Privacy

SORASTREAM PRIVACY POLICY

The SoraSTream Platform is owned and managed by Ludium Lab, SL with registered address at C/Manuel Girona, 82 – Basement, 08034, Barcelona, Spain. You can contact our Data Protection Officer via email to privacy@sorastream.com.

1. Introduction

At SoraStream we want to provide you with the best possible experience to ensure that you enjoy our service today, tomorrow and in the future. In order to do so, we need to know your gaming habits, so that we can offer you an exceptional and personalized service.

Having said that, the privacy and security of your personal data is of great importance to us. For this reason, we want to clearly explain how and why we collect, store, share and use your personal data, and show you the controls and options available for you to choose when and how you share your personal data.

That is our goal and we will explain it in more detail in this Privacy Policy (“Policy”).

2. About this Policy

This Policy provides essential information regarding the use that Ludium Lab, S.L (owner of the SoraStream platform, hereinafter “SoraStream“) makes of your personal data. The Policy applies to all SoraStream services and associated services (hereinafter the “SoraStream Service“). The terms governing the use of the SoraStream Service are defined in our Terms of Use and EULA (the “Terms of Use“).

Regularly, we may develop new services or offer additional services. If the introduction of these new or additional services generates any kind of change in the way we collect or process your personal data, we will provide you with more information and additional conditions or policies. Unless otherwise indicated, when these new or additional services are introduced, they will be subject to this Policy.

The main goal of this Policy is:

1. Ensure that you understand what personal data we collect about you, the reasons why we do so, and with whom we share it;

2. Explain the way in which we use the personal data that you share with us in order to control, manage and ensure the functionality of the Sorastream Service when you use it; and

3. Explain your rights and options regarding the personal data we collect and process about you and how we will protect your privacy.

We hope this helps to understand our commitment to your privacy.

If you have any questions or comments related to the processing of your data, you can send an email to privacy@sorastream.com. If you do not agree with the content of this Policy, remember that you decide if you want to use the SoraStream Service.

3. Your rights and preferences: options and control

As you may already know, the new European Union regulation known as the General Data Protection Regulation (“GDPR”) gives people certain rights related to their personal data. The rights granted to people are:

· Right of access: the right to be informed and request access to the personal data we process;

· Right to rectification: the right to request that we correct or update your personal data, when they are inaccurate or incomplete;

· Right to erasure: the right to request that your personal data be deleted;

· Right to restriction of processing: the right to request that the processing of all or some of your personal data be temporarily or permanently stopped;

· Right of opposition:

· the right, at any time, to object to the processing of your personal data for reasons related to your particular situation;

· the right to object to your personal data being processed for direct marketing purposes;

· Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit such data for use in the service of a third party;

· Right not to be subject to automated individual decision-making: the right not to be subject to decisions based solely on automated decision-making, including profiling, when the decision may have a legal effect on you or produce a similar significant effect.

· Right to revoke at any time the consent granted through the Privacy Settings panel.

 

In order to allow you to easily exercise these rights and record your preferences regarding how SoraStream uses your personal data, we will provide you with access to the following settings through the Account Settings page:

· Privacy settings: it allows you to control some of the categories of personal data that we process and it allows you to access your personal data, change your avatar, as well as consent or revoke your consent regarding the commercial communications that you may receive from SoraStream.

You can contact Ludium Lab, S.L (SoraStream) at C/Manuel Girona, 82 – Basement, 08034, Barcelona, Spain or you can contact us through privacy@sorastream.com, Ref: Data Protection, to exercise your rights. You must indicate the rights you want to exercise and prove your identity as an applicant when appropriate. Likewise, we inform you that you have the right to file a claim before the Spanish Data Protection Agency if you consider that there has been some type of violation in relation to the processing of your personal data.

4. How do we collect your personal data?

We collect your personal data as follows:

1. Checking in to SoraStream Service: When you register to create an account in the SoraStream Service, we collect certain personal data so you can use the SoraStream Service, such as username (alias) and email. In those plans that require payment for their use, the data regarding the payment method is also collected and, therefore, the payment platform that uses the SoraStream Service ensures its correct protection.

2. Use of the SoraStream Service: when you use the SoraStream Service, we collect personal data about the use of the SoraStream Service, such as what games you have played, when you have done it and how long have you been playing each one, as well as what games have been selected as favorites from the SoraStream Service catalog. Each game has a classification of the minimum age that the user must be to be able to access and play the game. This classification is determined by the official classification, known as Pan European Game Information (“PEGI”), which establishes the appropriate minimum age to play video games according to their category. The PEGI has the purpose of guiding the consumer about the suitability of playing a specific game through the minimum age recommended by the PEGI. Therefore, when collecting data about the games the user plays, we can also collect PEGI data.

3. Collect personal data that allows us to provide you with additional features / functionalities: from time to time, we also offer you the possibility to provide us with additional personal data or to give us your permission to collect it; for instance, to provide you with more features or functionality.

We use anonymous and additional information for purposes that include testing our computer systems, research, data analysis, marketing and promotion modeling, improving the SoraStream Service, and developing new functionality and features within the SoraStream Service. However, since the data is anonymised, it dissociates itself from the person who owns the data, preventing its identification.

5. How and what personal data do we collect from you?

We have established in the tables below the categories of personal data that we collect and use about you:

Personal data collected when you register with the SoraStream Service

Personal data Categories

Category description

Check-in data

It consists on the personal data that you provide or we collect to enable you to register and use the SoraStream Service. This includes your username, for the SoraStream Service, and your email. At the same time, in order to record the acceptance by the user of the privacy policy and the terms and conditions of the SoraStream Service, we will register the IP address and the exact time in which the user has accepted it.

The personal data that we request is necessary to create your account. However, you have the option to provide us with additional personal data in order to further personalize your account such as an image or avatar.

The exact personal data that we collect may vary depending on the type of SoraStream Service plan that you have subscribed.

Personal data collected through your use of the SoraStream Service

Personal data Categories

Category description

SoraStream Service usage data

These are the personal data collected when you use the SoraStream Service, and may include:

· Information about your type of SoraStream Service plan.

· Information about your interactions with the SoraStream Service, including the date and time of any requests you make and the games you have played and the games you have chosen as favorites.

· Messages you send and/or receive through SoraStream and your interactions with the SoraStream Customer Service team.

· Technical data that may include URL information, cookies data, your IP address, the types of devices you use to access or connect to the SoraStream Service, device attributes, device and network performance, the type of browser, the language, the information that allows the management of digital rights, operating system and version of the SoraStream application. You can find more information about the technical data that we process in our Cookies Policy[LEP1] .

Acceptance data of the PEGI of the video game

· The user has to confirm that complies,depending on the minimum age range, with the recommendations of each video game based on their corresponding PEGI, which is a European system for classifying the content of video games and other types of entertainment software based on the users age.


Personal data collected with your consent to enable us to provide you with additional features or functionality

Personal data Categories

Category description

Location data

Please note that we DO NOT access your GPS or Bluetooth to get the exact location of your mobile device. These do not include your IP address. We use your IP address to determine the inaccurate location. For instance, the country or city where you are, to comply with our license agreements, offer features, information, advertising or any other content based on your location and use of the service.

Payment data

The personal data collected for the payment method will go directly to the payment platform used and therefore, the payment platform will be responsible for its correct management and protection. The exact personal data will vary depending on the payment method (for instance, directly through your mobile operator or by invoice), but may include information such as:

· Name and surname;

· Postal Code;

· Payment method, credit card or debit

If you decide to request an invoice, we will provide your personal data to our payment processors in order to carry out a credit check so that you can have the invoices you require

Contests, raffles and survey data

This personal data is used to allow you to register and participate in these types of promotions. The exact personal data collected will vary depending on the promotion. Such personal information is used to allow SoraStream to send you marketing communications via email.

Marketing data

Such personal information is used to allow SoraStream to send you marketing communications via email.

6. For what purpose do we use your personal data?

When you use or interact with the SoraStream Service, we use different technologies to process your personal data for various reasons. The following table shows the purposes of the processing of your personal data, the associated legal bases which allows us to process your personal data, and the categories of personal data (identified in section 5 ” How and what personal data do we collect from you?”) used for the following purposes:

Description of why SoraStream processes your personal data (“processing purpose”)

Legal basis for the processing purpose

Categories of personal data used by SoraStream for the processing purpose

Provide and customize the functionality of the SoraStream Service according to the user.

· Performance of Contract

· Consent

· Account registration data

· Service usage data

· PEGI acceptance data of the video game

To understand the use of the SoraStream Service to improve the functionality of the service, develop new products and services provided by SoraStream, and analyze its use.

· Consent and acceptance of this Privacy Policy, Cookies Policy and Terms of Use of the SoraStream Service.

· Service usage data

To offer the user functions, information, recommendations, advertising or any other content based on their use of the service, including its location.

· Consent

· Service usage data

· Location data

To understand the use of the service to ensure the technical functionality of the SoraSteam Service.

· Performance of contract

· Legitimate interests

· Account registration data

· Service usage data

· PEGI acceptance data of the video game

To communicate with you for purposes related to the SoraStream Service.

· Performance of contract

· Account registration data

· Service usage data

[XVM2] [ASM3] [XV4] [LEP5] To validate your payment to prevent or detect fraud, including fraudulent payments and fraudulent use of the SoraStream Service, and manage billing services.

· Performance of contract

· To comply with legal obligations

· Payment data

To communicate with you regarding your participation in surveys, contests, raffles and promotions.

· Consent

· Contests, raffles and survey data

· Marketing data

7. Shared use of your personal data

Esta Sección presenta las diferentes categorías de destinatarios de los datos personales recogidos o generados a través de su uso del Servicio SoraStream.

This Section introduces the different categories of the recipients of the personal data collected or generated through your use of the SoraStream Service.

Publicly available information

The following personal data will always be publicly available on the SoraStream Service: Avatar and username that will be shared with other SoraStream users who use the service.

Information that we can share

Recipient Category

Sharing purpose

Service providers and other collaborators

We use technical service providers that procure the technical infrastructure we need to provide the SoraStream Service, in particular the providers that host, store, manage and maintain the Sorastream application, its content and the data we process.

We use technical service providers to help us communicate with you, as described in Section 6 of this Policy, among others, for the resolution of technical incidents that may lead to an exchange of questions-answers-technical data that we may need in order to resolve the incident.

We use marketing and advertising partners to display more personalized content, or to help us understand your use of the SoraStream Service provide you with a better service. We may also share personal data with some marketing or advertising partners or providers in order to send you promotional communications about SoraStream.

· We may also share your personal data in a pseudonymized format with our industry partners to help them understand how activities and games work on SoraStream.

· Similarly, we share your personal data in a pseudonymized format with marketing partners who help us with promotional activities, and with advertisers who allow us to offer a free service.

Academic researchers

We will share your personal data for activities such as statistical analysis and academic study, but only in a pseudonymised format.

Other trading companies

We will share your personal data with other companies with which there are marketing agreements to carry out our daily business operations and to enable us to maintain and provide the SoraStream Service.

Compliance with the law and data protection authorities

We will share your personal data in order to comply with a legal obligation under applicable law, or to respond to a valid legal process, such as a search warrant, court order, or subpoena.

We may also share your personal data when we believe in good faith that it is necessary for our own interest or the legitimate interest of third parties related to national security, law enforcement, lawsuits, criminal investigation, protection of the safety of any person, or avoid imminent death or bodily harm, provided that we consider that such interest is not overridden by your interests or the fundamental rights and freedoms that require the protection of your personal data.

8. Data retention and erasure

We retain your personal data only for the time necessary to provide the SoraStream Service and for legitimate and essential business purposes, such as maintaining the performance of the SoraStream Service, making data-driven business decisions about new features and offerings, complying with our legal obligations and resolving disputes. We retain some of your personal data while you are a user of the SoraStream Service.

Upon request, we may delete or anonymize your personal data so that you are not identified, unless, we can or are legally required to retain certain personal data, including the following cases:

· If there is an unresolved issue related to your account, such as pending payments on your account or an unresolved claim or dispute, we will retain the necessary personal data until such issue is resolved;

· When we are obliged to retain personal data to comply with our legal, tax, accounting and auditing obligations, we will keep the necessary personal data for the period required by applicable law; and/or

· When necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

9. Transfer to other countries

SoraStream does not share your personal data with other companies located outside the territory of the EU.

10. Links

We may display third party advertisements and other content linked to third party websites. We cannot control or be responsible for the privacy practices and content of third parties. If you click on a third-party advertisement or link, you understand that you are leaving the SoraStream Service and any personal information you provide will not be covered by this Policy. Please read the privacy policies of the third parties responsible for the website you access to find out how they collect and process your personal data.

11. Protection of your personal data

We are committed to protect the personal data of our users. We implement the appropriate technical and organizational measures to help protect the security of your personal data. However, keep in mind that no system is completely secure. We have implemented various policies including pseudonymization, encryption, access and retention policies to protect against unauthorized access and unnecessary retention of personal data on our systems.

The password protects your user account, so we recommend that you use a unique and firm password, to limit access to your computer and browser, and log out after using the SoraStream Service.

12. Minors

The SoraStream Service is not addressed to minors.

If you are the parent of a minor below the age limit established by the applicable regulations and you are aware that your child has provided personal data to SoraStream, please contact us using the email privacy@sorastream.com so you can request the exercise of your rights.

If we discover that we have collected a minor’s personal data, we will take reasonable steps to delete the personal data. This may require the deletion or, where appropriate, blocking of the SoraStream account.

13. Avatar or Profile Picture

We inform you that if you add your own image as a profile picture, it will be public and any person or user will be able to access and view it. To configure the Privacy of the profile picture you have chosen, you must access the Profile Settings.

14. Changes to this Privacy Policy

Occasionally, we may make changes to this Policy. If we make material changes, we will provide you with a prominent notice under the circumstances, for example, by displaying one in the SoraStream Service or by sending you an email. We can notify you in advance.

Therefore, be sure to read any notification carefully.

15. How to contact us

If you have any questions about this Policy, please contact our Data Protection Officer by email to privacy@sorastream.com or by writing at the following address:

SoraStream (Ludium Lab, S.L)

 C/Manuel Girona 82, Basement

PC 08034

Barcelona, Spain

The Data Controller is Ludium Lab, S.L (owner of the SoraStream Platform).