DATA PROTECTION POLICY


Updated, 12 November 2018 at 11:00 GMT+1


GOTO GAMES commits to protecting all customer data of a personal nature and to ensuring that the highest level of protection is used for this purpose.

In order to provide its services, GOTO GAMES collects personal data from the visitors to its website GOTO GAMES and from those who use its applications.

GOTO GAMES, as data controller, commits to respecting the provisions of the EU regulation n°2016/679 of the 27th April 2016 regarding the protection of data of a personal nature (GDPR) and the modified law n°78-17 of the 6th January 1978.

1. IDENTITY OF THE DATA CONTROLLER

The company collecting personal data and enforcing the processing of the data is:
GOTO GAMES, Simplified Joint-Stock Company with a capital of 66,803€, registered with the Lille Métropole Trade and Companies Registry under the number 509.567.681, of which the head office is situated at 3 avenue Antoine Pinay 59510 HEM (France).

2. PURPOSE OF THE COLLECTION OF DATA AND LAWFUL BASIS

GOTO GAMES will ensure that it is using one or several of the following lawful bases for collecting data of a personal nature:
  • the execution of an agreement (e.g. for handling and sending an order, for making games available or for opening and managing a customer account), or;
  • the execution of a legal obligation (e.g. conservation of billing statements), or;
  • when it is in the legitimate interest of GOTO GAMES, or;
  • when a customer has given his consent to the collection of data.
The legitimate interest of GOTO GAMES must not go against the rights and liberties of its clients. Fraud prevention, direct marketing and data sharing within a group of companies feature among the examples of legitimate interests mentioned in the GDPR.

GOTO GAMES may be required to collect and process data personal to its clients in order to carry out the following processes:
Purpose of the process implemented by GOTO GAMES Lawful basis
• Managing the client’s account, shopping basket and orders and the provision of games • Fulfilment of the contract between a client and GOTO GAMES
• Managing payment transactions
• Managing the relationship with the client (telephone/email), order tracking, after-sales service and refunds
• Managing customer satisfaction (collecting opinions from customers about the products and the performance of customer service) • Legitimate interest of GOTO GAMES in order to improve the quality of service
• Statistical, analytical, selection and customer segmentation operations in order to improve knowledge about customers • Legitimate interest of GOTO GAMES to improve the knowledge about its customers
• The sending of targeted commercial offers by email, on social networks, on other Internet sites or any other media • Customer consent
• Legitimate interest for the sending of direct marketing in paper form
• Measuring visitation to the websites (mobile and desktop) and mobile applications • Customer consent
• The provision of sharing tools on social networks

3. PERSONAL RIGHTS

3.1. What are the rights that may be exercised?

In applying articles 15 to 22 of Regulation 2016/679 of the 27th April 2016, any individual whose data have been collected has the freedom to exercise the following rights:
  • The right to access
  • The right to rectify
  • The right to oppose the processing of his data or to have his data erased
  • The right to oppose profiling
  • The right to limit processing
  • The right to data portability

The Client can also formulate guidelines for the conservation, deletion and communication of his personal data after his death, in accordance with Article 40-1 of Law 78-17 of the 6th January 1978. These guidelines may be general or specific.

When GOTO GAMES detects a violation of personal data which is likely to present a heightened risk to the rights and liberties of the Client, the latter will be informed of this violation as soon as possible.

Finally, the Client has the power to rescind his consent at any time.

3.2. How can they be exercised?

These rights may be exercised by contacting the GOTO GAMES company, which has collected data of a personal nature, by the following means:
• Electronically, at this address: rgpd@gotobridge.com or rgpd@funbridge.com

The request should give the surname, given name, postal address, email address and, if possible, the reference number of the customer.
After verifying your identity, GOTO GAMES will respond within 1 month after exercising the right. In some cases, depending on the complexity of the request or the number of requests, this period could be extended by 2 months.
These rights can, in some cases prescribed by the regulations, be subject to exceptions.
In case of a lack of response or an unsatisfactory response, the person concerned has the power to refer the matter to the supervisory authority in charge of data protection in his country.

4. RECIPIENTS OF THE DATA

Your data are transferred to the partners of GOTO GAMES who can process them on their behalf (these are the recipients) or solely on behalf of and according to the instructions given by GOTO GAMES (these are the subcontractors).

GOTO GAMES also calls on subcontractors for the following processes:
  • Secure payment on the website
  • Technical data hosting
  • Collecting customer opinions
  • Sending commercial communication emails
  • Publicity on social networks
  • Promotional targeting and commercial animation marketing operations

5. TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION

For some processes, data of a personal nature may be transferred to companies in countries outside the European Union. Before the transfer out of the European Union, and in accordance with the regulations currently in effect, GOTO GAMES guarantees the security of these data transfers.

Transfers out of the European Union in particular can be done within the framework of the following activities:
Activity Country of destination for data Data transfer framework
Providing social networks with data United States Privacy Shield

6. DURATION OF DATA CONSERVATION

GOTO GAMES has determined precise rules concerning the duration of conservation of the Clients’ personal data. In principle, without any legal obligation to the contrary, the data are kept for the duration necessary to accomplish the purposes for which they were collected.

The retention periods are as follows:
  • The data of prospective and current customers are kept for 3 years after the last log-in;
  • Cookies for audience measurement, targeted advertising and sharing across social networks remain in the customer’s terminal for a duration of 13 months;
  • Purchase invoices are kept for 10 years.

7. COLLECTION OF DATA FROM MINORS

GOTO GAMES does not collect data about minors below 16 years of age without the authorisation of a holder of parental authority who provides the data himself.

8. BUSINESS PROSPECTING

GOTO GAMES uses your contact information in order to direct targeted advertising towards you, in particular via email, SMS or social networks.
GOTO GAMES respects the rules decreed by the 2002/58/CE directive of the 12th July 2002, which legislates for the express prior collection of the customer’s consent for the sending of business prospecting material by electronic means (email).
Thus, when your account is created on the website, your consent for receiving offers from GOTO GAMES via email is expressly requested.
GOTO GAMES will not send you personalised offers by email or SMS if you have not consented to it.
There is an exception when the Client, without having given his prior consent, may still be canvassed, since he is already a customer of the GOTO GAMES company and the purpose of the prospecting is to suggest analogous products or services.
In all cases, the customer can refuse to receive these offers by taking the following actions:
  • For email, by clicking on the opt-out link provided in every email;
  • By contacting customer service.