Stagezero Oy Privacy Policy

Last update: May 29th, 2020

Main points:

·          According to this privacy policy («Privacy Policy»), Stagezero Oy and its affiliates also referred to as us/we/our in this Privacy Policy are providers and developers of products such as mobile applications and websites, including official website Stagezero.fi and our other services such as our speech recording products («Services») under the brand name Stagezero;

·          Stagezero Oy is a data controller of data processed through your use of its Services;

·          Data we might process includes profile and contact details, data related to your use of services including game stats, posts, log in, traffic data, data relating to the device you use to access the services;

·          Stagezero Oy uses your data in order to provide and develop services, improve and personalize the services, respond to queries and analyze use of our services;

·          We may send you info letters related to our Services we think may be of interest to you which you may unsubscribe at any time;

·          We may send you push notifications if you are using an app. You will be given a one-time option to allow such notifications or not. You can always use your device settings to control these;

This Privacy Policy explains how and what personal data relating to you we may use in relation to our Services. This Privacy Policy complies with General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter “GDPR”). Terms that are not defined in this Privacy Policy shall have the meaning defined in the GDPR.

Please read this Privacy Policy carefully before you use the Services and/or provide any content or other information for us which may include your personal data.

Stagezero Oy may modify this Privacy Policy. We will notify about significant changes on our website. You are highly recommended to review this Privacy Policy on our website every now and then. The most-current version of this Privacy Policy is available on our website.

Please note, that the Services may contain links to websites or other services owned and operated by third parties. We do not endorse any such third-party services. We are not responsible or liable for anything that happens to you when you visit or use these services. We recommend that you review the privacy policies and cookie usage of these third parties.

 

1. What data does Stagezero Oy collect from you?

In this Privacy Policy "data” or “personal data" means any personal data which could identify a natural person (“data subject”) directly or indirectly (by itself or in combination with other data), as defined in the GDPR, such as name, contact details or voice. “Anonymous data” means a 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.

We may collect the following data about you:

Data you give us directly:

·          if you register with us (such as your date of birth, username, avatar - picture, password and email address) and order our Services

·          that you provide by entering any competitions or completing any surveys, including your scores and ranking in any competition;

·          Data you provide by completing any in-game purchases, such as buying in-game currency and other items;

·          Data you provide by participating in any Stagezero Oy chats, forums or social media publics;

·          Data you provide us if you report about a problem with any of Services or communicate with us;

·        Data you provide when using the Services, such as when you provide speech recordings based on the applicable agreement or terms of service  

1.1 Data we may collect when you use our Services (whether or not you register with us):

·          data about your location, device type, operating system and platform;

·          data about your device, operating system version, page loading time, network, generated device identifier information, hashed MAC address, referral source and IP address.

·          data generated through playing games such as your high score and rankings;

·          game play history;

·          the number of times you visit our Services and the amount of time you spend using the Services;

·          where you are accessing Services through a third-party account such as Facebook or Google - certain information relating to your account with those third parties including your name, user ID, gender, location (country and/or city specific), email address, date of birth, information from your public profile including friends and connections, log in details, avatar, gender and other information based on your use of our Services.

You can manage the information which is shared by such third parties by amending your preferences through the privacy settings such third parties provide.

1.2 How Stagezero Oy protects your data?

Stagezero Oy follows applicable data protection laws and generally accepted industry standards and maintains reasonable safeguards to attempt to ensure integrity and privacy as well as security of personal data and other confidential information in Stagezero Oy’s possession.

Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.

2. What are the purposes and legal basis for the processing of your data?

We may process your data for the following purposes:

·          to provide the Services to you,

·           to communicate with you regarding the Services (including any newsletter or blog that you subscribe to with us (which you can opt out of at any time)),

·          to customize the Services which are available to you,

·          to restrict those we know are under-age from accessing inappropriate content;

·          to ensure that you are in compliance with our terms;

·          to moderate any chat messages in chat forums;

·          to improve the Services, for analysis, analytical and reporting purposes and to offer you technical support or respond to your questions. This also includes using data to log any crashes in our provision of the Services, so we may report such interruptions (in this regard, we may use a third party to assist us);

·          to notify you if you have won a competition, and for other necessary communication;

·          to personalize your experience;

·          Stagezero Oy may use information about your use of the Services, such as your high scores, game rankings and avatars, in order to provide marketing for Services that we believe may be of interest to you;

·          to send you push notifications for certain Services (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting;

·          to offer you other Services which we think may be of interest to you, by email or push notifications and other direct marketing activities such planning of marketing campaign and other activities.

·       to develop, maintain, commercialize, sell and market our speech recognition products to our clients and other stakeholders such as co-developers and for the further use and development of AI products by our clients and other stakeholders.

You can be a subject to a decision based solely on automated processing, including profiling. It means that you can receive some information or offers which are based only on automated processing of your personal information (for example, personalized advertisements). You have the right to refuse to be a subject to a decision based solely on automated processing, including profiling.

We process personal data on the following 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.

·        for the purposes related to our legitimate interest to inform you about the Services, to deliver and maintain the Services, provide relevant marketing information and communication about the Services and to maintain a customer relationship. In addition, when you have provided your personal data to us on the basis of your acceptance of applicable agreement or terms of service, we have a legitimate interest to process that data for the purposes mentioned above in this Privacy Policy and applicable agreement or terms of service. Where Stagezero Oy relies on the legitimate interests as a legal basis for the processing of personal data, it has considered whether or not those interests are overridden by the rights and freedoms of data subjects and has 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.

·           based on a parental consent for processing of personal data of children in relation to information society services when applicable law requires such consent.

3. What rights concerning your data processing do you have?

You as a data subject have the following rights relating to the processing of your personal data. Please note that your rights and options depend on the purposes of the processing of personal data and on the particular situation. Note also that if the purposes for which your personal data is processed do not or do no longer require your identification and we are not able to identify you, certain rights under the GDPR do not apply. In that case we will inform you.

(1) Right of access (right to obtain from Stagezero Oy confirmation as to whether your personal data are being processed and other information concerning your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of your personal data, the period of personal data storage, the existence of automated decision-making, including profiling) and obtain a copy of your personal data;

(2) Right to rectification (right to the rectification of inaccurate personal data concerning you);

(3) Right to erasure (right to obtain the erasure of personal data concerning you);

(4) Right to restriction of processing (right to obtain from Stagezero Oy the restriction of processing on the legal grounds provided in Art.18 GDPR (for example, when the accuracy of the personal data is contested by you or we no longer needs the personal data for the purposes of the processing));

(5) Right to data portability (the right to receive the personal data concerning you, which you has provided to Stagezero Oy, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from Stagezero Oy to which the personal data have been provided);

(6) Right to object (right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including the right to object at any time to processing of personal data concerning you for marketing purposes);

(7) Right not to be subject to a decision based solely on automated processing, including profiling;

(8) Right to file the request or complaint to Stagezero Oy regarding your personal data processing.

(9) Right to withdraw your consent for personal data processing.

You may use your rights by sending requests relating to the rights provided in paragraphs (1)-(9) to our email specified in Chapter 13 “How can I contact Stagezero Oy.

If you have an account with us, you can view and edit your profile to change the settings in order to prevent others being able to add you as a friend.

If you wish to cancel your account, please enter the settings inside of the mobile application or website platform developed by Stagezero Oy and choose an appropriate option.

If you wish to opt out of receiving any promotional emails or newsletters you can do so by clicking on the "unsubscribe here" link at the bottom of each email. To change or delete push notifications, visit the settings section on your device and select the appropriate setting.

If you think that Stagezero Oy has acted contrary the applicable legislation, you are entitled to file a complaint about the matter with a competent supervisory authority (a supervisory authority is a state authority in your country which monitor the compliance with the GDPR).

 

4. Does Stagezero Oy send marketing communications and how can I opt out?

Yes, we may send you marketing communications in relation to other Services that we think may be of interest to you via email or push notification. We always ask your opt-in consent for the electronic direct marketing communication when required so by applicable legislation. This would only ever be in relation to other similar Services of Stagezero Oy however. We do not provide your data to third parties so that they can send you marketing materials without your consent.

You can opt-out by using the unsubscribe mechanism in any email, contact us as set out below or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting.

5. How long does Stagezero Oy store data?

We will keep data only for as long as it is relevant and useful for the purpose for which it was originally collected while you use our Services (for example, play our games) and otherwise where required by law, including without limitations whilst you continue to have access to the Services. If you decide to delete an account you have with us and give up using our Services, we will delete your personal data as soon as technically possible.

Data included in our speech recognition products will be retained as long as a recording is used for the purposes mentioned in this Privacy Policy and as long as a certain product is used by us or by end customers or by other stakeholders which act as controller of that data. However, other data related to the voice recordings such as name and contact details will be deleted after the payments are made as you have agreed in the applicable agreement or terms of service and that personal data is not needed in order to comply legal requirements (such as tax law and/or accounting related obligations.

Nevertheless, certain data does stay on our Stagezero Oy system for administrative purposes (for archiving purposes, scientific or historical research purposes or statistical purposes and to defend or bring any legal action). We also will process those personal data which is needed to comply with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating at the Services.  

Please email us at info@stagezero.fi for more information regarding retention periods.

6. Ad Serving Technology

Subject to the limitations set forth in applicable laws, Stagezero Oy reserves the right to use and disclose the collected, non-personal data for purposes of advertising by Stagezero Oy or Stagezero Oy’s partners and contractors.

Stagezero Oy may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.

Stagezero Oy or third parties operating the ad serving technology may use demographic and geo-location information as well as information logged from your hardware or device to ensure that relevant advertising is presented within the Service. Stagezero Oy or third parties may collect and use data, for such purposes, and 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. Stagezero Oy recommends that you review the privacy policies and cookie usage of our third parties partners. The current list of third party service providers we use in connection with the Services and what data they process can be requested from us at any time by contacting us at info@stagezero.fi.

7. Location Data

To the extent Stagezero Oy makes location enabled Services available and you use such Services, Stagezero Oy 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. The location data is processed and stored only for the duration that is required for the provision of the location related Services.

Stagezero Oy may use, depending on the service (1) IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of WiFi networks.

Your fine, GPS-based geo-location is not accessed without your consent. Notwithstanding Stagezero Oy’s partners who are providing location related parts of the Service, Stagezero Oy will not share your GPS geo-location with third parties without your consent. To the extent Stagezero Oy makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously.

8. Will the data be transferred with third parties and what third party services do we use?

Your personal data can be transferred to third parties for the purposes mentioned in this Privacy Policy. Personal data can be shared to third parties for example if required under any applicable law or order by competent authorities, or to investigate a possible infringing use of the Services as well as to guarantee the safety of the Services. In a case of emergency or other surprising events, we may need to disclose the personal data to protect health and safety and property. In addition, we may be obliged to transfer the personal data to the third parties involved in any business operation, merger, sale of our assets, or other similar business arrangements.

The speech recording data can be transferred globally to our customers and other external stakeholders such as co-development partners, resellers, suppliers and distributors, as you have agreed in applicable agreement or terms of services when providing that data. However, we do not transfer or share any other data which may lead to your identification with these stakeholders (e.g. your contact details) and that data will be deleted as defined the section 5 of this Privacy Policy.

We may also share the personal data with third parties that process data on our behalf, for example in connection with our IT services.

More information can be provided upon request.

In addition, we may use third party services that collect, monitor and analyse data. The current list of third-party service providers we use in connection with the Services can be requested from us at any time by contacting us at info@stagezero.fi.

Stagezero Oy strongly recommends that you review the privacy policies and cookie usage of our third parties partners.

9. Will data be transferred overseas?

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), such as in the US. If we transfer your personal data to countries which are not a subject of adequacy decision of the EU Commission, we ensure an adequate level of data protection in accordance with data protection legislation such using standard data protection clauses approved by the EU Commission, or a transfer is carried out based on EU-USA Privacy Shield arrangement.

10. Special Note about Children’s Privacy

Applicable data protection laws in the EU countries require parental consent for the processing of personal data of children in relation to information society services. The age limit varies between 13 and 16 depending the country. We always ask a consent by a holder of parental responsibility, when required under applicable laws. If the processing of personal data is based on a parental consent, a data subject has right to withdraw the consent as defined in the GDPR or other applicable law.

13. How can I contact Stagezero Oy if I have query or complaint about data protection?

If you have any questions about this Privacy Policy or your rights as a data subject, please contact at info@stagezero.fi or alternatively you can send a letter to: Stagezero Oy, Tuubakuja 4 C 21, 00420 Helsinki.