
to do so:
(a) to enable them to provide customer support to
you; or
(b) for internal administrative and management
purposes (for example, for corporate strategy,
compliance, auditing and monitoring, research and
development and quality assurance).

3.8 We will also disclose your personal information to

third parties:
(a) where it is in our legitimate interests to do so to
run, grow and develop our business:
(b) 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
(c) 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;
(d) 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; or
(e) to protect the rights, property, or safety of
Blackout Lab SL, our staff, our customers or other
persons.

3.9 We may also disclose and use anonymised,

aggregated reporting and statistics about users of our
apps for the purpose of internal reporting or reporting to
our group or other third parties. None of these
anonymised, aggregated reports or statistics will enable
our users to be personally identified.

3.10 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.

4. How long we
store your personal
information
We keep your personal information for no longer than
necessary for the purposes for which the personal
information is processed. The length of time for which
we retain personal information depends on the
purposes for which we collect and use it and/or as
required to comply with applicable laws and to
establish, exercise or defend our legal rights.

5. Your rights
5.1 You have certain rights in relation to your personal
information. If you would like further information in
relation to these or would like to exercise any of them,
please contact us via email at
blackout.barcelona@gmail.com at any time. You have
the following rights:
(a) Right of access. You have a right of access to
any personal information we hold about you. You can
ask us for a copy of your personal information;
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"). You can make such a request
via the "Show my data" button in the settings menu of
our apps.
(b) Right to update your information. You have a
right to request an update to any of your personal
information which is out of date or incorrect.
(c) Right to delete your information. You have a
right to ask us to delete any personal information which
we are holding about you in certain specific
circumstances. You can ask us for further information
on these specific circumstances by contacting us using
the details in section 10. If you are entitled to deletion of
your personal data, you can make such a request via
the "Delete my data" button in the settings menu of our
apps.

We will pass your request onto other recipients of your

personal information unless that is impossible or
involves disproportionate effort. You can ask us who the
recipients are, using the contact details in section 10.
(d) Right to restrict use of your information. You
have a right to ask us to restrict the way that we
process your personal information in certain specific
circumstances. You can ask us for further information
on these specific circumstances by contacting us using
the details in section 10.

We will pass your request onto other recipients of your

personal information unless that is impossible or
involves disproportionate effort. You can ask us who the
recipients are using the contact details in section 12.
(e) Right to data portability. You have a right 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 on the basis of your consent or performance
of a contract; and where our use of your information is
carried out by automated means.
(f) Right to object. You have a right to 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.

5.2 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.

5.3 If an exception applies, 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.

6. Children
6.1 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.

6.2 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.

6.3 Please contact us at

blackout.barcelona@gmail.com if you are aware that we
may have inadvertently collected personal information
from a child below the age of 16.

7. Where we may
transfer your
personal information
7.1. Your personal information will be used, stored
and/or accessed by staff operating outside the EEA
working for us, other members of our group or
suppliers, including those located in the United States of
America. Further details on to whom your personal
information may be disclosed are set out in section 3.

7.2 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:
(a) 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); or
(b) entering into European Commission approved
standard contractual arrangements with them.

7.3 Further details on the steps we take to protect your

personal information, in these cases is available from us
on request by contacting us via the e-mail address set
out in section 10.

8. Risks and how we

keep your personal
information secure
8.1 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.

8.2 For this reason, 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 organisational 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 authorisation. We also strive to limit access
to your data to employees performing a legitimate
business function which requires them to access and
use your data in order to supply you with our apps. We
review our security procedures periodically to consider
appropriate new technology and updated methods to
ensure we continue to protect your data.

8.3 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 apps 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
unauthorised access to it.

9. Changes to our
privacy policy
We may update our privacy policy from time to time.
Any changes we make to our privacy policy in the future
will be made available to you via the privacy policy,
accessible in our app. Please check back frequently to
see any updates or changes to our privacy policy.

10. Further
questions and how
to make a complaint
10.1 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
blackout.barcelona@gmail.com. We will investigate and
attempt to resolve any such complaint or dispute
regarding the use or disclosure of your personal
information.

10.2 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.

The practices described in this privacy policy statement

are current as of 25 May 2018.

Privacy Policy
Support
Terms of Service
© Blackout Lab 2024. All rights reserved.