GYLT PRIVACY AND DATA POLICY

ISSUED BY TEQUILA WORKS

Last Updated:  14 January 2021

  1. INTRODUCTION AND GENERAL TERMS

This privacy and data policy (“Privacy Policy”) applies to the use of the game “GYLT” (the “Game”), as developed by Tequila Works, S.L. (‘Tequila Works’ / ‘we’ / ‘us’). Our registered office is at C/ Serrano, 19 planta 5, 28001, Madrid, Spain. We are a company registered in Spain, with company number CIF B85767523.

This Privacy Policy applies and has effect in respect of online services related to the Game (including online network play connectivity and interactivity) and other software and products made available by us, as well as any other online features relating to the Game including our website (www.gyltthegame.com) (the “Website”) and user support (the “Support Services«). Together the Game, the Website and the Support Services are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at info@tequilaworks.com

We are committed to protecting and respecting your privacy. We seek to limit the personal data we handle to only that which is necessary to support and help our customers.

The Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 (the “GDPR”), and the Spanish Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (the “Spanish Digital Protection Act”).

Please read this Privacy Policy carefully as it contains important information about the following:

  • What information we may collect about you;
  • How we will use information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal data you have provided to us.

We offer the Game through certain platforms (including “Google Stadia”) (each a ”Platform”) and the Game makes use of their cloud saving and achievements functionality. That means you need a Platform account to play the Game, and your use of each Platform is subject to the terms of use and privacy policy applicable to that Platform (as may change from time to time).

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them.  They will govern the use of personal data that you submit.  We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. Where appropriate we will notify you of changes through the Game.

  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process your contact information provided by you when you contact us or use the Support Service («Support Information«). In this regard, we provide our support services via email. Whilst it is entirely up to you to decide what information to provide to us in a support request, we may ask you for:

  • your player tag/ID;
  • your Platform username and password details;
  • your email address; and
  • a description of the issue you are experiencing.

If you don’t provide this information, we may not be able to help.

  1. INFORMATION OTHER PARTIES MAY COLLECT ABOUT YOU

Where you access the Game through a Platform or third party distribution platform, these third parties may conduct their own game analytics (including collecting information relating to gameplay attempts, events, level progression, statistics, achievements and results). This will be set out in their own respective privacy policies.

In addition, if you post or upload any content about the Game or Tequila Works on Facebook or Twitter, this will be under Facebook and Twitter’s privacy policies which can be found at https://www.facebook.com/full_data_use_policy and https://twitter.com/en/privacy.

Notwithstanding the above, where you follow us or interact with our content, we may be able to see personal data from your social media profile (depending on your social media privacy settings), including:

  • your name (and/or your social media unique user name);
  • your email and/or postal address;
  • your location;
  • your telephone number(s);
  • IP or MAC address;
  • your gender and/or age;
  • your correspondence with us through those channels; and
  • your general interests and preferences (e.g. Likes, Shares, Posts)

 

  1. WHY WE COLLECT INFORMATION ABOUT YOU
To respond to your enquiries and requests for support

We may process Support Information so that we are able to properly respond to your enquiries and support requests.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing our Game and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Game and Online Services.

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and enables us to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal data to inform relevant third parties such as your law enforcement agencies about the content.

We work with the Platforms to assist us with fraud prevention and the detection of any illegal activity.

 

  1. DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy Policy

Personnel, suppliers or subcontractors: We seek to keep your information confidential, but may disclose the strictly necessary information to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, no disclosure of personal data owned by the company will be executed to the shareholders. Moreover, this is on the basis that they process the information to the extent that it is strictly necessary for the purposes outlined in this Privacy Policy (i.e. do not make independent use of the information), and have agreed to safeguard it according to the applicable regulation.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Tequila Works, our customers, or others.

Digital Content Platforms: When the Game is played through a Platform (including Google Stadia), your personal data may be collected by the Platform and/or a third party payments provider for the purposes of facilitating any payments made through the Platforms.

 

  1. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:

  • for a copy of personal data we are processing about you (right of access) and/or to have inaccuracies corrected (right to rectification);
  • to restrict (right to restriction of processing), stop processing (right to object), or to delete (right to erasure) your personal data;
  • for a machine-readable copy of your personal data, which you can use with another service provider (right to data portability). Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
  • to make a complaint to a data protection regulator. You may contact them at: https://sedeagpd.gob.es/sede-electronica-web/vistas/infoSede/tramitesCiudadano.jsf

To make a request in relation to any of the aforementioned rights, please send your request to info@tequilaworks.com

  1. Data Retention

We will only process your personal data for as long as necessary, bearing in mind the purpose for which that personal data was collected, or as otherwise described in this Policy or, if applicable, for the length of time that we are required to retain your personal data for under applicable law. We will then block your personal data for a reasonable period during which liabilities could arise from the relevant processing activities. Once this reasonable period has elapsed, the personal data will be deleted.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 14. Our terms of use prohibit users aged under 14 years from accessing our Online Services. In the event that we learn that we have collected personal data from a child under 14 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 14 years of age please contact us at info@tequilaworks.com

  1. Security

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

  1. INTERNATIONAL DATA TRANSFERS

Whilst we do not anticipate that we will do so, if we transfer your information outside of the European Economic Area (“EEA”), we will inform you beforehand and we will have agreements in place with the recipient which include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data.  If you would like to find out more about these safeguards, please let us know by writing to info@tequilaworks.com

It is possible that your personal data may be transferred outside of the UK and/or the EEA by the Platforms acting as data controllers of your personal data. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred internationally.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to Tequila Works at info@tequilaworks.com or at C/ Serrano, 19 planta 5, 28001, Madrid, Spain. We will endeavour to respond to any query or questions within three business days.