General Privacy Policy

1. Categories of individuals - whom this policy concerns?
2. Huuuge Group companies
3. Personal Data Controller and Data Protection Officer
4. Personal data processing
5. Personal data sharing
6. International data transfers
7. Rights of the data subjects
8. Source of obtaining personal data
9. Updates to the information notice

1. Categories of individuals - whom this policy concerns?

The purpose of this policy is to gather in one place information about how personal data is  processed by the Huuuge Group companies.
This Huuuge Group (“we”, “us”) privacy  notice is addressed to the following categories of persons:

1. persons who want to communicate with us, get in contact with us,
2. persons who cooperate or intents to cooperate with us or are representatives of our business partners (including our service providers, advertising networks, independent game developers), 
3. persons who are willing to participate in our events (for instance conferences, lectures, competitions) or are addressees of other marketing activities.

If you intend to use or are already using our services (our mobile applications, our websites, our pages or presence on third party websites (e.g. Facebook) and other platforms, websites products, offers and services connected to our games), please read this privacy policy.

2. Huuuge Group companies

Huuuge Group consists of the following companies (please note that this list may be amended from time to time), that depending on the situation, as specified below, will be your data controller:

1. Huuuge Global Limited with its registered seat in Limassol, Cyprus
address: 28th October Street, No. 331 Kanika Enaerios, Lido House Block 1, Office 762 3106 Limassol Cyprus
2. Huuuge Publishing Ltd. with its registered seat in Limassol, Cyprus
Address: 28th October Street, No. 331 Kanika Enaerios, Lido House Block 1, Office 762 3106 Limassol Cyprus
3. Billionaire Games Limited with its registered seat in Limassol, Cyprus
Address: 28th October Street, No. 331 Kanika Enaerios, Lido House Block 1, Office 762 
4. Huuuge Games sp. z o.o. with its registered seat in Szczecin, Poland
address: Storrady Świętosławy 1A/501, 71-602 Szczecin, Poland
5. Huuuge, Inc. with its registered seat in Dover, Delaware, U.S.A.
address: Legal 850 New Burton Road Dover, Delaware 19940 U.S.A. 
6. Huuuge Digital Ltd. with its registered seat in Tel Aviv, Israel
address: Hashalom Rd 2, Tel Aviv, 6789202 Israel
Post address: 2300 W Sahara Ave. Suite #680, Mailbox #32 Las Vegas, NV 89102 USA
7. Playable Platform B.V. with its registered seat in Amsterdam, the Netherlands
address: Keizersgracht 121, 1015 CJ Amsterdam, Netherlands
8. Double Star Oy with its registered seat in Helsinki, Finland
address: Epicenter Helsinki, 00100 Helsinki, Finland, 
9. Huuuge UK Ltd. with its registered seat in London, United Kingdom
address: 7 Savoy Court, London WC2R 0EX, United Kingdom

3. Personal Data Controller and Data Protection Officer

Your personal data controller is one of the Huuuge Group companies listed above that interacts with you. In particular, it is a company with which you sign a contract, to which you address your letter or e-mail or which is organizing an event or other marketing activities you are interested in (hereinafter: “Controller”). 

If you have doubts as regards the exact company of Huuuge Group that is the Controller of your data, please kindly contact us. 

Within Huuuge Group there is appointed a Data Protection Officer (the “DPO”) who is the person responsible for overseeing matters related to data protection and privacy matters. The DPO is the designated contact for data protection issues for all the companies of the Huuuge Group. In case you have any questions regarding our processing of your personal data or if you would like to exercise any of your rights , you can reach our DPO at the following address: 

ATTN: Data Protection Officer
Huuuge Games sp. z o.o.
Storrady Świętosławy 1/501, 71-602 Szczecin, Poland
dpo@huuugegames.com

4. Personal data processing

The Huuuge Group companies ensure that the data processing is always in compliance with applicable privacy laws, no matter whether you are located in the EU/ or European Economic Area (EEA) or elsewhere.  

Persons contacting Huuuge Group

The purpose of personal data processing is to communicate with persons contacting a particular company of the Huuuge Group (the Controller). The legal basis for personal data processing is the legitimate interest of the Controller or third parties (e.g. other companies from Huuuge Group or our partner) which allows to:

1. initiate relationships with persons contacting the Controller, 
2. communicate with the person contacting the Controller, 
3. providing the requested or otherwise necessary information to such a person. 

Personal data processed are usually your name, surname, e-mail address, telephone number, correspondence address and other information provided by you within the course of communication, in particular in the contact form available on the Huuuge Group’s websites. 

Providing your personal data is voluntary, however, if in some cases you fail to provide all the details significant in specific circumstances, the communication process may be hindered or impossible to conduct. 

Data storing period: as long as necessary to pursue the legitimate interest of the Controller or a third party.

Contractors and representatives of contractors/ business partners

The purpose of personal data processing is to cooperate, initiate the possible cooperation, conclusion and/or performance  of the business contract, maintain relationships with our contractors, i.e. service providers and business partners, facilitate our contract management, KYC and procurement procedures. 

The processing of personal data of contractors and persons appointed by them (including their employees and business associates, representatives or other contact persons/ facilitators of the contract performance) takes place in order to conclude or perform an agreement or on the basis of a legitimate interest of the Controller or third parties, i.e. facilitation of communication and maintenance of relations with the contractor and performance of the agreement. Huuuge will also process personal data in order to fulfill its legal obligations stemming from applicable law, including provisions on tax and accounting.

We usually process the following personal data concerning our contractors or their contacting persons: name, surname, e-mail address, telephone number, workplace, position, business activity address, tax identification number, statistical number, personal number, bank account details and other particulars necessary to enter into and/or perform the agreement and maintain relations with contractors. Personal data collected form our contractors/their representatives may vary depending on the requirements of applicable legal frameworks. In some cases, we may require more detailed information in order to perform our standard KYC procedures (place or date of birth regarding company’s shareholders or names of the ultimate beneficial owners of the company) Providing personal data may be indispensable in order to conclude, perform a contract or to maintain a relationship with contractor/ business partner. The consequence of not providing data may be the inability to achieve the above and we may not be able to cooperate. 

Data storing period: the term of the contract and further a the period necessary to possibly protect from claims out of this contract or to fulfill the legal obligations, such as tax, accounting documentation archiving.

Events participation and marketing/activities

Huuuge Group companies are engaged in activities which aim at promoting the Huuuge brand. In particular, we may process your personal data when exercising the following:

• marketing and PR related communication including offers and invitations;
• organizing or co-organizing events (including conferences, lectures, competitions).

The legal basis for personal data processing is your consent or our legitimate interest i.e. conducting marketing activities, maintaining relationships with you, enabling you to participate in our events and providing you with necessary information. Sometimes we will also need your personal data for the purposes of concluding a contract with you.

In most cases we will be processing data such as your name, surname, e-mail address, telephone number, workplace, position, business activity address. We may also process personal data such as your image or shirt size. Depending on the circumstances, we may also process other categories of personal data. You may acquire information on personal data processed for the purposes of a particular event by reading its terms or/and by contacting the Huuuge Group company which acts as an organizer of a particular event. 

Providing personal data is voluntary, however, in some cases it may be indispensable, for instance in order to make it possible to communicate with you or to enable you to participate in our events. The consequence of not providing data may be the inability to communicate with you or to enable you to participate in our events.

Data storing period: until the consent is withdrawn, as long as a contract is in force, not shorter, however than for a period arising from provisions of law or as long as necessary to pursue a legitimate interest of the Controller or a third party.

5. Personal data sharing

If it occurs that we are legally obliged to do so, we may provide your personal data to entities and public bodies authorized to process such data on the basis of legal regulations (for instance tax office, courts). When necessary, we may share your personal data when a need to protect the rights or property of Huuuge Group or applicable third parties occurs.

Your personal data may be also transferred to other companies within the Huuuge Group, their affiliates and their contractors. Please note that all companies of the Huuuge Group (and their contractors) ensure appropriate safety measures regarding your personal data.

Also note that when necessary, sometimes we use assistance from our contractors (business partners and service providers) in order to maintain our business operations. Consequently, we may share your personal data with other entities who support us in conducting activities, in particular advisors, IT service providers, marketing service providers), services in the scope of archiving and destruction of documents, finance and accounting services and insurance services. 

 As a safeguards for such data sharing we arranged:

• data processing agreements with our support partners who act as our processors or,
• sharing personal data agreements/clauses, where our partner is also a data controller of your personal data,

where we ensure that your personal information is only used in accordance with our instructions and with the initial purpose of processing your data, and that the use by the third party is in accordance with the applicable law requirements or our contractual arrangements.

6. International data transfers

Where we apply the EU relevant personal data laws – please note  that your personal data might l be transferred to third countries situated outside the European Economic Area, e.g. via our business partner or to our affiliate outside of EEA or because of the design of service we provide to you. Such transfer shall only take place in accordance with the binding regulations regarding the protection of personal data and only when the applicable safeguards are in place. We take steps to ensure that the recipients of your data, or country of the data destination grant you the appropriate level of privacy and data protection. You can direct any requests, questions or concerns regarding Huuuge’s handling of safeguards of the transfer outside the EEA to our DPO, whose contact details are given in the point 3 above.

7. Rights of the data subjects

In connection with personal data processing, the persons whose data are processed shall have the right to (respectively):

1. demand that the Controller provides access to the personal data being processed,
2. demand that the Controller rectifies the personal data being processed,
3. demand that the Controller erases the personal data being processed, 
4. demand that the Controller restricts the processing of personal data,
5. object to the processing of personal data,
6. portability of personal data,
7. withdraw his or her consent for the processing of personal data, whereas its withdrawal shall not affect the legality of processing executed on the basis of such consent before its withdrawal.

Please note that the rights above are not unconditional. Therefore, an attempt to invoke any of the rights might not lead to its performance. We have to analyze first whether it is admissible to exercise your request.  

You also have the right to lodge a complaint with the data protection supervisory authority. We encourage you, however, to always contact us first when you have any problems or doubts regarding the personal data processing by us.

8. Source of obtaining personal data

If we did not receive personal data directly from you, it shall mean that we acquired them from the entity you are representing or you work for, from another company of the Huuuge Group or their contractors, or from publicly available sources (Internet).

9. Updates to the information notice