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Novarama Privacy Policy

Last Updated: 12 January, 2022

 

We inform you that this privacy policy of Novarama Technology, S.L. (hereinafter Novarama) is applicable to the use of the Services offered by Novarama, either through Web access, on our website www.novarama.com, through mobile devices, online or offline, as well as to through the desktop app or on any other platforms.

Likewise, this privacy policy also describes how we treat the information provided by you when you access our website, and when you provide us with personal information through the forms that we make available to you.

To be as clear and transparent as possible, we have created different sections according to the data we process:

  • General
  • Request for commercial information 
  • Candidates
  • Play our games

Within such sections, you will find detailed information about the purposes for which we process your data, the period during which we have access to your data, with whom we can share it, what are your rights regarding said data, as well as any additional information in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “European Regulation” or “GDPR”), and with the current Organic Law on Data Protection.

For clarification purposes, the General section applies to all users of our website, and additionally indicates in a generic way our data processing policy for those cases that are not included in the specific sections mentioned.

Finally, and before detailing other sections, we inform you that the security policy detailed hereunder is applicable to all of them, and that the “Rights” section that follows, is applicable to all sections except for the section of “Play our games”, which has its own peculiarities.

 

Security

Novarama Technology, S.L. has adopted the required security measures, in accordance with the provisions of article 32 of the GDPR. In this sense, taking into account the state of the art, the application costs and the nature, scope, context and purposes of the processing, as well as the risks of variable probability, and severity for the rights and freedoms of natural persons, Novarama Technology, S.L has established the appropriate technical and organizational measures to guarantee the level of security appropriate to the existing risk.

In any case, Novarama Technology, S.L. has sufficient mechanisms in place to:

  1. Guarantee the confidentiality, integrity, availability, and permanent resilience of the processing systems and services.
  2. Restore the availability and access to personal data quickly, in the event of a physical or technical incident.
  3. Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the security of the processing.
  4. Pseudonymize and encrypt personal data, if applicable.

 

Rights of the data subject

We inform you that you have the right to obtain confirmation on whether if at Novarama Technology, S.L. we are treating personal data that concerns you, or not. You have the right to access your personal data, as well as to request the rectification of inaccurate data, or where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. Likewise, you may request the portability of your personal data, and the limitation of its processing, in which case we will only keep it for the exercise or defense of claims. In certain circumstances and for reasons related to your particular situation, you may object to the processing of your personal data, in which case Novarama Technology, S.L. will stop processing your data, except for compelling legitimate reasons, or the exercise or defense of possible claims. The above rights may be exercised by communication sent by postal mail to Novarama Technology, S.L., Avenida Diagonal 418, 3º-1ª, 08037, Barcelona, ​​or by email to info@novarama.com. It is possible that in order to verify the identity of the applicant, an identification document (ID, passport or equivalent) will be required. You can direct your claims arising from the processing of your personal data to the Spanish Data Protection Agency (www.agpd.es).

Novarama Technology, S.L. reserves the right to modify this privacy policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. In the event that we make a substantial change, we will notify you via email or through the Novarama platform itself, before the change becomes effective.

 

GENERAL

Controller

NOVARAMA TECHNOLOGY, S.L. 

Avenida Diagonal 418, 3º-1ª 

08037.- Barcelona (Barcelona) 

Spain

Email: info@novarama.com

 

Processing of personal data

The personal data that is requested, where appropriate, will consist only of that strictly essential information to identify and respond to the request made by the owner of such data, hereinafter known as the interested party. Said information will be treated in a fair, lawful, and transparent manner in relation to the interested party. On the other hand, personal data will be collected for specific, explicit, and legitimate purposes, not being further processed against said purposes.

The data collected from each interested party will be adequate, pertinent, and not excessive in relation to the corresponding purposes for each case and will be updated whenever necessary.

The owner of the data will be informed, prior to the collection of their data, of the general points regulated in this policy so that they can give precise, explicit, and unequivocal consent for the processing of their data, in accordance with the following aspects.

 

Purposes of the Processing

The explicit purposes for which each treatment is carried out are included in the information clauses incorporated in each of the data collection channels (web forms, paper forms, voice-overs or posters and information notes).

However, the personal data of the interested party will be treated with the sole purpose of providing them with an effective response and meeting the requests made by said party, specified together along the option, service, form or data collection system that the owner uses.

When the interested party has expressly accepted it by activating the corresponding box, we will also process the information to send them the Novarama Newsletter with news and updates on sales, technology, and their sector, as well as to periodically send them marketing communications related to the products and Novarama services.

 

Legitimation

Generally, prior to the processing of personal data, Novarama Technology, S.L. obtains express and unequivocal consent from the owner by incorporating informed consent clauses in the different information collection systems.

However, if the consent of the interested party is not required, the legitimizing basis of the processing on which Novarama Technology, SL relies on is the existence of a specific law or regulation that authorizes or requires the processing of the data of the interested party. 

You are responsible for the legality and accuracy of the data entered in the form. We inform you that you can withdraw the consent given for the processing of your data, at any time, by contacting info@novarama.com. Likewise, the interested party may stop receiving commercial communications by email by following the instructions that we will provide in each communication.

 

Origin

Generally, personal data is always collected directly from the interested party, however, in certain exceptions, the data may be collected through third parties, entities or services other than the interested party. In this context, this point will be transferred to the interested party through the informed consent clauses within a reasonable period, once the data has been obtained, and at the latest within one month.

 

Recipients

Generally, Novarama Technology, S.L. does not engage in data transfer or communication to third parties, except for those legally required, however, if necessary, said transfers or data communications are informed to the interested party through the informed consent clauses contained in the different ways of collecting personal data. However, no disclosure of personal data owned by Novarama Technology, S.L. will be assigned to the shareholders.

In any case, Novarama Technology, S.L. takes the appropriate measures to maintain security, both during transit and at the place of reception, and as a group complies with the applicable regulations on data protection, including the European Regulation.

Finally, and if applicable, our service providers may also process your data at some point as personal data managers under our instructions, and in accordance with the corresponding processing manager contract, and with the goal of Novarama carrying out the purposes for which your data has been collected.

 

REQUEST FOR COMMERCIAL INFORMATION 

Controller

NOVARAMA TECHNOLOGY, S.L. 

Avenida Diagonal 418, 3º-1ª 

08037.- Barcelona (Barcelona) 

Spain

Email: info@novarama.com 

The processed data categories are: 

  • Identification data
  • Postal and/or electronic addresses
  • Specially protected data is not processed

 

Purpose of the processing

We inform you that the personal data you provide us will be processed by Novarama Technology, SL, (hereinafter “Novarama”), for the purpose of processing your request for information, to provide you with the commercial information that you require about Novarama products and services, and where appropriate, to inform you of any sales that we launch, as well as to send you information about new Novarama products or services. When you have expressly accepted it by activating the corresponding box, we will also process your information to send you the Novarama Newsletter with news and updates on sales, technology, and your sector, as well as to periodically send you marketing communications related to Novarama products and services.

 

Conservation period

Novarama will keep your personal data after receiving your request as long as you do not request the cessation of processing. This means that during this period we can use your data for the purposes detailed above. 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.

 

Legitimation

You are responsible for the legality and accuracy of the data entered in the form. The processing of your data is carried out based on your express consent. We inform you that you can withdraw the consent given regarding the processing of your data, at any time, by contacting info@novarama.com. Likewise, you may stop receiving commercial Communications by email by following the instructions that we will provide you with each communication.

 

Recipients

Generally, Novarama Technology, S.L. does not engage in data transfer or communication to third parties, except for those legally required, however, if necessary, said transfers or data communications are informed to the interested party through the informed consent clauses contained in the different ways of collecting personal data. However, no disclosure of personal data owned by Novarama Technology, S.L. will be assigned to the shareholders.

In any case, Novarama Technology, S.L. takes the appropriate measures to maintain security, both during transit and at the place of reception, and as a group complies with the applicable regulations on data protection, including the European Regulation.

Finally, our service providers may also process your data at some point, as personal data managers under our instructions, and in accordance with the corresponding processing manager contract, and for the purpose of Novarama carrying out the aforementioned purposes.

 

CANDIDATES FOR NOVARAMA VACANCIES 

Controller

NOVARAMA TECHNOLOGY, S.L. 

Avenida Diagonal 418, 3º-1ª

08037.- Barcelona (Barcelona) 

Spain

Email: info@novarama.com

 

The processed data categories are: 

  • Identification data
  • Postal and/or electronic addresses
  • Academic and employment history
  • Specially protected data is not processed

 

Purpose of the processing

We inform you that the personal data you provide us will be processed by Novarama Technology, SL, (hereinafter “Novarama”), and will be used for the purpose of processing your job application, to provide you with Novarama services to you as a candidate, and to determine if you would be a suitable candidate for us.

 

Conservation period

Novarama will keep your personal data for a period of 1 year after receiving your request. This means that during this period we may use your details to contact you should we have a suitable available position for you in the future.

 

Legitimation

The processing of your data is carried out based on your express consent. We inform you that you can review or deactivate your candidate profile, as well as withdraw the consent given for the data processing at any time, by contacting info@novarama.com.

 

Origin

Generally, personal data is always collected directly from the interested party, however, in certain exceptions, the data may be collected through third parties, entities or services other than the interested party. In this context, this point will be transferred to the interested party within a reasonable period, once the data has been obtained, and at the latest within a month.

 

Recipients

Generally, Novarama Technology, S.L. does not engage in data transfer or communication to third parties, except for those legally required, however, if necessary, said transfers or data communications are informed to the interested party through the informed consent clauses contained in the different ways of collecting personal data. However, no disclosure of personal data owned by Novarama Technology, S.L. will be assigned to the shareholders.

In any case, Novarama Technology, S.L. takes the appropriate measures to maintain security, both during transit and at the place of reception, and as a group complies with the applicable regulations on data protection, including the European Regulation.

Finally, and if applicable, our service providers may also process your data at some point as personal data managers under our instructions, and in accordance with the corresponding processing manager contract, and with the goal of Novarama carrying out the purposes for which your data has been collected.

 

PLAY OUR GAMES 

Controller

NOVARAMA TECHNOLOGY, S.L. 

Avenida Diagonal 418, 3º-1ª 

08037.- Barcelona (Barcelona) 

Spain

Email: info@novarama.com

By downloading, accessing and/or playing our games or using our other Services, you agree to us collecting your information. Most of this data comes directly from you or your device, such as device information, country and region information, and game information. We use this data to provide our games and Services to you, as well as for optimization, fraud prevention, personalization of in-game offers, and purchases verification. We can also use it for other purposes established in this Privacy Policy.

By accepting this privacy policy, the client and the user expressly accept and consent to the collection, use and, where appropriate, the transfer of their data, in the terms indicated below.

 

Categories of data:

Most of the information we collect comes directly from you when you play our games or other Services. In general, the information we collect about you is related to the type of device you are using, how you play our games (such as game progress, milestones achieved, etc.), and may include information that you submit when creating an account. We may also collect information from advertising platforms, partners and third parties, such as information about purchases and interests.

In more detail, depending on which of our Services you interact with, we may collect and process the following types of information:

  • Progress of the player such as contracts (maps) that have been passed, items that they have in inventory, which enemies they have defeated, the progress of the quests, and the date of the last save of the savegame.
  • User identifier to validate that the save game is correct for each player.
  • Logs of program execution.

This data is saved on the player’s own PC or on the Steam Cloud (See their privacy policy)

Analysis and research

We use analytics tools, which may include third-party tools, to collect information about how you play our games or how you use our Services. This game usage data is anonymous and we may use it to create reports, analysis, or similar services to use for research or business intelligence purposes, for example, to track potential issues or trends with our Services, or to test new features and content for games.

When the user decides to send information about a crash, an auto generated identifier of the user’s machine is sent that does not allow the user to be identified and is simply to differentiate one user from another along with the information on the execution status of the software at the time of the crash, and user hardware and operating system information. If the user has an Epic Games account, their account identifier is submitted.

Chat

Some of our services include the chat function. Users of our chat service(s) can send messages to other players. We may use and store your messages to (a) transmit them; and (b) so that you and your recipients can see your message history (although you should note that we only keep 30 messages sent on each channel and for a maximum of 24 hours. Afterwards you will no longer be able to access your chat messages within the game). We reserve the right to review the content of your messages, including through the use of automatic filters, to ensure that you comply with our terms of service, and we also reserve the right to prevent the use of our chat service(s) or block the ability to send any message for any reason. We will not use the content of your chat messages for any other purpose.

Multiplayer

Players of our games will be able to enjoy Steam’s public multiplayer services. We reserve the right to disable, block or limit this functionality if players violate any of our terms of service.

 

Purposes of the processing

We inform you that the data indicated above will be processed by Novarama Technology, S.L., and will be used for the following purposes:

  • So that we can provide you with our games and additional Services
  • To allow us to optimize our games, improve the experience

We also analyze and use the information we collect anonymously or jointly for product development, to analyze the performance of our games, for troubleshooting, to improve and optimize games, and to ensure the best player experience for our players in general.

 

Conservation periods

Novarama Technology, S.L. will keep the data for the duration for which the service is provided. Once said provision is completed, Novarama Technology, S.L. will proceed to eliminate the data. Notwithstanding the foregoing, Novarama Technology, S.L. may keep information and anonymized data related to the use of such Services, with the goal of improving their quality.

Once the legitimation period has expired, 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.

 

Legitimation

The Solution of Novarama Technology, S.L. allows customers to play our games by downloading them from a third-party platform such as Steam. The legal basis is a contract execution.

Finally, our service providers may also process all the aforementioned data at some point, as managers of personal data processing under our instructions and in accordance with the corresponding processing manager contract, and for the purpose of Novarama being providing its Services, under the agreed terms and conditions. These providers provide us with auxiliary services necessary for the normal operation of our services.

If it is necessary to subcontract any processing, Novarama Technology, S.L., will communicate in advance and in writing to our clients, indicating the processing that it is intended to subcontract, and clearly and unequivocally identifying the subcontractor company and its contact details.

 

Recipients

Generally, Novarama Technology, S.L. does not engage in data transfer or communication to third parties, except for those legally required, however, if necessary, said transfers or data communications are informed to the interested party through the informed consent clauses contained in the different ways of collecting personal data. However, no disclosure of personal data owned by Novarama Technology, S.L. will be assigned to the shareholders.

In any case, Novarama Technology, S.L. takes the appropriate measures to maintain security, both during transit and at the place of reception, and as a group complies with the applicable regulations on data protection, including the European Regulation.

Finally, and if applicable, our service providers may also process your data at some point as personal data managers under our instructions, and in accordance with the corresponding processing manager contract, and with the goal of Novarama carrying out the purposes for which your data has been collected.

 

Rights of the data subject

We inform you that you have the right to obtain confirmation on whether Novarama Technology, S.L. we are treating personal data that concerns you, or not. You have the right to access your personal data, as well as to request the rectification of inaccurate data, or where appropriate request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. Likewise, you may request the portability of your personal data, and the limitation of its processing, in which case we will only keep it for the exercise or defense of claims. In certain circumstances and for reasons related to your particular situation, you may object to the processing of your personal data, in which case Novarama Technology, S.L. will stop processing your data, except for compelling legitimate reasons, or the exercise or defense of possible claims. The above rights may be exercised by means of a communication sent by postal mail to Novarama Technology, S.L., Avenida Diagonal 418, 3º-1ª, 08037, Barcelona, ​​or by email to info@novarama.com. It is possible that to verify the identity of the applicant, the provision of an identification document (ID, passport or equivalent) will be required. You can direct your claims arising from the processing of your personal data to the Spanish Data Protection Agency (www.agpd.es).

Novarama Technology, S.L. reserves the right to modify this privacy policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make a substantial change, we will notify you via email or through the Novarama platform itself, before the change becomes effective.

 

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