PLAYNETIC MALTA LTD

12th December 2023

1. Introduction

Playnetic Malta Ltd, whose registered office is at Elite Business Centre, Trejqa ta’ Box Box, Msida MSD 1840, Malta, and its affiliates (“Playnetic,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website www.playnetic.com (the “Website”) and social media services and other products and services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“User(s)” or “you”).

By using our Services, you acknowledge Playnetic will process your Personal Data in accordance with this Privacy Policy, including for the purposes set out in paragraph 3 below. If you do not wish to provide your Personal Data on the basis set out in this Privacy Policy, you should not provide the relevant information on the Website forms, or otherwise provide us with any of your Personal Data. However, if you do not provide your Personal Data, we may not be able to support you with respect to your queries.

 

2. Information We Collect

As part of providing our Services, we may collect a variety of personal information from or about you or your devices from various sources, as described below. You agree that you will only provide information to us that is accurate, complete and up-to-date, and that you will notify us of any changes to your information.

Personal Information that we collect from you are the following:

• Name and Surname
• Email Address
• Company Name
• Contact Phone number

(collectively, the “Personal Data”)

We collect Personal Data from you which you provide us, when you register interest that we communicate with you to provide more information about our Services, and/or you show interest in our vacancies and require us to contact you, and/or about your use of our Services.   

 

3. How We Use Personal Data

In accordance with data protection laws, we will only process your information where we have a lawful basis for doing so. In respect of your information, these bases are:

• On Contact enquiry form, if you wish that we contact you to provide information about our Services;
• On Careers page: if you are interested in working with us. For the purposes of Careers, please visit https://careers.playnetic.com. Please note that there is a supplementary privacy policy in our Careers page (the “Careers Privacy Policy”) and the Careers Privacy Policy is subject to this Privacy Policy, and forms an integral part thereof. In the event of a conflict or inconsistency between the terms of this Privacy Policy and the Careers Privacy Policy, the terms of the Careers Privacy Policy shall prevail with respect to the subject matter thereof.
• To provide you with information about, and support for, our Services, including changes to our Services, technical updates to our Services, and changes to the terms (including this Privacy Policy).
• To provide you with marketing materials, only where you have provided your consent.  

The following are a list of the “Purposes” for which we (including any of our agents, group members, sub-contractors and/or employees) process your information, and the lawful basis on which we carry out such processing:

 

Purpose	Lawful Basis	Retention Period	Geographical locations where data is processed
Contact Enquiry Form: To use your Personal Data in order to contact you and provide you with information about our Services	Consent	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
Careers Page: To allow job applications to open roles within Playnetic.	Consent	Please see Careers Privacy Policy	EEA and UK
To provide you with information about, and support for, our Services, including changes to our Services, technical updates to our Services, and changes to the Terms (including this Privacy Policy)	Necessary for the performance of a contact and necessary to comply with a legal or regulatory obligation	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes	Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in, and Consent	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
To keep you informed of offers and promotions relating to our Services and those of other entities within our group, provided that you don’t “opt-out” from this option	Legitimate interests so we can send you information about our Services (and promotions and offers) that you may be interested in, and Consent.	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
To keep you informed of offers and promotions for which you have specifically opted-in	Consent	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
For general marketing purposes, but only where you have provided your express and informed consent	Consent	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK
To support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your personal information	Necessary for the performance of a contract	6 months, or earlier if User does no longer wish to be contacted.	EEA and UK

If at any time you wish us to stop processing your information for the above Purposes, you should contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your account will be closed.

 

4. How We Share the Information We Collect

Analytics Partners. We use analytics services to collect and process certain analytics data.. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

There may be other third parties collecting analytics data from you depending on the platform you access our Services from.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement or regulatory requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Corporate Group. We may transfer your information to any company within our group (including to their employees and/or sub-contractors) which assists us in providing our Services or which otherwise has a need to know such information, in accordance with applicable law.

Consent. We may also disclose your information with your permission.

 

5. Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.

 

6. Third Parties
   

Our Services may contain links to other websites, products, or services that we do not own or operate.  We are not responsible or liable for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

 

7. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information that we collect.

All the information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the information can.  All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.

Where your information needs to be disclosed to our service providers and/or subcontractors, we require them to process and protect your information in a manner consistent with this Privacy Policy, our security policies and applicable laws.

 

8. Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Services are directed to children. Legally you must be at least 18 years old to use the Services (but this might be older depending on whether or not a particular Service has a required minimum age rating) as per our Terms of Service. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

 

9. Data Transfers outside the EEA

Your information will not be transferred outside of the European Economic Area or UK, and will be transferred both to us and other members of our group. In the event we transfer your Personal Data outside the EEA and UK, we shall inform you accordingly.

 

10. EU Data Subject Rights

If you are based in the European Union, you have the following rights in relation to your information:

(i) a right to access your information as held by us (also known as a subject access request);

(ii) a right to receive certain information in machine-readable format;

(iii) a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your information where there are other relevant lawful bases or where we have compelling grounds to continue processing your information in our interests which are not overridden by your rights, interests or freedoms;

(iv) a right to have inaccurate information rectified;

(v) a right to have certain information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph (viii), where you have objected pursuant to paragraph (iii), where your information has been unlawfully processed, or where erasing your information is required in accordance with a legal obligation;

(vi) a right to request an explanation of the logic involved where we make decisions about you solely through automated means;

(vii) a right to complain to your national data protection regulator;

(viii) where we have specifically requested your consent to process your information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and

(ix) a right to object to direct marketing, which can be done by opting-out of direct marketing either through email or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

If you are unsure about your rights or are concerned about how your information may be processed, you should contact your national data protection regulator.

We have appointed a data protection officer (DPO) who is responsible for all requests relating to the privacy of your information. If you would like to exercise any of your rights then you can do so by contacting us at [email protected]. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request. If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

 

11. Retention of your information

We will retain your information for the period necessary for us to provide you with our Services. Accordingly, please refer to paragraph 3 for the retention periods. Where it is no longer necessary for us to process your information, we will delete it. Please note, however, that we may be subject to legal and regulatory requirements to keep personal data for a longer period, in particular pursuant to any applicable statutory limitation period.

 

12. Changes to this Privacy Policy

Our company keeps its privacy policy under regular review and places any updates on this page and the revised version will be effective when it is posted. Please take a look at the “LAST UPDATED” date at the top of this page to see when this privacy policy was last revised; this privacy policy was last updated on 8^th December, 2023. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication. If you do not agree to the new version, you must stop using the Services completely – in order to make the Services work properly we need to have everyone using them under the same rules instead of different people having different rules.

 

13. Cookies

When you use the Services, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the user’s device, such as computer, mobile phone or tablet, when using the Services. We use cookies to improve your usage of the Services and to gather information about, for example, statistics about the usage of the Services. This is done to secure, maintain and improve the Services. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy https://careers.playnetic.com/cookie-policy .

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Services, for example disabling some functions thereof.

 

14. Contact Information

If you have any questions, comments, complaints or concerns about our processing activities, please email us at [email protected].

Should you wish to report a complaint or if you feel that Our company has not addressed your concern in a satisfactory manner, if you are an EEA citizen, you may contact the Office of the Commissioner for Personal Data Protection http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/page1i_en/page1i_en?opendocument , and in case you are a non-EEA citizen, kindly contact the relevant Data Protection authority in your country.