Privacy Policy

This Privacy Policy explains how we collect, handle and process your personal data on our services, websites, career sites and social media services. Here you can read about the purposes and means of how we process your personal data. We are committed to ensuring that your privacy is protected, as we recognize the importance of your privacy. We are committed to being transparent regarding how we collect and use that personal data as well as meeting our data protection obligations.

This privacy policy helps you understand what personal data we may collect, and how such data is used and processed. “Personal Data” refers to data which allows the identification of an individual person (as defined and in compliance with the European Union’s General Data Protection Regulation 2016/679 (“GDPR”)). This is opposite to “non-personal data” or “anonymous data” meaning data which does not relate to an identified or identifiable natural person or to Personal Data rendered anonymous in such a manner that the data subject is not or no longer identifiable.

In this Privacy Policy, any use of the words “you”, “yours” or similar expressions shall mean any applicant or candidate. Terms such as “we”, “us, “our” or similar expressions shall mean the Spectarium Oy (registration number 3100367-7)

We commit to adhere to the provisions of the aforementioned legislation and other such applicable laws and regulations pertaining to processing of Personal Data. The practices described in this policy are subject to applicable laws in the places in which we operate.

With regard to recruitment, we as the data controller, use several service providers to facilitate the recruitment process. As our sub-processors the service providers collect, use and store personal data, pertaining to applicants, on our behalf. We are responsible for the processing of your personal data. If you want to know more about our sub-processors please contact us.

PERSONAL DATA

This policy applies to users of our services, any apps, games, websites, social media services, features and other services. This policy describes also how we and our affiliates process Personal Data. This policy specifically applies to the following data subjects:

  • Users: who play our games, use our services and engage with us on our social media channels

  • Candidates & Potential Recruits: who engage with us during the recruitment process

  • Other visitors: Who visit our website, services and social media channels

This policy also applies to those who provide Personal Data to us in connection with an application to use our services, website or website where our services can be used, social media or whose Personal Data we otherwise receives in connection with our services or other channels of communication such as email.

PERSONAL DATA COLLECTION & USE

We collect the following Personal Data. The primary source of Personal Data is the relevant data subject. Mainly, Personal Data is collected when the data subject uses our services or communicates with us. In some cases, we may also collect Personal Data from third parties, such as public registers or analytics tools or from the organisations the data subject represents.

Personal Data may include:

Users

We may collect necessary Personal Data when you create or update your account. This may include the following Personal Data:

  • Your name, email, password, and birth date (users must be 16 or older) as well as preferences and settings that you enable for your account.

User content

  • We may collect Personal Data that you create when you contact customer support, provide ratings or compliments, engage with other users or otherwise contact us or use the services as well as intereact within the services and generate content.

Transaction & Payment information

  • We may, if necessary and if possible via the services we provide, collect transaction details related to your use of our services, including the type of services, your order details, date and time, amount charged and payment method. Additionally, if someone uses your promotional codes, we may associate your name with that person.

  • We may use third party service providers for payments in our services. When you make payments through the service provider will receive your transaction and payment verification information, contact information and other necessary Personal Data for the payment processing. We do not have access to your payment information. See more on the relevant service providers page.

Device information

  • We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, and mobile network information.

Communications data

  • We may enable users to communicate with each other and us through our apps, websites, and other services. To provide this service, We may receive some information regarding the communication.

Information from other sources including

  • User feedback, such as ratings or compliments.

  • Users providing your information in connection with referral programs. Users requesting services for or on your behalf. o Users or others providing information in connection with claims or disputes.

  • Our business partners through which you create or access your account, such as payment providers, social media services, on-demand music services, or apps or websites who use our APIs or whose API we use.

  • Publicly available sources.

Safety and security

We use your data to help maintain the safety, security and integrity of our services and users. This includes, for example:

  • Using information from our services to identify unsafe or toxic

  • Using information provided to us to prevent, detect, and combat fraud or unsafe activities. This includes processing of such information, in certain countries, to identify practices or patterns that indicate fraud or risk of safety incidents. This may also include information from third parties.

Mandatory Personal Data.

Without that Personal Data we cannot for example provide our services and necessary communication and ensure security and safety of the services. We may combine Personal Data collected from these sources with other information in our possession.

With regard to recruitment, your personal data is processed with the purpose of managing our recruitment related activities concerning candidates for our business.When you apply through the career site, website or via LinkedIn/other social media, you provide personal data to us. Categories of personal data that you provide could be for example name, e-mail address, phone number, location, resume, cover letter, degree, further education, and/or LinkedIn profile. What is mandatory versus optional personal data to provide varies depending on what is relevant to the process for the role you are applying for. Please note that the above are examples of categories and the list is not exhaustive. As part of the recruitment process we may perform sourcing where we collect personal data from sources such as LinkedIn. For candidates moving on in the process, we may also request to collect personal data from references and previous employers.

SPECIAL CATEGORIES OF PERSONAL DATA

No special categories of personal data are processed by us. We do not process either racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, trade union membership nor data concerning health or sex.

LEGAL BASIS

We process Personal Data for the purposes including but not limited to:

  • To provide services and to maintain our relationship with the data subjects

  • Management of customer service, feedbacks and related communications

  • Registrations for our services

  • Direct marketing (including electronic direct marketing and other direct marketing activities) and customer analysis and surveys and target marketing

  • Business planning and product and application development

  • Ensuring security of our products and services and preventing abuses

  • Ensuring security of our IT environments and protection of data

  • To enhance the safety and security of our users and services

  • For customer support

  • For research and development by both us or our partners such as universities, research institutes and co-developers

  • To enable communications to or between users

  • To provide promotions or contests

  • In connection with legal proceedings

  • Create and update your account.

  • When necessary, verify your identity.

  • Allowing for our game engine to process actions in the game, to generate the game content in accordance with your preferences. This includes automated processing of your decisions and interractions within the game information.

  • Process or facilitate payments for our services.

  • Enable features that allow you to share information with other people.

  • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

  • We may also need to process Personal Data to ensure that we are compliant with the applicable legal obligations, such as tax law, accounting related obligations. Furthermore, Personal Data may be needed to respond to and defend against legal claims and complaints and other disputes.

We process Personal Data on the following legal basis:

  • For the purposes of performance of a contract to which a relevant data subject is party or in order to take steps in order to enter into a contract (both users and partners and other users of our services).

  • For the purposes related to our legitimate interest to inform you about our services, to deliver and maintain our services, provide relevant marketing information (including direct and target marketing) and communication about our services and to maintain a customer relationship and ensuring security of our services and preventing abuses as well as research and development purposes among others. Where we reliy on the legitimate interests as a legal basis for the processing of Personal Data, we have considered whether or not those interests are overridden by the rights and freedoms of data subjects and have concluded that they are not.

  • To comply with our legal obligations applicable to us (such as accounting and tax law related)

  • Based on your consent for example regarding direct marketing activities, if applicable law requires a consent. In addition, We rely on consent in connection with data collections or uses that are necessary to enhance your user experience, to enable optional services or features, or to communicate with you. The following types of data collections or uses are done on the basis of your consent, including but not limited to:

    • Notifications: Account, Discounts and News

    • Game: Content related choices and preferences


RECRUITMENT: PROCESSING BASED ON CONSENT

The personal data you provide, and data that is collected publicly, is processed with your consent and may be used in the recruitment processes, as part of evaluation and selection of applicants, setting up and conducting interviews and tests, evaluating and assessing results, and as otherwise needed in the recruitment process, including the final recruitment.

We may reach out to candidates regarding the process, during and after the recruitment process has been completed. Some positions will require work assessments and/or personality tests. We may also perform a background check for compliance reasons where necessary. The processing of your personal data described in this section is based on your consent.

Under GDPR you have the right to withdraw your consent at any time. You may do so by sending an e-mail to privacy@spectarium.games. However, please note that your personal data is used to evaluate your application for employment and by exercising this right you can not use the career site or website based recruitment service.

RETENTION TIME

Personal data provided in the recruitment process will be processed for as long as deemed necessary in relation to business recruitment related activities, and for global organizational planning, as well as in accordance with jurisdictional requirements.

Please note that we may retain your personal data after we have stopped providing services to you, if it is necessary in order to comply with our legal obligations, prevent fraud, meet regulatory requirements, or to resolve disputes. We may keep your personal data if you could be a potential candidate for future recruitment subject to your consent. We may also keep anonymized derivatives of your personal data for business analytical purposes, such as recruitment statistics. Personal data that we process for any purpose will not be retained longer than what is necessary for that specific purpose and in any case no longer than for the period you consent for us to process said data.

Under GDPR you have the right to request access to your personal data, to request that your personal data is corrected or erased and to request restriction of the processing of your personal data.

Should you go from candidate to employee your personal data processed during the recruitment process will be used for employment purposes in accordance with our internal Privacy Policy.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We may use third party suppliers that perform services on our behalf, and we may disclose your personal data to such suppliers. These third party suppliers include for example hosting, analytical services, database management and internet service providers. In line with our business purposes and as permitted by law, we may share your personal data with other parties, such as professional advisers. In certain cases, we may be required to disclose information, either by law, as part of a legal process or according to regulations. We ensure the proper processing of Personal Data through adequate contractual obligations. List of recipients that process Personal Data can be provided upon request.

Personal Data are also shared or transferred to third parties for the purposes described in this privacy policy if required under applicable laws or regulation or order by competent authorities, or to investigate possible infringing use of our services as well as to guarantee safety of the services.

In case of an emergency or other surprising event, we may need to disclose Personal Data to protect health, safety and property. In addition, we may be obliged to transfer Personal Data to the third parties involved in any business operation, merger, sale of our assets, or other similar arrangements.

INTERNATIONAL TRANSFERS

For purposes that are in line with this Recruitment Privacy Policy, personal data may be disclosed within Spectarium and to our third-party service providers around the world. For example, once you have applied via our website or LinkedIn your personal data may be transferred outside of the European Economic Area (EEA). Some parties and third party providers that we utilise may be established outside the EEA, meaning that personal data may be processed outside EEA. We have taken reasonable measures to ensure that your personal data is protected in accordance with this Privacy Policy, as these countries may not have privacy protection laws corresponding to GDPR.

PROTECTING YOUR PERSONAL DATA

We have in place security measures in order to protect your personal data from unauthorised access, unlawful disclosure, destruction or modification, accidental loss, and other misuse. The security mechanism we use are technical, physical and administrative, such as encryption, firewalls, physical access controls and information access controls. Despite our reasonable efforts to safeguard personal data, please note there is always a risk that a third party may unlawfully access our systems or otherwise access personal data. We do not accept liability for protecting personal data disclosed through your internet connection.

YOUR RIGHTS

Please note that for a definitive explanation of the rights you have, you should familiarise yourself with the applicable laws and regulations as this is intended to be an illustrative list. According to GDPR your principal rights are:

  • The right to access: You can contact us to request a copy of your personal data being processed.

  • The right to withdraw consent: You may withdraw your previously given consent where this is the legal basis for processing your personal data.

  • The right to rectification or erasure: You can contact us to request us to modify, correct or remove information that we process about you, in cases where it is incorrect, incomplete or no longer necessary.

  • The right to object to or restrict processing: You can contact us if you consider the processing to be unlawful or if you don’t want it to be processed in a certain manner.

  • The right to request portability: You can request us to transfer your personal data should you wish to use it elsewhere.

  • The right to complain to a supervisory authority: You may contact your local data protection authority if you wish to make a complaint regarding our collection and use of your personal data.

To exercise your rights, please contact us by e-mail at privacy@spectarium.games. If you believe that we have not complied with applicable data protection laws when processing your Personal Data, you can lodge a complaint with a competent supervisory authority.

USE OF COOKIES

We use cookies and other identification technologies on our apps, websites, emails, and ads for purposes described in this policy. Cookies are small text files that are stored on your browser or device by websites, apps, online media and advertisements.

We use only strictly necessary cookies and similar technologies for purposes such as authenticating users and remembering user preferences and settings. You can allow and control cookies on your browser or device by using the appropriate settings of a browser or device. Please note that disabling use of certain cookies may downgrade or reduce our service’s functionality.

CHANGES TO THIS POLICY

We may, from time to time, update our Recruitment Privacy Policy by publishing a new version on this page. The changes will become effective on the date of publication (please see date below). To ensure you are comfortable with changes please make sure to visit this page occasionally.

CONTACT

You can contact us if you have questions, comments and concerns about this Recruitment Privacy Policy, or the way in which we handle your personal data. Do not hesitate to reach out to us should you wish to execute your rights as described above. Please contact us by e-mail at privacy@spectarium.games.

Last updated: 25.7.2023