Privacy Policy for WebShop

Definitions
Data processing in connection with the use of the website
Purposes and legal basis of data processing at the website
Use of the website - cookies and similar technologies
Period of Personal Data processing
User’s rights
Disclosure of personal data, Data recipients, and Transfer of data outside the EEA
Security
Contact data and DPO
U.S. RESIDENTS SUPPLEMENT

 

Definitions

Last Updated on: 27 Nov 2024

1. Personal Data – any information about a natural person, identified or identifiable by one or several factors defining his/her physical, physiological, genetic, psychic, economic, cultural or social identity, including the IP of the device, location data, online identifier and information collected through cookie files and other similar technologies. This definition includes “Personal Information” as defined in the California Privacy Notice section below as well as any similar terms defined under applicable data protection law.

2. Policy – this Privacy Policy for WebShop.

3. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC.

4. Website – an online service “WebShop” run and provided by Huuuge, possibly with support of third party platform provider.

5. User – any natural person visiting the Website or using one or more Services or functionalities.

6. EEA – countries in the European Economic Area.

Any other definitions should have the same meaning as in the Terms of Use for WebShop.

Data processing in connection with the use of the website

In connection with the User’s use of the Website, Huuuge Global Limited as Website and Service provider, as described in the Terms of Use for WebShop together with Huuuge Games sp. z o. o as joint controllers (and jointly named “Huuuge”) collects data with the scope necessary to provide the respective Services and as the case may be, maintain the relation with the User or collects information about the User’s activity on the Website. The detailed rules and purposes of processing the Personal Data collected during the use of the Website by the User are described below.

Purposes and legal basis of data processing at the website

USE OF THE WEBSITE

1. You have to be legal adult in your country to enter our Website and use our Services.
2. When you enter a Website, you have to choose an option to log in, also via our third-party partner (e.g. via using your Facebook). Depending on the option you choose, we may receive your personal data also from such third-party partners (e.g. your Facebook ID) and we also recommend that you read third party partner respective privacy notice.
3. Huuuge itself may also collect User’s Personal Data such as IP address or other identifiers and information collected through cookie files and other similar technologies.
4. Personal Data are processed:
   • to provide Services (connected with running and maintaining an account, to identify the player) on this Website – the legal basis for the processing is that the processing is necessary for the performance of a contract (Article 6(1)(b) of GDPR);
   • to maintain relationships with Huuuge’s players, to possibly determine and pursue claims or defend against claims – the legal basis for the processing is the legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) to protect its rights.

PLACING ORDERS (USING PAID SERVICES ON THE WEBSITE)

5. Placement of a purchase order (to purchase Virtual Goods such as in-game virtual currency, level boosts, skins, etc) by a Website User entails the processing of his/her Personal Data. Processing data such as User identifiers, User’s name, e-mail address, billing address, device ID, IP address/location, order ID,  information on transaction you are making, payment card details, bank account details, tax ID/status is necessary to accept and handle a purchase order.
6. Personal Data are processed:
   • to fulfill a submitted purchase order and provide the Service – the legal basis for the processing is that processing is necessary for the performance of a contract (Article 6(1)(b) of GDPR);
   • to perform the statutory obligations imposed on Huuuge, in particular those following from tax and accounting laws – the legal basis for the processing is legal duty (Article 6(1)(c) of GDPR);
   • to maintain relationships with Huuuge’s  players, to possibly determine and pursue claims or defend against claims – the legal basis for the processing is the legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) to protect its rights.
7. By purchasing our goods and services, submitting information to Huuuge  in connection with using our goods or services, an application and/or by visiting, interacting with and/or using our website, in some jurisdictions, it may mean that you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy.
8. If the User purchases Virtual Goods, Huuuge’s third-party payment partner will collect the billing and financial information it needs to process the User’s charges. This may include the User’s postal address, e-mail address, and data regarding credit cards and bank account details. We encourage you to check the third-party payment partner privacy policy.
9. The third-party payment partner may share some data with Huuuge related to User’s purchases in order to enable the payments.

Use of the website - cookies and similar technologies

1. When the User visits the Website, we may collect and store some information using cookies and similar technologies, however, those are only necessary cookies and similar technologies to enable you to use this Website properly, for authentication and for security. These are indispensable for providing you the Services and you cannot opt out. Additionally, we encourage you to check our Cookies Policy.
2. Please note, however, that third-parties payment partner may use cookies for their own purposes.

Period of Personal Data processing

1. The period of data processing (including retention) by Huuuge depends on the type of service provided and the purpose of the processing. In principle, data are processed for the entire period of providing the service or fulfilling a purchase order or until the moment of filing an effective objection to the data processing in the cases where the legal basis for the processing is Huuuge’s legitimate interest.
2. The data processing period may be extended if processing is necessary to determine and pursue possible claims or defend against claims and, after that time, only when and to the extent required by law and/or authorized by law. After the processing period, the data are deleted or as permitted by law anonymized/deidentified.

User’s rights

The User may have the following rights depending on jurisdiction:

1. right to information about the processing of Personal Data – on this ground Huuuge provides a natural person submitting the request with information on the processing of data, including in particular the purposes and legal grounds for processing, the scope of available data, the entities to which the data are being disclosed, as well as the planned date of data erasure;
2. right to obtain a copy of data – on this ground Huuuge provides a copy of processed data to the natural person submitting the request;
3. right to rectification – Huuuge is obliged to remove any inconsistencies or errors in the processed Personal Data and to complete them if they are incomplete;
4. right to data erasure – on this ground one may request the erasure of data whose processing is no longer necessary for any of the purposes for which the data were collected;
5. right to restriction of processing – if such a request is submitted, Huuuge shall cease to carry out operations on the Personal Data – except for operations with regard to which the User has given consent – and to store them, in accordance with the applicable retention principles or until the reasons for the restriction of data processing cease to exist (e.g. the supervisory authority issues a decision authorising further processing);
6. right to data portability – on this ground – to the extent to which the data are processed by automated means in relation to the concluded agreement or the consent given – the User issues the data provided by the data subject in a computer readable format. It is also possible to request the data to be sent to another entity, provided that this is technically practicable on the side of both the Huuuge and the designated entity;
7. right to object to processing for marketing purposes – if applicable, the User may at any time object to the processing of Personal Data for marketing purposes, without having to justify such objection;
8. right to object to other processing purposes – the User may at any time object – on grounds relating to his or her particular situation – to the processing of Personal Data that is carried out on the basis of a legitimate interest of Huuuge (e.g. reasons related to property protection); such objection should be justified;
9. right to withdraw consent – if the data are processed on the basis of the consent given, the User has the right to withdraw it at any time, which, however, does not affect the lawfulness of processing based on consent before its withdrawal;
10. right to complain – You have the right to complain to a data protection authority about our collection and use of your personal information which is to be in Huuuge’s case –the leading protection authority is the Polish President of the Office of Data Protection. You may also contact your local data protection authority. For more information, please contact such authority, however, we always encourage you to first contact Huuuge at dpo@huuugegames.com.

Disclosure of personal data, Data recipients, and Transfer of data outside the EEA

1. In connection with provision of Services, Personal Data may be disclosed to external entities, including in particular the payment operator, service providers and vendors responsible for maintenance of IT systems, banks, entities providing accounting services and entities related to Huuuge, including companies from its group. We may also share your Personal Data with any other corporate entities within the same corporate group (including parent company and subsidiaries) (“Affiliated Entities”)  if it is necessary to provide Services.
2. Personal Data may also be disclosed in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
3. Huuuge reserves the right to disclose Personal Data to relevant authorities or third parties which will demand that they are provided such information pursuant to an appropriate legal basis and in compliance with prevailing laws. Personal Data also may be shared to protect the rights, property, life, health, security and safety of us, the Website or anyone else or to detect and prevent fraud.

User’s Personal Data collected in connection with the provision of services may be transferred across jurisdictions and outside the country or province in which you reside (to our “Affiliated Entities”, business partners or service providers located in the EEA or outside, including the United States, Israel  and possibly other countries), in which case, your information will be subject to the laws of that foreign jurisdiction which may differ from those in your jurisdiction and may be available to government authorities under lawful orders and laws applicable there. For example, Personal Data may be transferred by the payment operator.  Where required by applicable law, Huuuge takes reasonable steps to ensure that such User’s data is treated securely and lawfully and that transferred Personal Data is subject to suitable safeguards, such as application of standard contractual clauses issued by the European Commission  or transfer to “approved” territories.

Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. The personal data we receive are often encrypted.

Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

Contact data and DPO

1. Data Protection Officer (the “DPO”) at Huuge, who is the person responsible for all matters related to data protection and privacy matters. You can reach Huuuge’s 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
2. If you have any service-related issue, please contact us at support@huuugegames.com instead of contacting the Data Protection Officer.

U.S. RESIDENTS SUPPLEMENT

1. We treat all our users the same. This section, however, specifically provides additional information on how we collect, use, disclose and otherwise process personal information of our players who are individual residents of the United States of America.
2. Terms in this section mean the same as they are defined elsewhere in this policy. We refer below to You and it includes our players as well as people who access our Websites or other Services. 

Collecting Personal Information

3. Our Services may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”) as specified below.
4. Personal information does not include publicly available information, or deidentified or aggregated consumer information.
5. We DO NOT (i) sell Your personal information; (ii) knowingly collect, sell or share personal information of users under 13 years of age; (iii) collect, sell, disclose or share sensitive personal information. By sensitive personal information we mean data on race or ethnic origin, religious beliefs, genetic data, biometric data, health data, sexual orientation, philosophical beliefs and the contents of a consumer’s mail, email, text messages that are not directed to us, and personal data from a known child under 13 years of age.

Categories of Personal Information and Business Purposes and Disclosure

Please check the chapter above for the categories of personal information we collect on the Website, the business purpose and disclosures of your personal information to third parties.

Please note, that we do not sell personal information of U.S. players to third parties, regardless of the player’s age. 

Your Rights and choices 

6. You as a U.S. resident, just as all other users of our Services, have certain rights regarding Your personal information. Details about Your rights and how to perform them are set forth in Section 6 of this policy. Additionally, as a U.S. resident You may have the following rights. Please note that these rights might be subject to certain limitations.
7. Your Right to Opt-out of “Sale”/ “Sharing” of Your personal information. We do not currently consider the ways we shared users’ personal information in the past 12 months to comprise the “sale” of personal information. 
8. Right to Limit Use of Sensitive Personal Information. We do not collect sensitive personal information nor do We use sensitive personal information for the purpose of inferring characteristics about an individual, therefore We do not offer a path to exercise this right.
9. Right to opt out of the processing of Your personal information for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.
10. Right to appeal any decision or indecision related to the exercise of any right granted to You under the applicable law. Instructions for how to submit Your appeal will be included in our response explaining why We denied Your request.
11. Right to access. You have the right to confirm whether we are processing Your personal information and access such personal information. 
12. Right to not be Discriminated: The right to not be discriminated against for exercising these rights. Of course, if You do exercise any of Your rights, We will not treat You any differently.
13. Shine the light requests. Customers who are residents of California may request:

• a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and 
• a list of the categories of third parties to whom we disclosed such information.

14. How to exercise Your rights. Please see section 6.6. above for detailed description how to contact us. Inasmuch as the above information is not already provided by Huuuge, Huuuge U.S.-resident Users should make any privacy-related request by contacting “Support” from within an app or by contacting the DPO using the contact information in this Privacy Policy. 
15. How to exercise Your rights. Please see section 6.6. above for detailed description how to contact us. Inasmuch as the above information is not already provided by Huuuge, Huuuge U.S.-resident Users should make any privacy-related request by contacting “Support” from within an app or by contacting the DPO using the contact information in this Privacy Policy.
16. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of receipt. If We require more time (up to another 45 days), We will timely inform You of the reason(s) and extension period in writing. If You have an account with us, We will deliver our written response to that account. If You do not have an account with us, We will deliver our written response electronically. Any disclosures We provide will only cover the 12-month period preceding our receipt of Your request. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
17. Your browser settings may allow You to automatically transmit a “Do Not Track” signal to online services You visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.