This Privacy Policy is applicable to the processing of data carried out by TAPROOM, S.L. carried out through this game: Basketball Fantasy Manager NBA (hereinafter, the "Game") and/or those indicated. We recommend that you read it carefully before using this Game or providing your data through it. Please do not hesitate to contact us with any questions you may have by e-mail: finance@taproomgames.com.
TABLE OF CONTENTS
In this Policy you will find all the information relating to the processing of your personal data and the rights you can exercise to maintain control over them. In this regard, you will find information on:
1. Who is responsible for the processing of your data?
2. What requirements you must meet to provide us with your personal data?
3. What data processing we carry out through the App and what are its main characteristics, explaining to you:
Ř What data we collect and how we collect it?
Ř For what purposes we collect the data we request.
Ř What is the legitimacy for its processing?
Ř How long we keep them?
4. To which recipients your data is communicated?
5. Existence of international transfers of your data.
6. What your rights are and how you can exercise them?
7. How we protect your personal data?
8. Which legislation affects this policy?
9. Changes to this policy.
Your personal data will be processed by the company TAPROOM, S.L. ("TAPROOM "), with NIF B67961870 and whose contact details are as follows:
· Registered offices: Calle Rosselló i Porcel 21, 15B – 08016 Barcelona
· Contact email address: finance@taproomgames.com.
1.1. Our Data Protection Officer: From TAPROOM, we provide you with the contact details of our Data Protection Officer (DPO), to whom you can address any queries you may have in relation to this Privacy Policy or the processing of your personal data.
E-mail: dpo@fromthebenchgames.com.
2.1. Minimum age. To provide us with your personal data, you must be at least 13 years of age and/or have sufficient legal capacity to use this Game.
2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the personal data and information provided is real, truthful, updated and belongs to you and not to third parties.
Furthermore, you must notify us of any modification that may occur in the data provided, being responsible in any case for the truthfulness and accuracy of the data provided at all times.
2.3. Age and Truthfulness Check. From TAPROOM we reserve the right to verify your age and identifying information at any time, if necessary, including by requiring official proof of age or equivalent procedure and, in the event of fraud detection that proves or is suspected that you are under the age indicated, to delete, temporarily disable and/or terminate your account.
Below, we explain how we treat your personal data and provide you, in detail, with all relevant information regarding your privacy:
|
What are the ways of data collection? |
· Customer assistance channel · Sending e-mails to any mail addresses of TAPROOM. |
|
What data do we collect?
|
Identifying and contact information. We collect your identifying information (name and surname) and e-mail address, as well as any other personal data that you voluntarily include in the communications you send us. We may request additional information from you if necessary to comply with your request or requirement. |
|
What are the purposes of the processing of your personal data?
|
To answer your requests. The main purpose of the processing of this data will be to answer your requests, resolve your queries and/or provide you with the required information, as well as, where appropriate, to follow up on your requests.
Improving customer assistance. All the information derived from the doubts, queries, and advice offered to interested parties, as well as the way in which requests are resolved, allows us to know how we provide our own customer service, enabling us to improve its quality. Likewise, all the personal data collected, once the retention period indicated below has expired, is anonymised and used for the purposes of analysing the most frequently asked questions via the chat and automating the most frequently asked questions, creating FAQS or being kept for statistical purposes in order to develop commercial strategies. |
|
What is the lawful basis of processing? Is the provision of this data obligatory?
|
Consent. The data provided for the above purposes will be processed on lawful basis of your consent, granted when you voluntarily contact us through the means made available to you to request information. All personal data collected by the customer service department will be processed by us for statistical purposes that will help us to improve the quality of the customer service provided. This purpose is compatible with the initial one. The personal data that you are required to provide will be indicated by an asterisk or similar. Without this personal data it will not be possible to deal with your enquiries or requests.
|
|
How long do we keep your personal data?
|
All your personal data will be processed by us during the time your applications are being processed and, if necessary, to follow up on them. At the end of this period, TAPROOM we will keep this personal data, blocked, for the periods provided for by law to deal with any liabilities and to demonstrate compliance with our obligations. From this point onwards, TAPROOM will only process the personal data in an anonymised form, so it will not be possible to link the statistical information with the specific users to whom it refers. |
|
Who do we give your personal data to?
|
We do not make any additional transfers to carry out this processing other than those indicated, in general terms, in point 4. To whom do we transfer your personal data? In this regard, some of the channels through which you can contact us are managed by service providers, who act as Processors. You will find more information about how these service providers operate in section 4 above. |
|
What are the ways of data collection? |
We may obtain your personal data in different ways. This will depend on how you access to the Game. You have two options: - to register - or not to register If you decide to register, here are the ways to do it: · Via Facebook · Apple account · FTB account
|
|
What data do we collect?
|
When you choose not to register, you just need to give us your nickname. If you decide to register, depending on the type of registration, the data we will obtain will be: · Facebook: email and nickname · Apple account: Apple ID, contact ID and nickname · FTB account: email, name and surname, date of birth, gender, country, hobbies and nickname.
The personal data that you are required to provide will be indicated by an asterisk or similar. Without this personal data you will not be able to play the Game. |
|
What are the purposes of the processing of your personal data?
|
The main objective of the processing is to manage and administer everything necessary for you to be able to play our game.
Within this main purpose there are others:
· We may profile your data if you give us your explicit consent. o This profiling will allow us to offer you a better gaming experience. o Third-party customized advertising (you can oppose this purpose). · Game improvement analytics. · Sometimes we may ask you to provide us with your email address to offer you compensation for the Game. · "Big whales contact": When you are a "great player", i.e., you meet certain requirements in the game, TAPROOM may contact you directly to offer you compensation or collaboration, provided you have given us your email address or your Contact ID. · Submmit you our retargeting campaigns.
|
|
What is the lawful basis of processing? Is the provision of this data obligatory?
|
Execution of the contract. The processing of data is necessary for the performance of the contract between the parties, i.e. so that you can play the Game. All data requested and processed by TAPROOM for the above purposes will be necessary for the purposes indicated. If they are not provided, it will not be possible to carry out the services related to them.
Consent. Your explicit consent will be required to process data that is not necessary to play the Game. We also ask for your explicit consent to receive advertising from Third parties.
Legitimate interest. Retargeting campaigns are carried out on the basis of TAPROOM's legitimate interest. TAPROOM has carried out a Legitimate interests assessment (LIA) which you can consult by contacting our DPO. |
|
How long do we keep your personal data?
|
All personal data will be processed by TAPROOM for the duration of the contractual relationship between the parties. At the end of this period, TAPROOM we will keep this personal data, blocked, for the periods provided for by law to meet any liabilities and to demonstrate compliance with our obligations. |
|
Who do we give your personal data to?
|
We do not make any additional transfers to carry out this processing other than those indicated, in general terms, in point 4. To whom do we transfer your personal data? In this regard, we may use service providers for the provision of certain additional services (e.g. consent management platforms -CMP-), who act as Processors. You will find more information on how these service providers operate in point 4 above. |
We use tracking and tracing tools on this Game to collect personal data about how users use the Game.
We can also obtain other data such as:
- geo IP
- Analytics, game statistics, login - log out.
- Payment details
- IDFA, Device ID
We use this data just for profiling and anlytical purposes.
When you use our services, you can share personal data on social networks, such as Facebook, via an implemented social plug-in (such as a "Share" button). If you choose to share information via a social plug-in, the following data will be transferred to the relevant social network:
I. Date and time of visit;
II. The Internet address or URL for the address you are temporarily visiting;
III. The IP address;
IV. The browser you are using;
V. The operating system you are using;
VI. Where applicable, your username and password and if you are a registered user of the social network, first and last name; and
VII. The information for which you have used the specific plug-in.
The above information will be used to perform the action you have indicated (sharing, "liking", etc.), in accordance with the terms and conditions of the relevant social network. We therefore encourage you to keep yourself informed of the purpose and scope of the collection of personal data through social plug-ins. If you wish, you can block social plug-ins in your browser settings.
Please note that we have no influence on the personal data that the social network collects by plug-ins.
TAPROOM has a profile on the main social networks, such as Facebook, Twitter, Instagram, Linkedin or YouTube.
When you become a follower of any of our pages on social networks, the processing of data will be governed by the terms of use, privacy policies and access regulations belonging to the corresponding social network and previously accepted by the user.
TAPROOM in this sense, will process your data for the purposes of correctly managing its presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.
Please note that we have no influence over the personal data that the social network collects or how it processes it, so we recommend that you keep yourself informed of the purpose and extent of the collection of personal data through these social networks.
In addition to the transfers that we specifically indicate in the section in which we explain the characteristics of the different operations (point 3), we inform you of the communications that we may make, in general, and which affect all the above processing and its lawful basis of processing.
i. Providers of essential services to carry out the service we offer you (for example, computer hosting companies or platforms for sending commercial communications). Notwithstanding the above, these entities have signed the corresponding confidentiality agreements and will only process your data in accordance with our instructions and may not use them for their own purposes or for purposes other than the service they provide us with.
ii. Public bodies. We may disclose to the competent public authorities the personal data and any other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of the services or fraudulent activities through our Game or our web pages. In such cases, the personal data you provide to us will be retained and made available to administrative or judicial authorities.
iii. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).
iv. To third parties after aggregation or anonymisation: we may disclose or use aggregated or anonymised data (i.e. data which cannot be linked to an identified or identifiable natural person) for any purpose.
v. To third parties with your consent or other lawful basis of processing: We share data with third parties outside the scope of this Privacy Policy (all the Ad Partners). In order to carry out this activity, we will always ask for your consent and provide you with the necessary information for you to access the Privacy Politicy of our Ad Partners.
|
Name of the Ad Partner |
Country |
Transfer mechanism |
|
Taproom SL |
Spain |
SDK |
|
AddApptr |
Germany |
SDK |
|
Google Ireland Limited |
Ireland |
SDK |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
We also inform you that this Privacy Policy only relates to the collection, processing and use of information (relating to personal data) by us through your interaction with our Game. Access to third party websites that you may access through links from the Game have their own privacy policies over which we have no control. Therefore, before you provide them with any personal data, we recommend that you inform yourself about their privacy policies.
Some of our service providers are in countries outside the European Economic Area ("EEA").
The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could imply a lower level of protection than that provided for in European legislation. However, we have implemented measures to ensure that such transfers do not occur. TAPROOM has implemented measures to ensure that such transfers does not result in a lower level of protection for your personal data.
In this regard, service providers outside the EEA have signed the relevant standard contractual clauses approved by the European Commission ("SCC"), an agreement signed between the two entities whereby the non-EU company guarantees that it applies European data protection standards.
Therefore, the use of these providers does not result in a lower level of protection of your personal data than the use of providers located in the European Union. You can consult the content of the SCC at the following link:
https://ec.europa.eu/info/law/law-topic/data-protection/publications/standard-contractual-clauses-controllers-and-processors_en
You can exercise the rights guaranteed to you by law in relation to the processing of your personal data by contacting our Data Protection Officer by emailing us at dpo@fromthebenchgames.com.
Any rights request we receive will be dealt with as soon as possible and in any event within the maximum time limit set by law from the time we receive them. In some cases, we may need to ask you for a copy of your identity card or other identification document if we need to verify your identity.
Your rights as a data subject are as follows:
i. Right to withdraw consent given
You can revoke your consent in connection with all processings based on it. However, we remind you that the withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal.
ii. Right of access
You have the right to know what data are being processed, if any, and, if so, to obtain a copy of it, as well as to obtain information relating to:
Ř the origin and recipients of the data;
Ř the purposes for which they are processed;
Ř whether there is an automated decision-making process, including profiling;
Ř the data retention period; and
Ř the rights provided by law.
iii. Right of rectification
You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.
iv. Right of withdrawal
You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or if we are no longer authorised to process it.
v. Right to data portability
You have the right to request data portability in the case of the processing of your data based on your consent or the execution of a contract, as well as when the processing is carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you can also request, where possible, that your data be transmitted directly to another company.
vi. Right to restrict the processing of your personal data
You have the right to limit the processing of your data in the following cases:
a) When you have requested the rectification of your personal data during the period in which we verify the accuracy of them.
b) When you consider that it is no longer necessary for us to continue processing your data and you want us to keep them for the purposes of exercising or defending claims.
c) When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.
d) In cases where there is processing based on our legitimate interest and you have exercised your right to object, you may ask us to limit the use of your data during verification of the prevalence of such interests over yours.
i. Right to object
You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.
Unsubscribe from commercial communications: Remember that you can oppose the receipt of such communications at any time by sending an email to dpo@fromthebenchgames.com. You can also unsubscribe from our commercial communications by following the instructions on the body foot of each electronic communication we send you.
Unsubscribe from the Game: Please note that you can unsubscribe from the Game at any time.
ii. Right to lodge a complaint with the Supervisory Authority
Remember that, at any time, and if you consider that we have violated your right to the protection of your data, you will be able to a complaint with the corresponding Control Authority, in the case of Spain, the Spanish Data Protection Agency (www.agpd.es).
The security of your personal data is a priority for us. Therefore, TAPROOM has implemented all necessary security measures to ensure the effective use and processing of personal data provided by the user, safeguarding the privacy, confidentiality and integrity of them.
Consequently, we comply with the recommended safety standards to protect your data. However, it is impossible to fully guarantee your security due to the nature of the Internet and because there may be fraudulent actions by third parties beyond our control.
We are committed to acting quickly and diligently if data security is compromised or compromised, and to inform you of this where relevant.
Below, we provide you with the laws and regulations that assist, protect and establish your rights, which have inspired this policy:
- General Data Protection Regulation EU 216/679
https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807
- Ley Orgánica 3/2018, de 5 de diciembre, on the Protection of Personal Data and Guarantee of Digital Rights.
https://www.boe.es/eli/es/lo/2018/12/05/3
- Ley 34/2002 de 11 de julio de 2002, on information society services and electronic commerce.
http://www.boe.es/buscar/act.php?id=BOE-A-2002-13758
From TAPROOM we can modify the content of the privacy policy at any time, especially when there are changes in legislation, jurisprudence or interpretation of the Spanish Data Protection Agency that affect the processing of data carried out by TAPROOM through the Game. Any new version of this Privacy Policy shall enter into force on the date of entry into force published.
If the revised version includes a material change that affects the processing of your data, we will notify you at least 30 days in advance by posting a notice on our Game. In any case, we recommend that you periodically review this Privacy Policy to be informed of how your personal data is processed and protected, as well as your rights.
This Privacy Policy has been amended on 19 de April de 2022.