DESARROLLO A MEDIDA SL Privacy Policy


Swamedida Ltd (“Swamedida”), its parent and its subsidiaries respect the privacy rights of our users and are committed to protecting the information collected through its online products, online services and websites including, but not limited to Swamedida’s Apps or games  (together “Services”). Swamedida has adopted this privacy policy (“Privacy Policy”) to explain how Swamedida collects, stores, and uses the information collected in connection with Swamedida’s Services.

Should you have any questions relating to this Privacy Policy, please contact us at privacy[a] www.swamedida.com or alternatively at DESARROLLO A MEDIDA SL, Legal Department, info[a]swamedida.com

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. Swamedida reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. If Swamedida makes material or significant changes to this Privacy Policy, Swamedida may post a notice on Swamedida’s website along with the updated Privacy Policy.  Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.


Non-personal data

For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Swamedida collects about the use of Swamedida Services, from which any personally identifiable data has been removed.

Swamedida may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Swamedida to identify you. The types of non-personal data Swamedida may collect and use include, but are not limited to:

(i) device properties, including, but not limited to IP address, Media Access Control (“MAC”) address and unique device identifier or other device identifier ("UDID").

(ii) device software platform and firmware.

(iii) mobile phone carrier.

(iv) geographical data such as zip code, area code and coarse location.

(v) game progress, score and achievements.

(vi) other non-personal data as reasonably required by Swamedida to enhance the Services and other Swamedida products and services.

Swamedida uses Google analytics tool in order to develop and analyze use of the Services. If you wish to opt-out from Google analytics, please follow this link: http://www.google.com/intl/en/policies/privacy/

Swamedida may use and disclose to Swamedida’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other Swamedida services and products.

You recognize and agree that the analytics companies utilized by Swamedida may combine the information collected with other information they have independently collected from other services or products relating to your activities. These companies collect and use information under their own privacy policies.


Ad Serving Technology

Swamedida reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Swamedida or Swamedida’s partners and contractors. Swamedida may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. Swamedida or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. Swamedida or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-game information. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

You recognize and agree that the advertising companies who deliver ads for Swamedida may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services. Although Swamedida takes commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, Swamedida does not have access to or control of third party technologies.


Location Data

To the extent Swamedida makes location enabled Services available and you use such Services, Swamedida may collect and process your location data to provide location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. Swamedida may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS location is not accessed without your consent. Notwithstanding Swamedida’s partners who are providing location related parts of the Service, Swamedida will not share your geo-location with third parties without your consent. To the extent Swamedida makes available geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that Swamedida may share your anonymous coarse location with its partners.


Personal Data

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual.

Likely situations when you make personal data available to Swamedida include, but are not limited to:

(i) registration for Services, contests and special events.

(ii) accessing Services using a third party ID, such as social networking sites or gaming services.

 (iii) subscribing to newsletters

 (iv) purchasing a product or services through Swamedida’s online stores.

 (v) using “tell a friend,” "email this page," or other similar features.

 (vi) requesting technical support; and (vii) otherwise through use of Swamedida Services where personal data is required for use and/or participation.

The types of personal data may vary depending on the type of activity you are engaged in. The personal data Swamedida may collect, process and use may include, but are not limited to your name, screen/nick name, Swamedida Services’ or third party service ID, e-mail address,If you choose to use Swamedida’s "tell a friend" or a similar service about Swamedida Services or order a gift certificate for your friend, Swamedida will store your friend's name and contact details that you provide to Swamedida.

Swamedida may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving) and to further develop the Services and other Swamedida services and products. Swamedida may combine non-personal data with personal data.

Swamedida may use your personal data to send messages to you with informative and/or commercial content about Swamedida’s services and services Swamedida thinks may be of interest to you, such as new features and services, special offers and updated information.

Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you.  In such cases, Swamedida may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to Swamedida.  This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. Swamedida may associate and/or combine as well as use information collected by Swamedida and/or obtained through such social networking sites in accordance with this Privacy Policy.


Disclosure and Transfer of Personal Data

Swamedida collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, Swamedida are not going to disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy.

Swamedida may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Swamedida to legal liability. Swamedida may also disclose your personal data to third parties when Swamedida has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Swamedida’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Swamedida believes that such disclosure is necessary to protect Swamedida’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Swamedida. To the extent permitted by applicable law, Swamedida will make reasonable efforts to notify you of such disclosure through Swamedida’s website or in another reasonable manner.


Data Retention and Correctness

Swamedida retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Swamedida deletes all aforementioned data in its possession within a reasonable timeframe. Swamedida does not verify the correctness of personal data.

Swamedida may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Swamedida user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.


Cookies, beacons and tracking

The Services may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Swamedida treats information collected by cookies and similar technologies as non-personal data.

Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user's computer. Swamedida’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” you. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.

Flash cookies & HTML5: Swamedida may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate. You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or visit www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.

Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image that allows Swamedida to count users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Swamedida sends to you may contain pixel tags that enables Swamedida to track your usage of the communication, including whether the communication was opened and/or what links were followed (if any).


Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. You recognize and agree that Swamedida is not liable for any such third party terms and conditions and their use of your personal data.

Swamedida may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Swamedida. Swamedida is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Swamedida is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies.

Please note that certain Services that Swamedida may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID or gaming network account. When you register to join or use the Services from a third-party gaming or social networking system, certain personally identifiable user and/or membership data may be transferred automatically to and from Swamedida and you hereby consent to the processing, using, combining, disclosing and retaining of such data in accordance with this Privacy Policy by Swamedida.


Safeguards

Swamedida follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Swamedida’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Swamedida’s possession. Personal data collected by Swamedida is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Swamedida maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Swamedida’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.


Other

Please be aware of the open nature of certain social networking and other open features of the Services Swamedida may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Swamedida is not responsible for any personal data you choose to make public in any of these forums.

If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. Swamedida takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. Swamedida does not knowingly collect any personal information from children below the aforementioned age and if Swamedida learns that Swamedida has inadvertently gathered personal data from children under the aforementioned age, Swamedida will take reasonable measures to promptly erase such personal data from Swamedida’s records.

Swamedida does not store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. Swamedida may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Swamedida’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.


Further information

Pursuant to Section 26, SpanishPersonal Data Act (15/1999), the data controller is DESARROLLO A MEDIDA SL, address Pza San Cristobal,14, Alicante,Spain. The name of the personal data file is “Swamedida Services’ Data File”. Any and all use of your personal data by Swamedida is governed by Finnish law and not the laws where you may be located.

Should you wish opt-out from receiving communications (such as newsletters or offers) from Swamedida, please contact info[a]Swamedida.com.

Swamedida makes good faith efforts to enable you to review, update, correct or delete your personal data in Swamedida’s possession. In order to do so, please contact Swamedida at privacy[a]Swamedida.com. Swamedida will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.  Requests will be processed as soon as possible. Please note that even if personal data is changed or deleted according to your request, Swamedida may still retain some of your personal data to resolve disputes, enforce Swamedida user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of Swamedida Services.

Swamedida regularly reviews its compliance with this Privacy Policy. If Swamedida receives a formal written complaint from you, it is Swamedida’s policy to attempt to contact you directly to address any of your concerns. Swamedida will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and Swamedida. TO THE EXTENT YOU AND Swamedida ARE NOT ABLE TO AMICABLY RESOLVE ANY DISPUTE THAT MAY ARISE, YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST Swamedida ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.