Space Puzzle Privacy Policy

Last updated: December 4, 2019

Vectura Games OÜ (“Company”, “We”, “Us”, or “Our”) is the owner and operator of Space Puzzle mobile game (“Game”). Any reference to “You”, “Your” or “User” refers to the User who installs and uses the Game. The Company is the data controller for the purposes of this Privacy Policy.

1. Acceptance of this Privacy Policy

Please read this Privacy Policy before you proceed to use the Game. This Privacy Policy informs you: what information we and the third-party services we use collect from you; and how we and these third-party services use and share your information. We do not use or share your personal information with anyone except as described hereunder. By installing the Game and making use of our services, you give us your full consent to the collection and use of your Information as outlined hereunder. If you have any questions about this Privacy Policy, please contact us at .

2. Amendments to this Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time. We will notify you of any changes to the Privacy Policy by changing the last updated date on this page. You are advised to review this Policy periodically. Please take note that any changes will be effective when posted on this web page.

3. Information we collect and how we process it

Personally identifiable information refers to information that can be used to personally identify you including but not limited to: your name, your email address, your IP address, your phone number and other similar information. Users are not required to provide us with any personally identifiable information to use the Game, however, Users may choose to provide us with their personally identifiable information by contacting us via email with queries or support requests.

Collection of enquiry information

We collect your email address, your name and the content of your message when you send us enquiries or other support requests directly to the email address: .

Purpose of processing

We process the data received from your enquiry for the purpose of responding to your request, to keep a record of your past communication with the Company and to provide you support where applicable.

Legal Basis for Processing

The legal basis of our processing is legitimate interest as we are unable to perform our obligations towards you without processing your personal information.

4. Sharing your information

We do not sell or rent your personal information to any third-party. We may disclose your personal information in the following circumstances:

  • if we are required to do so by law;
  • to fulfil our legal obligation;
  • to protect our vital interest;
  • to protect the interests of other individuals and/or;
  • upon reasonable requests from the law enforcement authorities.

We may also disclose your personal information to our employees and other service providers and sub-contractors who assist us in delivering our service to you as set out in this privacy policy, only to the extent necessary.

5. Transfering your data outside of the EEA

Although the Company is located in Estonia and we use third-party applications and services that have servers located outside of the Eurpoean Economic Area (EEA) including United States of America where the data protection laws are significantly different from those within the EEA. When you use the Game your information may be transferred outside of the EEA for the purposes of processing as set out in this Privacy Policy. Please note that despite such transfer of data outside of the EEA, your personal information will always be handled in accordance with this Privacy Policy and you will retain all rights outlined in this Privacy Policy.

Merger or Acquisition

Mergers and acquisitions are part of business reality. In the event we undergo a merger or acquisition, your personal information will be transferred to the new acquirer who may be outside the EEA as part of our business asset. We assure you that any transfer of your personal data to a new entity will not limit your rights under this privacy policy and your personal information will be managed by the new entity on terms substantially the same as set out in this Privacy Policy.

6. Your Rights

  1. You have the right to access your personal information that we hold;
  2. You have the right to edit your personal information on our records;
  3. You have the right to request erasure of your personal information from our records;
  4. You have the right to restrict processing of your personal information;
  5. You have the right to request that we do not process your personal information for a specific purpose;
  6. You have the right to data portability;
  7. You have the right to file a complaint with a supervisory authority;
  8. You have the right to withdraw your consent as specified in this Privacy Policy.
Your right to access your personal information

Where we process your personal data, you have the right to access your personal data that we hold along with information relating to the purpose for which we are processing your data and who we share it with. This right is only available to the extent that your access does not negatively affect the rights of other individuals and is not excessive or manifestly unfounded. Please note, we may be required to verify your identity before providing any access to personal information. This is to ensure that your personal information is not accessed by any unauthorized person. We will respond to your request within one month provided the request is not excessive or manifestly unfounded.

Your right to edit your personal information

Where the information we hold about you is incorrect, outdated or inaccurate, you have the right to rectify any inaccuracies or updating your information. Please note, we may be required to verify your identity before providing any access to personal information. This is to ensure that your personal information is not accessed by any unauthorized person resulting in a security breach. We will respond to rectification requests within one month provided the request is not excessive or manifestly unfounded.

Your right to erasure of your personal information

You have the right to request erasure of your personal information from our records under the following circumstances:

  • Your personal information is no longer required for the purpose for which it was initially collected;
  • You withdraw your consent that you previously granted;
  • Where you object to the processing of your data and there is no overriding legitimate interest to continue processing;
  • Where your personal data is unlawfully processed (originally in breach of GDPR);
  • To comply with legal obligation
  • Where your personal data is used for direct marketing purposes.

If you wish to exercise your right to access, edit or erase your personal information, please contact us at and we will respond to your request within thirty days.

Your right to restrict processing of your personal information

You may under certain circumstances request us to restrict processing your personal data including where:

  • You dispute the accuracy of your personal information that we hold;
  • The processing of your personal information is unlawful but you are not authorizing us to erase it;
  • We no longer require your personal data for the purposes for which it was obtained but you require the personal data for establishing, exercising or defending legal claim and you have objected to processing of such personal information in the interim;

Please note that we will continue to retain your personal data in the aforementioned circumstances and we will only process your personal information under these circumstances if:

  • We have your consent;
  • Where such processing of personal information will be in public interest; or
  • We need to process your personal information to establish, exercise or defend a legal claim.
Your right to object to storing and processing of your personal information

You have the right to object to our holding and processing of your personal information where processing is based on legitimate interest, direct marketing purposes including profiling. We will immediately cease processing your personal data unless where processing is for the establishment, exercise or defence of a legal claim; or we have a compelling legitimate ground for processing.

Your right to Opt Out

You have the right to opt out from receiving marketing communications by simply clicking the unsubscribe link at the bottom of our email.

Your right to data portability

Where your personal information was collected automatically, you have the right to receive your data in a machine readable format or request us to send this data to another Company upon your request. We will respond to your request with thirty days from the date of receipt.

Your right to file a complaint with a supervisory authority

If you are of the view that our processing of your personal information is infringing your privacy rights or any applicable privacy laws governing your personal data, you may file a complaint with a supervisory authority responsible for data protection in your country of residence (if you are living in EEA) or in Estonia at:

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Väike-Ameerika 19
10129 Tallinn
Tel.: +372 6274 135
Fax: +372 6274 137
e-mail: info@aki.ee
Website: http://www.aki.ee/en

Your right to withdraw your consent

Where we use consent as the legal basis for processing your personal information, you have the right to withdraw your consent anytime by giving us a written notice of your withdrawal at .

7. Security of your data

We endeavour to keep all your information secure and use all reasonable and commercially viable methods and techniques to protect your data. However, as with most online storage and transmission of data, there may be vulnerabilities that we are not aware of therefore we are unable to offer any guarantees as to the security of your data. As you are not required to provide any personal information to use the Game, the risk is limited.

8. Retention of data

We will not retain any of your data for a period longer than necessary for the fulfilment of our business and legal requirements.

9. Disclaimer for third-party website links

Our Game may contain links to third party websites that are neither owned nor operated by us. Should you decide to click on any such third party links, you will be directed to such third party website. These third-party sites have their own Terms of Service and Privacy Policy and we encourage you to review their Terms and Privacy Policy prior to using their site or any services offered by them.

We disclaim all liability with regards to your use and access of such third-party sites. We cannot be held responsible for any content made available by these third-party sites or their practices. You access and use these sites solely at your own risk.

10. Protection of Children’s Privacy

Our Game is not aimed at people who are under the age of eighteen (18) years ("Children"). If you are the parent / legal guardian of a Child who you believe has provided us with his/her personally identifiable information, please contact us immediately and we will take steps to remove such personally identifiable information from our database and servers immediately. We do not and never will knowingly collect any personal information from children.

11. Contact us

Email:
Address: Sepapaja 6, Tallinn 15551, Estonia