BACKGROUND
Goals AB, reg. no. 559313-9750, with its main offices at Nybrogatan 55, 114 40 Stockholm, Sweden ("Goals”, “GOALS", "We", "Us", or "Our") create original and memorable experiences for players to enjoy through GOALS' software, games, games services, and digital content, as well as all GOALS' related websites, forums, chat rooms, accounts, apps, and any other services GOALS provide and any other materials included with the software (the "Product").
GOALS collect your personal data (the "Data") so that you can benefit from the Product and in order for GOALS to provide you with customer support. This privacy policy (the "Policy") is designed to help you understand how GOALS collect, use, and retain your Data and to inform you of your rights and how to exercise them. Additionally, GOALS use cookies on GOALS' website (the "Cookies"). Please see applicable Sections of this Policy and GOALS' cookie policy (the "Cookie Policy") for more information about the Cookies GOALS use.
GOALS value your privacy. It is therefore very important to GOALS that you understand this Policy and how and why GOALS process your Data. Please do not hesitate to contact GOALS should you have any questions.
1. WHAT DATA IS COLLECTED?
Data is all information that identifies you, either directly, for example, your last name, first name, email address or telephone number, or indirectly, for example your account ID, IP address, cookie identifier or game data. Processing of Data is a reference to what GOALS do with your Data, for example collection, use, structuring, storing, and erasure of Data. For more information about the Data that GOALS collect, see Section 5 below.
2. ACCESSIBILITY TO THE PRODUCT
The age at which minors can create a GOALS Account or have access to some of the Product depends on the Data protection laws of each country. For more information, please see the section on the access for and terms specific to minors in end user license agreement (the "Agreement") of the Product:
3. GOALS' RESPONSIBILITY FOR COLLECTED DATA
Please note that this Policy describes the processing activities undertaken by GOALS in GOALS' capacity as data controller only. A data controller is essentially the company who is responsible for your Data. GOALS have detailed the processing activities that GOALS are responsible for below in Section 5. Please see below for some examples of Data in each category.
CATEGORY OF DATA // EXAMPLE OF DATA
- Name and contact information // Your name and email address.
- Information provided in free-text fields // Information you submit to GOALS via free text fields when You will be processed by GOALS. GOALS encourage You to always be cautious when providing GOALS information via free text fields, as information given to via free text fields may be processed automatically and that GOALS therefore will not be able to identify incorrect information or sensitive personal data you may have submitted by accident.
- User statistics // Game data and statistics. Data associated with bugs and malfunctions. Login and browsing Data. Information concerning the user's browser and operating system.
- User information // Date of birth, gender, IP address, geographic region and city.
- Consumer relation administration information // Image and audio. Console identifier and Product registered on users' GOALS Account
4. HOW LONG DOES GOALS KEEP YOUR DATA?
4.1 Unless the law specifies a different retention period, GOALS will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected by GOALS.
4.2 For example, GOALS will keep the Data associated with your GOALS Account until the termination of the GOALS Account. In some cases, the Data may be kept for a longer period such as when it is needed for GOALS to apply a sanction.
4.3 For your convenience, GOALS have listed all of GOALS' retention periods in the table below, see Section 5.
5. WHEN AND WHY GOALS COLLECTS DATA AND THE TYPE OF DATA COLLECTED
5.1 GOALS may collect Data in various situations. Below is examples of situations where GOALS may collect user Data.
a) You Create a GOALS Account
GOALS collect your user name, password, and email address. Some items of Data, such as your user name, are made public to allow your community to find you in the Product. When you create your GOALS account ("GOALS Account"), you can manage your Account via your Account's management page.
b) You Use GOALS' Product on a Personal Computer
GOALS collects your game data andadditional data about you to improve your experience and the security of the Product such as achieved game levels, rewards, rankings, completed game missions, statistics including the game time or the use of the various features as well as the Data associated with any bugs and malfunctions. GOALS collect your login and browsing Data, to enable the operation and security of GOALS' Product, such as: visited pages, identifier of your device and the connection (IP address, MAC address), login dates and times, information concerning the browser and the operating system you use. GOALS use various types of technologies such as Cookies to collect such categories of Data when you use GOALS' Product or visit a third party site where GOALS and GOALS'partners provide content or carry out content use analysis. GOALS allow some of GOALS'partners to set and access their Cookies on your device. These partners’ use of Cookies is subject to their own privacy policies and not this Policy. To refuse Cookies or request their deletion as well as obtain the list of partners who are permitted to store and/or access these Cookies, please see the Cookies page. You can also adjust your browser settings to understand when these Cookies are stored on your device or to disable the Cookies by consulting your browser’s “Help” menu. Please note that these settings may affect your ability to access certain features of the Product whenever these Cookies are needed for the operation of the Product.
c) You Contact GOALS via the GOALS Customer Support
If you contact GOALS' customer support, GOALS collect Data such as your last name, first name, user name, email address, and the Product registered on your GOALS Account, depending on your questions or requests.
d) In Order to Comply with Legal Requirements
Your Data may be processed in order for GOALS to be able to comply with legal requirements, Data is necessary for GOALS to be able to comply with mandatory legal obligations.
e) You Do Not Comply With the Rules of the Game
When you use the Product, GOALS ask that you comply with the terms and conditions applicable to the Product and the codes of conduct associated with the Product that are intended to protect GOALS' users, employees, and more generally, GOALS' rights. If you do not abide by these rules, you may be sanctioned including in the event of inappropriate conduct, cheating or toxic behaviour. GOALS will keep your Data for the time needed to apply these sanctions. This Data may include for example your GOALS Account identifier, your game data, your IP address, the identifier of your device and your chat history. GOALS' legitimate interest is based on GOALS' need to investigating suspicious activity and/or that of a third party to investigate suspicious activity is considered.
5.2 GOALS may process your Data on the basis of different legal grounds and store your Data for different periods of time and for various purposes. For your convenience, GOALS have summarized these grounds, time periods, and purposes below.
PURPOSE // CATEGORY OF DATA // LEGAL GROUNDS // STORAGE PERIOD
- To allow the user to create a GOALS Account. // Username. Name and contact information. // Performance of contract (Article 6.1(f) GDPR). The processing is necessary to fulfil GOALS' contractual obligations with the user. // For as long as the user has a GOALS Account.
- To allow the user to use GOALS' Product on a personal computer. // User statistics. User information. // Performance of contract (Article 6.1(f) GDPR). The processing is necessary to fulfil GOALS' contractual obligations with the customer. // For the duration the user uses GOALS' Product.
- To provide you with customer support or additional important information about GOALS and the Product. // Name and contact information. IP address and Product registered on users' GOALS Account. Information provided in free text fields. // Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil GOALS' legitimate interest in conducting GOALS' business and responding to your inquiry, which GOALS have determined outweighs your interest not to have your Data processed for this purpose. // For the duration of the relationship with you.
- To administer customer relationships, including managing your GOALS Account. // Name and contact information. Device information. Consumer relation administration information. IP address and Product registered on users' GOALS Account. Information provided in free-text fields. // Performance of contract (Article 6.1(f) GDPR). The processing is necessary to fulfil GOALS' contractual obligations with the customer. // For the duration of the customer relationship.
- To view, review, and respond to queries you submit to Us. // Name and contact information. Information provided in free-text fields. // Performance of contract (Article 6.1(b) GDPR). The processing is necessary to fulfil GOALS' contractual obligations with the customer. // Until GOALS have resolved your query.
- To comply with a legal obligation, for example to provide information to public authorities where GOALS are required to do so by law. // Name and contact information. Device information. Information provided in free-text fields. // Compliance with legal obligations (article 6.1(c) GDPR). The processing is necessary to comply with GOALS' legal obligations. // For as long as GOALS are required pursuant to applicable law, or otherwise in accordance with GOALS' retention periods set forth in this policy (depending on which processing activity that is applicable).
- To defend ourselves against any legal claim. // Name and contact information. Device information. Information provided in free text fields. // Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil GOALS' legitimate interest in defending GOALS' business against legal claims, which GOALS have determined overweighs your interest not to have your Data processed for this purpose. // For as long as GOALS are required pursuant to applicable law, or otherwise in accordance with GOALS' retention periods set forth in this policy (depending on the applicable processing activity).
6. HOW AND WITH WHOM GOALS MAY SHARE YOUR DATA
6.1 GOALS will always ensure that third parties can provide sufficient guarantees in protecting your Data before GOALS share any of your Data. GOALS have listed the categories of third parties with whom GOALS may share your Data below.
6.2 GOALS may share your Data with the following entities:
a) GOALS Subsidiaries Involved in the Administration of the Product and Technical Service Providers Involved in the Supply of the Product
In order to provide, and for the sole purpose of providing, GOALS' services and the Product to you, GOALS may need to share your Data with certain carefully selected suppliers and contractors. Such suppliers and contractors could be consultants or providers of legal, technical, IT support/functions, and storage providers (such as cloud storage) as well as involved with delivery and/or promotion of the Product, and bulwarks to act against inappropriate conduct, cheating and toxic behaviour. They will only process your Data based on GOALS' instructions to them, and GOALS will always ensure that the necessary agreements (for example so-called data processing agreements) are in place to protect your Data at all times. Such technical service providers cannot act independently and have no right to share Data. These technical service providers and subsidiaries include providers of cloud services used to run backend API and game servers, message queuing systems, collect telemetry, and storage of game and user date. The legal ground is GOALS' legitimate interest in conducting GOALS' business by accessing these services and functions, which GOALS have determined outweighs your interest not to have your Data processed for this purpose.
b) Mergers and Acquisitions
GOALS may need to share your Data for the purposes of selling GOALS, or all or parts of GOALS' assets, to a potential buyer who wishes to acquire the same, or if GOALS are otherwise subject to a merger with another company. The legal ground is GOALS' legitimate interest to complete such transactions, which GOALS have determined outweighs your interest no to have your Data processed for this purpose.
c) Public Authorities and Governmental Entities
GOALS may share your Data with public authorities when required by law to do so. The legal ground is to comply with a legal obligation.
7. WHERE GOALS PROCESS YOUR DATA
7.1 As a main rule, GOALS will only process your Data within the European Union and the European Economic Area (jointly, the "EU/EEA"). In some situations, for example when the services and functionalities GOALS need are provided outside of the EU/EEA, GOALS may need to transfer your Data outside of the EU/EEA.
7.2 Regardless of whether your Data is processed within or outside the EU/EEA, GOALS will at all times ensure that the same level of technical and organisational measures are in place to protect your Data. Should GOALS transfer your Data outside of the EU/EEA, GOALS will take additional appropriate measures to safeguard your Data, which may as a main rue include one of the following measures:
a) Transfer of Data only to countries that, according to the European Commission, provide an adequate level of protection. This means that those countries offer a similar level of protection as is provided under the GDPR in the EU/EEA.
b) GOALS will enter into standard contractual clauses adopted by the European Commission with the recipient of your Data. This means that the recipient is required to comply with the same level of protection as is provided under the GDPR in the EU/EEA.
7.3 In addition to the above measure, GOALS will always seek to take any additional security measures that GOALS deem necessary and appropriate in order to safeguard your Data at all times.
7.4 For information on as to how you may opt out of the sharing of your Data, please see Section 9 below.
8. COOKIES
GOALS use Cookies and other similar technologies to provide the Product to GOALS' users. For more information, please see applicable Sections in this Policy and GOALS' Cookie Policy:
9. YOUR RIGHTS AND HOW YOU EXERCISE THEM
9.1 You have rights with regards to your Data. Please read this Section 9 to understand them, as well as how you can exercise them. You are always welcome to contact GOALS if you need more information about your rights. You can also read more about your rights on the Swedish Authority for Privacy Protection's (Sw. Integritetsskyddsmyndigheten) ("IMY") website:
9.2 If and when GOALS process your Data, you have certain rights. Below is a list of these rights, what they mean to you, and how you may exercise them.
9.3 Right to Information
You have the right to be informed about how GOALS process your Data. GOALS respect this right by being transparent with you in GOALS' communication and on GOALS' website, and providing you with the information in this Policy.
9.4 Right of Access
You have the right to obtain a confirmation from GOALS as to whether or not GOALS process your Data, you also have the right to obtain access to the Data by requesting a copy showing which Data GOALS have about you, and how GOALS use it. Please note that GOALS may ask for additional information in order to identify you to ensure that Data is disclosed to the correct individual.
9.5 Right to Rectification
You have the right to request that GOALS correct inaccurate information about you, as well as to complete any incomplete information.
9.6 Right of Erasure
You sometimes have the right to request the erasure of Data that concerns you. GOALS are required to eras the Data in question, for example if the Data is no longer necessary in relation to the purpose for which the Data was initially collected. Please note that GOALS are not obligated to delete your Data if it is necessary to retain it in order to comply with legal obligations, or for the establishment, exercise, or deference of legal claims.
9.7 Right to Restriction of Processing
You have the right to request that GOALS restrict GOALS' processing of your Data if you for example believe that the information new have about you is inaccurate, GOALS' processing unlawful, or that GOALS no longer need the information for the purposes for which they were collected.
9.8 Right to Object
You have the right to object to GOALS' processing of your Data if GOALS' processing is based In a legitimate interest. You always have the right to object to GOALS' processing of your Data for direct marketing purposes.
9.9 Right to Data Portability
You have the right to request a copy of the Data in a machine-readable format that concerns you and which GOALS process to perform a contract or based on tour consent. You can then have such Data transmitted to a different data controller.
9.10 Right to Withdraw Consent
You have the right to withdraw your consent at any time. If you have questions related to a specific processing activity or wish to withdraw your consent, please write to GOALS on via the contact information provided in Section 12 below.
9.11 Right to Lodge a Complaint
If you have any complaints about the way in which GOALS process your Data, you are always welcome to contact Us. You also have the right to lodge a complaint to a supervisory authority, via the contact details provided in Section 12 below.
10. CHANGES TO THIS POLICY
GOALS reserve the right to introduce updates and make amendments to this Policy. This is necessary to ensure that GOALS have the ability to constantly improve GOALS' services to you and to introduce new functionalities. GOALS may also be required to make changes to the way in which GOALS process your Data pursuant to applicable laws or a decision by public authority or court of law. GOALS will inform you of the material updates and, if GOALS make changes to the Policy, change the "Last updated" date at the top of this Policy, and recommend that you consult this Policy on a regular basis or contact GOALS if you have any questions. Using GOALS' Product following such a change means that you accept any changes made to this Policy.
11. SECURITY
11. 1 GOALS take the protection of Data seriously. GOALS have reasonable and appropriate technical and organisational measures in place throughout GOALS' business to ensure that your Data is safeguarded and protected against loss, destruction, abuse, unauthorized access, and disclosure at all times.
11.2 Our employees work under strict confidentiality and follow clear instructions as to how to manage your Data in accordance with applicable data protection laws and GOALS' own policies. GOALS only grant employee access to your Data when It is necessary in order for them to perform their duties.
11.3 GOALS continuously evaluate GOALS' security measures to remedy any vulnerabilities GOALS may identify in an effort to make sure that your Data is safe with us. Please note that, although GOALS strive towards maintaining a reasonable level of security for Data, no security system can prevent all potential security violations.
12. CONTACT
12.1 If you have any questions about this document or GOALS' processing of your Data, or if you want to exercise your rights following on the above, please contact GOALS' data protection officer through any of the means listed below. GOALS shall, no later than one month after having received your request to exercise your rights, inform you about the steps undertaken in relation to your request, unless this one-month period is extended by GOALS. The one-month period may be extended, if need be, by an additional two months. GOALS shall inform you about such extension no later than one month after having received your request as well as motivate why such extension is necessary.
a) Electronically:
Email: policy@playgoals.com
b) Via mail:
GOALS AB
Nybrogatan 55
114 40 Stockholm
Sweden
12.2 For any other questions, including questions relating to the hacking of your GOALS Account, a problem with online payment, or the use of GOALS' Product, please contact GOALS' Customer Support.
12. 3 You may also contact IMY to file a complaint, following which IMY may initiate a review of GOALS, if you consider GOALS' processing of Data to violate applicable laws. IMY can be reached at:
a) Electronically:
b) Via mail:
Integritetsskyddsmyndigheten
Drottninggatan 29 plan 5, Box 8114
114 20 Stockhom
Sweden