Legal

1 Background

At Social First, accessible from www.socialfirst.com, one of our main priorities is the privacy of our players and website visitors. This privacy policy (“Privacy Policy”) contains types of personal data (“Personal Data”) that is collected and processed by Social First and how we use it. Personal data includes any information which may be used to identify an individual. Under GDPR Personal Data means any information relating to an identified or identifiable natural person.

Social First is the controller (“Controller”) of Personal Data if not mentioned otherwise.

It is important to us that you feel secure in the way we handle your Personal Data. We take steps to ensure that your Personal Data is protected and processed in accordance with applicable data protection legislation and our internal processes and practices. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

2 Personal Data sources

We collect your data primarily from yourself. We may also receive Personal Data from platform providers and our service providers.

3 How and why we process your Personal Data

We are processing your Personal Data for the following purposes:

Customer communication

We might collect the following groups of Personal Data in the context of communicating with our customers.

Registering for an Account and Account Management

We may collect the following groups of Personal Data in the context of customer registering for an account and managing accounts.

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Analytical tools

We may collect the following groups of Personal Data in the context of using analytics tools.

We use your Personal Data to

· provide, operate, and maintain our games, services and website

· improve, personalize, and expand our games, services and website

· understand and analyze how you use our games, services and website

· develop new products, services, features, and functionality

· communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes

· provide targeted advertising

· send you emails

· find and prevent fraud

We do not use your Personal Data for automatic decision-making as described in GDPR Article 22(1).

4 Cookies

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Social First, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that Social First has no access to or control over these cookies that are used by third-party advertisers.

Social First's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

5 Recipients to which we share Personal Data

We will share your personal data with others when necessary. The recipient is the controller for the processing of your personal data, unless otherwise stated.

We share your personal data with the following recipients:

Service providers

In order to fulfil the purposes for which we process your Personal Data, our service providers also process your Personal Data. Service providers provide us with IT services such as cloud hosting, technical support and maintenance of IT systems and analytics services. Service providers may process your Personal Data only for these purposes and only in accordance with our instructions, not for their own purposes. In this relation we remain as the Controller and these service providers act as our processor, as defined in the GDPR:

We are the data controller for the processing that service providers carry out on our behalf and for us.

6 Where we process your Personal Data

We always aim to store and process Personal Data in the EU/EEA.

However, some of our service providers are located outside the EU/EEA and in such cases Personal Data is processed outside the EU/EEA. In order to ensure the protection of Personal Data, we ensure that appropriate safeguards are in place with respect to those service providers that process your Personal Data outside the EU/EEA.

If you have any questions about the countries to which your Personal Data is transferred and the safeguards applicable to the transfer or would like a copy of the safeguards and information, if available, please contact us using the following contact details specified in Section 11.

7 Your rights (EU)

You have certain rights under data protection legislation in relation to the processing of your Personal Data. You can send us requests to exercise your rights by using the contact details specified in Section 11.

You have the following rights concerning your Personal Data processed by us:

Right to access

You have the right to access the Personal Data we process about you. You can request a copy of your Personal Data. We will give you a copy unless we have a legitimate reason not to share that information or unless sharing it would adversely affect the rights and freedoms of others.

Right to correct

You also have the right to request that incorrect or incomplete personal data be corrected or completed.

Right to withdraw consent

If the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time.

Right to object to processing

You have the right to object to the processing of your Personal Data on the basis of our legitimate interest on grounds relating to your particular situation. In this case, we will stop processing your Personal Data insofar as the processing is based on our legitimate interests unless we can demonstrate that our legitimate interests override the interests, rights and freedoms of the data subject or that the use of your Personal Data is necessary for the establishment, exercise or defence of legal claims.

Right to deletion

In certain circumstances, you have the right to request the deletion of your Personal Data. However, we cannot delete your Personal Data if, for example, we are required by law to retain it.

Right to restriction of processing

In certain circumstances, you have the right to request restriction of the processing of your Personal Data. If the processing of your Personal Data is restricted, we may process your Personal Data not only for the purposes of storage but also only with your consent, for the establishment, exercise or defence of legal claims or for the defence of other rights.

Right to data portability

You have the right to request a copy of the Personal Data we hold about you in an aggregated, commonly used and machine-readable format (data portability). Unlike the right of access, the right to data portability consists only of personal data that you have provided and that are processed on the basis of certain legal grounds, such as your consent.

8 Your rights (California)

Under the CCPA, among other rights, California consumers have the right to:

· Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

· Request that a business delete any personal data about the consumer that a business has collected.

· Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

9 Data of minors

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Social First does not knowingly collect any Personal Data from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

10 We may update this Privacy Policy

We may update the information in this Privacy Policy from time to time, for example, if we process Personal Data for new purposes, collect Personal Data included in new categories of Personal Data or share Personal Data with other recipients. In this case, we will notify you in an appropriate manner. The latest version of the Privacy Policy is always available on this website.

11 Contact

Please contact us if you have any questions about the processing of your Personal Data. You can find our contact details below. If you are not satisfied with our response, you can lodge a complaint with the relevant supervisory authority.

Social First Oy
Business ID: 3231739-5
Correspondence address: Metsärinne 17, 48310 Kotka, Finland
E-mail address: info@socialfirstgames.com
Contact person: Sophie Riordan, Marketing & Communications

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