We are a business company Retinmount, s.r.o., ID No.: 071 83 402, with registered office at Kuršova 980/5, Bystrc, 635 00 Brno, Czech Republic, established under Czech law, registered with the Regional Court in Brno, Insert C, Section 106645 (hereinafter referred to as "We", "Us" or "Our Company" or by using the possessive pronoun "Our").
We are also the provider of several standalone video games under the designation “TV Games” running on a wide range of televisions (each or all of which are collectively referred to as the "Games").
When you (for the purposes of this Policy, we will refer to you as "You" or by using the possessive pronoun "Your" when referring to something to which You have a right or which belongs to You) use or play the Games, We process some of Your personal data and are therefore Our Company is a controller of Your personal data.
You can contact us using the following contact details:
Your privacy is important to Us and We respect every individual's right to privacy. This privacy policy (hereinafter referred to as "Policy") has been prepared in accordance with the GDPR and explains what personal data We collect and process about You, how We process it and for what purpose We collect and process it. This Policy further describes Our commitment to the privacy and security of Your personal data and informs You of Your rights relating to the processing of Your personal data. We aim to ensure transparent, secure and ethical processing of personal data in all aspects of our business.
You can read the Policy before using or playing the Games, so please take a moment to read this Policy to understand how We treat Your personal data. If You are unsure whether and how this Policy applies to You, please do not hesitate to contact us using the contact details above. We will be happy to explain. By continuing to play or playing the Game You represent that You have read the Policy.
Personal data means, generally and for the purposes of this Policy, any information relating to an identified or identifiable natural person (You); and identifiable natural person means a person who can be identified, directly or indirectly, in particular by reference to his or her identifying information. identifier, such as location data, device unique identifier, device model public IP address or one or more factors.
It is important to note that You can use most of Our Games without telling Us directly who You are (e.g. Your name). However, Your personal data is a bit broader than that, and may include, for example, an identifier for Your device where You play the Games.
Processing of personal data then means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collecting, recording, organising, structuring, storing, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, disclosure, arrangement or combination, restriction, erasure or destruction.
You have to fill in certain data to conclude an agreement with Us to play the Games, and We also access other data, e.g. from Your device (usually Your TV). To help You understand not only the scope of the processing of Your personal data, but also the purpose of the processing, We classify this data into the following categories:
In particular, Your personal data will reach Us in one of the following ways:
We do not process personal data if We have no reason to do so or the processing is not for any purpose. According to the GDPR, We may use one of the following reasons for processing Your personal data:
| Legal reason | Explanation |
|---|---|
| consent | We process Your personal data if You give Us Your consent to do so. |
| compliance with legal obligations | We process Your personal data when it is necessary for the performance of a legal obligation. |
| legitimate interest | We process Your personal data where Our legitimate interest in processing it supersedes Your rights and freedoms. |
We process Your personal data when You make enquiries, make suggestions or complaints, or when You choose to rate the Game (e.g. on Google Play) or write a comment or review on it.
If You choose to use one of the platforms or social networks to communicate with Us, please note that the processing of the data provided in this way is also governed by the terms and conditions of these platform or social networks, which We cannot control. If You comment on or rate Our Game, the processing of Your personal data is also governed by the rules of that platform. The processing of personal data for this purpose is justified by Our legitimate interest in being able to communicate with Our customers or Your consent, depending on which party initiates the communication. The provision of personal data in this case is not a legal or contractual requirement. Thus, You are under no obligation to provide Us with Your personal data for this purpose.
If You choose to publish a review, You do so voluntarily and We process Your data on the basis of Your consent. You can withdraw Your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. Thus, You are under no obligation to provide Us with Your personal data for this purpose.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Communication, evaluation of satisfaction, rating, publication of reviews, handling of complaints and complaints | Identification and address data; Data related to the contract and its performance; Contact details | legitimate interest | For a period of 5 years from the end of Our contractual relationship, or for 5 years from the date of collection of the personal data, whichever lasts for a shorter period of time |
| consent | Until Your consent is withdrawn |
Advertisements are how We make money, and they allow Us to bring You new Games or improve existing ones to keep You entertained.
We try to make sure that You only see advertising that You are genuinely interested in and that is suitable for You and that You can enjoy, not advertising that has no connection to Your person or interests. In order to target advertising in this way We need to process some of Your personal data, typically the country the device or device mode You used is located, language of the device, cookies or other similar data that tells Us something about Your interests and behaviour. For the purpose of targeting advertising, We process Your personal data on the basis of Your consent.
The provision of personal data on the basis of Your consent is voluntary in this case, but without that it would not be possible to provide You with personalised content and advertising. You can withdraw Your consent at any time. The provision of personal data in this case is not a legal or contractual requirement. You are therefore under no obligation to provide Us with Your personal data for this purpose.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Personalised advertising | Electronic data from the device, data relating to the Games, geo-location data | consent | For the duration of Our contractual relationship or for the duration of the consent (until withdrawal), whichever lasts for a shorter period of time |
If You do not give Us Your consent, You will still see ads, they just may not be as personalised and relevant to Your preferences. We also process some personal data to provide non-personalised ads, but this does not relate to You as much as in the case of personalised ads, but may still include Your age (for example, for the relevance of the ad) or Your device identifier.
In the absence of consent to personalised advertising, We process this minimum data for some (non-personalised advertising) on the basis of Our legitimate interest.
The provision of personal data in this case is not a legal or contractual requirement. Thus, You are not obliged to provide Us with Your personal data for this purpose, however, We process Your personal data for this purpose in situations where You have already provided Us with Your personal data. You are entitled to object to the processing of personal data on the basis of legitimate interest.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Non-personalised advertising | Electronic data from the device, data relating to the Games, age, geo-location data | legitimate interest | For the duration of the contractual relationship |
We want You to enjoy playing Our Games. That's why We try to make them the best they can be. To meet Your requirements or the requirements of Your device, We process some data about Your device or the Games themselves as You play them. This helps Us to develop Games that Your device will run without problems, i.e. that are optimised. At the same time, We can use the statistics to find out what Games people enjoy and focus on them.
We do so based on Our legitimate interest in improving Our Gams.
The provision of personal data in this case is not a legal or contrctual requirement. Thus, You are not obliged to provide Us with Your personal data for this purpose, however, We process Your personal data for this purpose in situations where You have already provided Us with Your personal data. You are entitled to object to the processing of personal data on the basis of legitimate interest.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Development and improvement of games, their optimization | Electronic data from the device, data relating to the Games | legitimate interest | For the duration of the contractual relationship |
We also process some of Your personal data to comply with Our legal obligations. The processing of personal data for this purpose is justified by the fulfilment of legal obligations. We must process this data about You.
An example of this would be to verify Your age if We offer subscriptions, microtransactions or other payments. This will also involve the processing of personal data, particularly for tax and accounting purposes.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Fulfilling legal obligations in the field of accounting and taxation | Identification details; Contact details, payment card details or the payment itself, which We collect, for example, from the payment gateway. | fulfilling legal obligations in the field of accounting and taxes | For the period prescribed by the relevant laws. In the case of the Czech Republic, the period is 5 years, for tax documents the period is 10 years. |
| Verifying the appropriateness of advertising | Age or date of birth | fulfilling legal obligations | For the duration of the contractual relationship |
After the termination of Our contractual relationship, We will still retain Your data for a reasonable period of time, as determined by statutory limitation periods, to protect Our rights, property or safety or the rights, property or safety of others. The processing of Your data for this purpose is justified by Our legitimate interest in protecting Our rights, property or safety or the rights, property or safety of others.
The provision of personal data in this case is not a legal or contractual requirement. Thus, You are under no obligation to provide Us with Your personal data for this purpose, however, We process Your personal data for this purpose in situations where You have already provided Us with Your personal data.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Protection of Our rights; | Identification and address data; Data related to the contract and its performance | legitimate interest | For a period of 5 years from the termination of Our contractual relationship or for a period of 5 years from the acquisition of personal data |
In order to ensure the security of Your personal data and to offer and provide You with the Games, the following groups of recipients and processors help Us to process Your personal data:
| Processors / Recipients | Reasons for disclosure |
|---|---|
| Legal advisors, tax advisors and auditors | Things We don't understand, We entrust to the experts. To the extent necessary, We therefore pass on Your personal data for processing to accountants, legal advisors, tax advisors or auditors. In the vast majority of cases, this is only the data contained in accounting and tax documents. |
| Subjects ensuring the operation of the Games or IT infrastructure | In order to offer and provide You with Games at the highest level, We have to cooperate with a number of information and communication service providers (e.g. providers of IT services and hosting including cloud storage, providers of security and integrity of Our services and websites, providers of billing or accounting system.) |
| Entities providing marketing and graphic services, advertising providers | Marketing agencies, marketing specialists or graphic designers can help Us with the preparation and implementation of marketing campaigns. The ads You see in the Games are also not created by Us directly but are sourced in an automated way from ad providers. In order for them to select appropriate advertising for You, We must also provide them with certain personal data. |
| Subjects providing payment services (payment gateway operators, banks, etc.) | If We use subscriptions or other transactions in the Games, We must transfer Your personal data to the payment processors. |
| Public authorities (courts, prosecutors, state and local government authorities, etc.) | We disclose Your personal data to public authorities in cases of protection or enforcement of contractual rights (typically when filing a lawsuit, motion, complaint, etc.) or if required by law. Disclosures of personal data to these bodies are not made on a regular basis, but only on a random basis. |
We are a company from the Czech Republic, We also have a large part of Our processors in the European Union. However, We operate the Games globally, so in some cases We may provide Your personal data to entities outside the European Union or the European Economic Area.
However, if We transfer Your personal data for processing to a third country (outside the European Economic Area, which includes the countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organisation, We do so only if the European Commission has determined that the third country or international organisation provides an adequate level of protection, or if the recipient of the personal data has provided appropriate safeguards for the protection of the personal data and there are enforceable data subject rights and effective legal protection for data subjects in the destination country. We may also transfer personal data to certain entities in the U.S. under the Data Privacy Framework if they participate in it.
Personal data is processed manually and automatically. We keep proper records of all processing activities in accordance with the relevant legislation.
To exercise Your rights, please contact Us using Our contact details, which are set out at the beginning of this Policy. We reserve the right to reasonably verify the identity of the applicant for the rights in question. If requests are repetitive and manifestly unfounded or unreasonable, We may impose a reasonable fee or refuse to comply with the request.
Our Games are not primarily intended for persons under the age of 18. Therefore, We do not intentionally collect their personal data. If, for any reason, it is necessary to obtain consent from a person under the age of 18, We ask for the consent of the person who has parental responsibility for the child. If We discover that We have inadvertently obtained personal data about a person under 18 without the appropriate consent, We will take steps to delete that data as soon as possible, except where We are required by law to retain it.
We are committed to keeping your personal dta safe. We have therefore adopted appropriate and appropriate physical, technical and procedural security measures that are appropriate to the sensitivity of the personal data concerned. These safeguards are designed to prevent the loss and unauthorized access, collection, use, disclosure, copying, modification, destruction or destruction of Your Personal data.
The security of your personal data is important to Us. Please notify Us immediately of any incident involving the loss of or unauthorized access to personal data under our control of which you become aware by emailing Us at the address listed at the beginning of this Policy.
We also regularly assess the risks associated with the processing of personal data and take steps to minimise them.
When processing personal data, We are mainly governed by the Regulation (EU) 2016/679 of The European parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Legislation and Our business strategy and related processing of Your personal data may change. If We decide to update this policy, We will post the changes on Our website. We ask that You read this policy carefully and review this policy on an ongoing basis when You communicate with Us, use Our website or play the Game.