Playsense Privacy Policy

This Privacy Policy has been prepared to help you understand how we collect your personal data and how we use it. This Privacy Policy also describes your options when it comes to your personal data as well as your rights.

Who is responsible for processing your personal data, and who you can contact in this regard

This website https://playsense.agency/ is provided by Playsense Limited (“we”, “our” or “us”). We are the controller of personal data obtained via the website, meaning that we are the organization legally responsible for deciding how and for what purposes it is used. If you have any questions or want more details about how we use personal information, you can contact our Data Protection Officer at 10 Spyrou Kuprianou, Flat G1, 4001 Limassol ,Cyprus, or via email: dpo@playsense.agency

By using our website you consent to the processing of your personal data in accordance with this Privacy Policy.

What data do we collect and how?

We try to minimize the personal data we collect about you, however, by using our website we may collect and process some of your personal data (“Personal Data” or “data” or “information”) as per below and in the following ways:

How we use your personal data and on which legal bases?

We process personal data for the purposes set out below:

It is necessary to pursue our legitimate interests for the purposes:

We process your personal data for the following legal bases:

You have the right to opt-out of at any time of receiving marketing communications by contacting us at dpo@playsense.agency or using the “unsubscribe” link in emails.

How long do we keep your data?

We keep your personal data for as long as necessary, to fulfil the purposes we collected it for, unless a longer retention period is required or permitted by law. It shall be deleted when it no longer serves the purpose for processing or shall be anonymized and therefore will no longer constitute Personal Data

You have the right to delete your data; to request erasure. This enables you to instruct us to erase your personal data (known as the ‘right to be forgotten’). Once we have deleted or anonymized your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability. For your rights, see “What are your data protection rights” below.

The criteria used to determine our retention periods include:

The duration of the data storage depends on the statutory obligations and is generally no longer than ten (10) years. We delete personal data, except Marketing and Communications Data, after ninety (90) days. Marketing and Communications Data are deleted after one (1) year.

Who do we share your personal information with?

  • Storage: Personal Data is stored in the cloud centres of our third-party cloud centres service providers.
  • Sharing with our service providers and partners: We use certain service providers and partners to help us operate and improve our website. These service providers and partners assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care and marketing. These parties are bound by confidentiality and are limited in the way in which they can process, access, or store personal data based on our instructions.
  • With your consent or at your request: We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
  • Legal Requirement: We may also disclose personal data (to the extent that we have it) if we are required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements,(ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of individuals, or (v) protect against legal liability.

International transfers?

We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully using encryption method. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Personal Information of Minors

Our website is not intended for or targeted at children under the age of 16 and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16 please contact us at dpo@playsense.agency that we can delete the information promptly.

What are Cookies?

We use cookies to run our website. A “cookie” is a small file containing a string of characters that is sent to your web browser and uniquely identifies your browser.

Cookies help us collect information so we can better understand how you access and navigate our website. This information helps us develop and improve the design, layout, content, and function of our website. It also allows us to prevent fraud and improve our security.

We may also use cookies to track activity and click-through behavior to better understand your preferences and browsing habits and to provide a more personalized experience while visiting our website and for more personalized alerts

We use different types of cookies to run the website. You can view and manage cookies in your browser. 

You can be directed to our “Cookies Policy” for more information.

What are your data protection rights?

Under the General Data Protection Regulation (GDPR), you have certain rights regarding your personal data. These rights include:

  • Access to a copy of your personal data. The right to access and be provided with a copy of your personal data that we hold about you.
  • Correction (also known as rectification). The right to require us to correct any mistakes in your personal data;
  • Erasure (also known as the right to be forgotten). The right to require us to delete your personal data - in certain situations.
  • Restriction of use. The right to require us to restrict use of your personal data in certain circumstances, for instance, if you contest the accuracy of the data.
  • Data portability. The right to receive the personal data you provided to us in a structured, commonly used and machine-readable format and transmit that data to a third party - in certain situations.
  • To object to use. The right to object: (a) at any time to your personal data being used for direct marketing (including profiling); (b) in certain other situations to our continued use of your personal data, for instance, where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
  • Not to be subject to decisions without human involvement. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
  • The right to withdraw consents. If you have provided us with consent to use your personal data, you have a right to withdraw that consent easily at any time. You may withdraw consent by contacting us at dpo@playsense.agency. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

How to contact us?

If you have any questions about our privacy policy, the data we hold about you or you would like to exercise one of your data protection rights please do not hesitate to contact us at dpo@playsense.agency

You may also find it helpful to refer to the guidance from the https://www.dataprotection.gov.cy/ on your rights under the GDPR.

When contacting us please provide enough information to identify yourself and let us know which right(s) you want to exercise and the information to which your request relates.

Please note that exercising some of these rights may impact our ability to provide our website experience to you. We will inform you of any such impact when you make a request to exercise your rights.

How you can complain to the appropriate authority?

Should you wish to report or if you feel that we have not addressed your concern is a satisfactory manner you may contact the Office of the Commissioner for Personal Data Protection https://www.dataprotection.gov.cy/

Changes to this Privacy Policy

We keep this privacy policy under regular review and places any updates on this web page.

Supplemental privacy notice and rights for USA residents

We may make changes to this Supplementary Privacy Notice so please refer from time to time to keep yourself informed of how we may collect, use, and disclose your personal information.

CALIFORNIA

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”). The below solely apply to California residents and supplement the information as relevant and contained in the Privacy Policy, above.

“Personal Information” means information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. Personal information does not include publicly available information from government records or de-identified or aggregated consumer information.

Rights

As a California resident, you have the following rights, subject to certain exceptions and limitations:

  • Right to know what personal information is collected (Right of Access)

You have the right to know and see what information we have collected about you over the past 12 months, including:

  • The categories of information we have collected about you;
  • The categories of sources from which the information is collected;
  • The business or commercial purpose for collecting your information;
  • The categories of third parties with whom we have shared your information; and
  • The specific pieces of information we have collected about you.
  • Right to Delete: You have the right to request we delete the personal information we have collected from you or maintain about you, subject to certain exceptions
  • Right to Access and Portability: You have the right to request we provide you with a copy of your personal information in a portable, readily reusable format that allows you to transmit the information to a third party.

When you make a request, we will confirm your verifiable request and attempt to fulfill the request subject to applicable exceptions as outlined in the law.

To exercise your right, please submit your request to dpo@playsense.agency.

We may request more information to be able to verify who you are and identify you in our system based on the information we currently have. 

If we do not get a verifiable request, which contains sufficient information to verify you and describes your request with sufficient detail, we may not be able to fulfill your request. We might also not be able to fulfill your request because we cannot identify you in our system or your personal information was already deleted or anonymized based on retention periods.

We will confirm we received your request within 10 business days from the date of receipt. We will verify the process for you and seek additional information if it is necessary. We may also ask that you provide us with an attestation that you are who you claim to be. We will process your request within 45 days of receipt. Should we require a time extension, we will inform you in writing. We will not discriminate against you for exercising your CCPA rights.

Use of Personal Information

For more information, please see “what data we collect and how we use it” section above.

Sale of Personal Information

We do not sell your personal information.

COLORADO, CONNECTICUT AND VIRGINIA

This Supplemental Privacy Notice only applies to our processing of personal information of personal data that is subject to the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) and the Connecticut Data Privacy Act (“CDPA”).

Rights

  • Right of Access: You have the right to request from us to confirm whether or not we are processing their personal data and to obtain a copy of the personal data that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
  • Right of Rectification: Depending on your area, you have the right to request that we correct inaccuracies in their personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.
  • Right of Erasure: You have the right to request that we delete the information we have collected from you.
  • Right to object / Right to opt-out: You have the right to “opt-out,” from targeted advertising to the sale of your personal data (if relevant), or depending on your state, to profiling in furtherance in decisions that produce legal or similarly significant events. To submit an opt-out request, please contact us at dpo@playsense.agency.
  • Non-Discrimination: In certain states, residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the US State Laws.
  • Right to Delete: You have the right to request we delete the personal information we have collected from you or maintain about you, subject to certain exceptions
  • Right to Access and Portability: You have the right to request we provide you with a copy of your personal information in a portable, readily reusable format that allows you to transmit the information to a third party.

Exercise your privacy rights.

To exercise your right, please submit your request to dpo@playsense.agency.We may request more information to be able to verify who you are and identify you in our system based on the information we currently have.

 If we do not get a verifiable request, which contains sufficient information to verify you and describes your request with sufficient detail, we may not be able to fulfill your request. We might also not be able to fulfill your request because we cannot identify you in our system or your personal information was already deleted or anonymized based on retention periods.

We will confirm we received your request within 10 business days from the date of receipt. We will verify the process for you and seek additional information if it is necessary. We may also ask that you provide us with an attestation that you are who you claim to be. We will process your request within 45 days of receipt. Should we require a time extension, we will inform you in writing.

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