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 limited pseudonymous technical analytics data only in aggregated statistical form about the use of the Games, and Our Company may therefore be considered a controller of certain limited pseudonymous technical data under applicable data-protection law.
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 data We process about You, how We process it and for what purpose We process it. This Policy further describes Our commitment to the privacy and security of Your 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 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 generally means information that relates to an identified natural person or that could reasonably be used to identify a person.
Our Games do not require You to provide information that identifies You directly (such as Your name, email address, phone number, postal address, or precise location). Retinmount does not attempt to identify players.
However, certain limited technical and analytics information (such as a pseudonymous measurement identifier used by Google Analytics 4 and country-level usage information) may still be treated as personal data under the GDPR, even though Retinmount cannot use it to identify any individual and only accesses it in aggregated statistical form.
Processing of personal data then means any operation or set of operations which is performed on personal data or on sets of personal data 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.
The Games do not require You to create an account or provide Your name, email address, postal address or precise location in order to play. To help You understand the scope and purpose of processing, We classify the limited technical information processed in connection with the Games into the following categories:
We do not intentionally collect Your name, precise location, MAC address, or device advertising identifiers for the purpose of identifying You. We also do not require cookies in the Games (Smart-TV apps typically do not use browser cookies).
In particular, limited technical and analytics data may reach Us in one of the following ways:
Advertisements in the Games are delivered by third-party advertising partners and TV platform operators. Technical information necessary to deliver or measure ads (for example within advertising requests such as VAST) is processed by those partners on their own systems in accordance with their privacy policies. Retinmount does not access or store advertising identifiers and receives only aggregated advertising statistics.
We process limited technical and analytics data only where necessary to operate, measure, and improve the Games. We do not process personal data for marketing profiling, behavioral advertising, or user identification purposes.
Under the GDPR, the legal basis for this limited processing is Our legitimate interest in ensuring the proper functioning, stability, security, and improvement of the Games.
| Legal reason | Explanation |
|---|---|
| legitimate interest | We process limited pseudonymous technical and usage analytics in aggregated statistical form in order to operate, monitor, secure, and improve the Games. This includes metrics such as game stability (e.g. crashes and errors), number of game sessions, device platform distribution, advertisement playback events, and country-level usage. This data is not used to identify individual users. |
We process Your personal data when You make enquiries, make suggestions or complaints, or when You choose to rate the Game 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 platforms 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. 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 | Contact details and information You provide in the communication | legitimate interest | For a period of 5 years from the end of Our communication or relationship, unless a shorter period is sufficient to resolve the request |
Advertisements are how We make money, and they allow Us to bring You new Games or improve existing ones to keep You entertained.
Ads shown in the Games are delivered by third-party advertising partners and/or TV platform operators. Retinmount does not create advertising profiles of players and does not perform behavioral advertising based on tracking of individuals.
Retinmount does not itself collect or store persistent identifiers such as IP address, MAC address, or device advertising identifiers for advertising purposes. Our advertising partners may process technical information on their own systems in order to deliver, measure, and prevent fraud in advertising, in accordance with their own privacy policies and legal obligations.
Legal reason: legitimate interest in funding free Games through advertising.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Advertising delivery and measurement (contextual) | Limited technical information necessary to display and measure ads (processed mainly by advertising partners); Retinmount may receive aggregated reporting (e.g. ad success events) via analytics | legitimate interest | For the duration necessary to deliver and measure ads and to operate the Games |
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 limited technical and statistical data about the Games as You play them. This helps Us to develop Games that Your device will run without problems and to improve stability and user experience.
We do so based on Our legitimate interest in improving Our Games.
| Sub-activities | Scope of processed data | Legal reason | Duration of processing |
|---|---|---|---|
| Development and improvement of games, optimization | Technical and analytics data (aggregated usage statistics, device/platform info, game version, performance events) | legitimate interest | For as long as necessary to maintain and improve the Games (analytics retention is configured within the analytics service) |
In order to offer and provide You with the Games, certain third parties may process data as described below:
| Processors / Recipients | Reasons for disclosure |
|---|---|
| Analytics provider | We use Google Analytics 4 to obtain aggregated usage statistics and improve the Games. |
| Advertising providers / TV platform operators | Ads are delivered and measured by third-party partners. They may process technical data on their own systems in accordance with their own privacy policies. |
| Public authorities (courts, prosecutors, state and local government authorities, etc.) | We disclose data where required by law or necessary to protect or enforce Our rights. |
We are a company from the Czech Republic and many of Our service providers are located in the European Union. However, We operate the Games globally and some service providers (such as analytics or advertising partners) may process data outside the European Union or the European Economic Area.
If We transfer personal data to a third country or an international organisation, We do so only where appropriate safeguards are in place under applicable data-protection law (for example, adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms).
All data is processed automatically.
Under applicable data-protection law, You may have certain rights in relation to personal data. Retinmount processes only limited pseudonymous technical analytics data and accesses such data solely in aggregated statistical form. Retinmount does not maintain datasets that identify individual users.
Because Retinmount cannot identify individual users from the aggregated analytics information available to Us, some rights (such as access, rectification, or portability) may be limited in practice. Where requests relate to data processed by third-party analytics or advertising providers, We may direct You to those providers.
To exercise any rights that may apply, You may contact Us using the contact details set out at the beginning of this Policy. We reserve the right to reasonably verify the identity of the applicant where applicable.
Our Games are general-audience entertainment and are not directed to children under the age of 13. We do not knowingly collect personal information from children. The Games can be played without providing personal information such as name, email address, phone number or precise location.
We do not perform behavioral advertising and we do not create profiles of players, including children.
Because We do not knowingly collect personal information from children beyond limited pseudonymous technical analytics used only in aggregated form, verifiable parental consent is not required.
COPPA notice (U.S.). The Games are not directed to children under 13 and Retinmount does not knowingly collect “personal information” from children as defined by the U.S. Children’s Online Privacy Protection Act (COPPA). Because the Games do not collect personal information from children (the Games can be used without accounts and without providing name, email, phone number or precise location) and Retinmount only processes aggregated technical analytics that does not identify individual users, Retinmount does not request or obtain verifiable parental consent under COPPA. If a parent or guardian believes a child has provided personal information directly to Retinmount (for example by email), please contact Us at [email protected] and We will delete it.
Retinmount designs the Games so that they can be used without providing directly identifiable personal information and without creating user accounts or storing user-level records. Retinmount does not maintain databases containing personal identifiers of players.
Limited technical and analytics information used to operate and improve the Games is processed primarily by trusted third-party service providers (such as analytics and advertising partners) on their own secure systems in accordance with their security and data-protection practices.
Retinmount applies reasonable technical and organisational measures to protect its own systems and aggregated analytics data against unauthorised access, alteration, disclosure or loss. Because Retinmount only accesses data in aggregated statistical form and does not hold identifiable user datasets, the risk to individual users is inherently limited.
If You believe You have discovered a security issue related to the Games, You may notify Us using the contact details provided in this Policy.
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.