1. Categories of individuals that this information notice concerns
The purpose of this policy is to gather in one place information about how personal data are processed by the Huuuge Group companies.
This information notice is addressed to the following categories of persons:
- persons who want to cooperate with us or are representatives of our business partners (including our service providers, advertising networks, independent game developers),
- persons who want to communicate with us,
- persons who are willing to participate in our events (for instance conferences, lectures, competitions) or are addressees of other marketing activities.
2. Huuuge Group companies
Huuuge Group consists of the following companies (please note that this list may be amended from time to time):
- Huuuge Global Limited with its registered seat in Larnaca, Cyprus
address: Huuuge Global Ltd. 61 Lourdou Vyronos Street, Lumiel Building 4th Floor, Larnaca 6023, Cyprus
- Huuuge Games sp. z o.o. with its registered seat in Szczecin, Poland
address: Storrady Świętosławy 1A/501, 71-602 Szczecin, Poland
- Huuuge Digital Ltd. with its registered seat in Tel Aviv, Israel
address: Derech Hashalom 8, Tel Aviv, 6789210 Israel
- Huuuge, Inc. with its registered seat in Dover, Delaware, U.S.A.
address: 850 New Burton Road, Suite 201, Dover, DE 19904, U.S.A.
post address: 2300 W. Sahara Ave., Suite 680, Mailbox 32, Las Vegas, Nevada 89102, U.S.A.
- Double Star Oy with its registered seat in Vantaa, Finland
address: Itämerentori 2, 00180 Helsinki, Finland
- Playable Platform B.V. with its registered seat in Amsterdam, the Netherlands
address: Nieuwezijds Voorburgwal 118 E, 1012SH Amsterdam, the Netherlands
- Coffee Break Games HGL Ltd. with its registered seat in Larnaca, Cyprus
address: 61 Lourdou Vyronos Street, Lumiel Building 4th Floor, Larnaca 6023, Cyprus
- Huuuge Publishing Ltd. with its registered seat in Larnaca, Cyprus
address: 61 Lourdou Vyronos Street, Lumiel Building 4th Floor, Larnaca 6023, Cyprus
- Huuuge UK Ltd. with its registered seat in London, United Kingdom
address: 7 Savoy Court, London WC2R 0EX, United Kingdom.
3. Personal Data Controller and Data Protection Officer
Your personal data controller is one of the Huuuge Group companies listed above that interacts with you. In particular, it is a company with which you sign a contract, to which you address your letter or e-mail or which is organizing an event or other marketing activities you are interested in (hereinafter: “Controller”). If you have doubts as regards the exact company of Huuuge Group that is the Controller of your data, please kindly contact us.
Within Huuuge Group there is appointed a Data Protection Officer (the “DPO”) who is the person responsible for all matters related to data protection and privacy matters. The DPO is the designated contact for data protection issues for all the companies of the Huuuge Group. In case you have any questions regarding our processing of your personal data or if you would like to exercise any of your rights as a data subject under the General Data Protection Regulation (the “GDPR”), you can reach our DPO at the following address:
ATTN: Data Protection Officer
Huuuge Games sp. z o.o.
Storrady Świętosławy 1/501, 71-602 Szczecin, Poland
4. Personal data processing
The Huuuge Group companies which are based in the EU apply personal data protection standards described in this notice regardless of whether you are located in or outside of the European Union or European Economic Area. The Huuuge Group companies which registered seats are located outside the European Economic Area ensure that processing of personal data entrusted to them is in compliance with applicable laws and where applicable, these companies also apply GDPR provisions.
Persons contacting Huuuge Group
The aim of personal data processing is to communicate with persons contacting a particular company of the Huuuge Group (the Controller). The legal basis for personal data processing is the legitimate interest of the Controller or third parties which allows to:
- communicate with the person contacting the Controller,
- initiate relationships with persons contacting the Controller,
- providing the requested or otherwise necessary information to such a person.
Personal data processed are usually your name, surname, e-mail address, telephone number, correspondence address and other information provided by you within the course of communication, in particular in the contact form available on the Huuuge Group’s websites.
Providing your personal data is voluntary, however, if you fail to provide all the details significant in specific circumstances, the communication process may be hindered or impossible to conduct.
Data storing period: as long as necessary to pursue the legitimate interest of the Controller or a third party.
Contractors and representatives of contractors
The aim of personal data processing is conclusion and/or implementation of the agreement and maintaining relationships with our contractors, i.e. service providers and business partners (in particular advertising networks, independent app/game developers and users of the Huuuge Marketplace).
The processing of personal data of contractors and persons appointed by them (including their employees and business associates) takes place in order to conclude or perform an agreement or on the basis of a legitimate interest of the Controller or third parties, i.e. facilitation of communication and maintenance of relations with the contractor and performance of the agreement. Huuuge will also process personal data in order to fulfil its legal obligations stemming from applicable law, including provisions on tax and accounting.
We usually process the following personal data concerning our contractors or their contacting persons: name, surname, e-mail address, telephone number, workplace, position, business activity address, tax identification number, statistical number, personal number, bank account details and other particulars necessary to enter into and/or perform the agreement and maintain relations with contractors. Personal data collected form our contractors/their representatives may vary depending on the requirements of applicable legal frameworks.
Providing personal data may be indispensable in order to maintain a relationship or conclude/implement an agreement, when a given relationship already exists (or if the agreement is concluded) with a natural person. The consequence of not providing data may be the inability to maintain a relationship or conclude/implement an agreement. As regards persons who represent a legal entity, providing their data is not necessary, however, it makes contact with the Controller possible.
Data storing period: the term of the agreement made with the contractor and the period necessary to facilitate the seeking by the parties of claims arising from such agreement, not shorter, however than for a period arising from provisions of law or as long as necessary to pursue a legitimate interest of the Controller or a third party.
Marketing and PR activities
Huuuge Group companies are engaged in activities which aim at promoting the Huuuge brand. In particular, we may process your personal data when exercising the following:
- marketing and PR related communication including offers and invitations;
- organizing or co-organizing events (including conferences, lectures, competitions).
The legal basis for personal data processing is your consent or our legitimate interest i.e. conducting marketing activities, maintaining relationships with you, enabling you to participate in our events and providing you with necessary information. Sometimes we will also need your personal data for the purposes of concluding a contract with you.
In most cases we will be processing data such as your name, surname, e-mail address, telephone number, workplace, position, business activity address. We may also process personal data such as your image or shirt size. Depending on the circumstances, we may also process other categories of personal data. You may acquire information on personal data processed for the purposes of a particular event by reading its terms and conditions or/and by contacting the Huuuge Group company which acts as an organizer of a particular event.
Providing personal data is voluntary, however, in some cases it may be indispensable, for instance in order to make it possible to communicate with you or to enable you to participate in our events. The consequence of not providing data may be the inability to communicate with you or to enable you to participate in our events.
Data storing period: until the consent is withdrawn, as long as a contract is in force, not shorter, however than for a period arising from provisions of law or as long as necessary to pursue a legitimate interest of the Controller or a third party.
5. Personal data sharing
If it occurs that we are legally obliged to do so, we may provide your personal data to entities and public bodies authorized to process such data on the basis of legal regulations (for instance courts, prosecutor’s office). When necessary, we may share your personal data when a need to protect the rights or property of Huuuge Group or applicable third parties occurs.
Your personal data may be also transferred to other companies within the Huuuge Group, their affiliates and their contractors. Please note that all companies of the Huuuge Group (and their contractors) ensure appropriate safety measures regarding your personal data.
As we process tremendous amounts of information, we need assistance of our contractors (business partners and service providers) in order to maintain our business operations. Consequently, we may share your personal data with other entities who support us in conducting activities, in particular advisors, IT service providers, marketing service providers), services in the scope of archiving and destruction of documents, finance and accounting services and insurance services.
As a safeguard to protect your privacy, we arranged:
- data processing agreements with our support partners who act as our processors or,
- sharing personal data agreements/clauses, where our partner is also a data controller of your personal data,
where we ensure that your personal information is only used in accordance with our instructions and with the initial purpose of processing your data, and that the use by the third party is in accordance with the applicable law requirements or our contractual arrangements.
6. Transfer of data outside the European Economic Area (EEA)
Your personal data will be transferred to third countries situated outside the European Economic Area. Such transfer shall take place in accordance with the binding regulations regarding the protection of personal data, in particular on the basis of adequacy decisions or model contractual clauses adopted by the European Commission. Alternatively, we can also transfer data to the entities that are bound by binding corporate rules within their capital group, which are approved by the data protection authorities and grant the respective level of security even when outside the EEA.
You can direct any requests, questions or concerns regarding Huuuge’s handling of safeguards of the transfer outside the EEA to our DPO, whose contact details are given in the point 3 above.
7. Rights of the data subjects
In connection with personal data processing, the persons whose data are processed shall have the right to (respectively):
- demand that the Controller provides access to the personal data being processed,
- demand that the Controller rectifies the personal data being processed,
- demand that the Controller erases the personal data being processed,
- demand that the Controller restrictions the processing of personal data
- object to the processing of personal data,
- portability of personal data,
- withdraw his or her consent for the processing of personal data, whereas its withdrawal shall not affect the legality of processing executed on the basis of such consent before its withdrawal.
Please note that the rights under the GDPR are not unconditional. Therefore, an attempt to invoke any of the rights might not lead to an action. We have to analyse first whether it is admissible to exercise your request.
You also have the right to lodge a complaint with the data protection supervisory authority. We encourage you, however, to always contact us first when you have any problems or doubts regarding the personal data processing by us.
8. Source of obtaining personal data
If we did not receive personal data directly from you, it shall mean that we acquired them from the entity you are representing or you work for, from another company of the Huuuge Group or their contractors, or from publicly available sources (Internet).
9. Updates to the information notice
This notice is subject to updates. The current notice shall each time be published at the website.