EU Data Privacy Addendum
This Addendum applies to users in the European Union and supplements the core Privacy Notice.
PURPOSE OF PROCESSING YOUR DATA
| Processing Purpose | Basis of Processing |
|---|---|
| Account creation, Service delivery | Performance of a contract |
| Fraud prevention, legal compliance | Legal obligation |
| Corporate events, analytics | Legitimate interests |
| Targeted/behavioural advertising, marketing | Consent |
| EU Cookies / non-essential SDKs | Consent |
EU COOKIES AND ADVERTISING CONSENT
For EU, UK, and Swiss users, we deploy a Consent Management Platform (CMP) compliant with the IAB Transparency and Consent Framework (TCF). Non-essential cookies, advertising SDKs, and third-party analytics tools will not be initialised until you have provided prior, specific consent through the CMP. You may withdraw or adjust your cookie preferences at any time.
CHILDREN’S PRIVACY
We do not knowingly or intentionally process the personal data of minors below the Applicable Minimum Age. Any personal data of a minor inadvertently received by us will be promptly deleted in accordance with our core Privacy Notice.
RIGHTS OF DATA SUBJECTS
EU Users have the following rights:
- Right of Access
- Right to Rectification
- Right to Erasure
- Right to Restriction of Processing
- Right to Data Portability
- Right to Object
- Right Not to be Subject to Automated Decision-Making
- Right to Withdraw Consent
- Right to Lodge a Complaint with a Supervisory Authority
We use profiling to deliver interest-based advertising and to link your devices. This profiling does not produce legal effects concerning you or similarly significantly affect you and we do not make solely automated decisions of that kind. Where we rely on consent for advertising profiling, you may withdraw that consent at any time. To exercise these rights, please contact us at privacy@spill.games. We aim to respond within one month of receipt of your request or such other time as notified by applicable laws. You may also lodge a complaint with the supervisory authority in your Member State of residence.
DATA RETENTION
We retain personal data for the period necessary to fulfil the purposes set out in this Notice. The criteria used to determine that period include the duration of your account and use of the Services, our legal and accounting obligations, the limitation periods for bringing or defending legal claims, and the need to resolve disputes and enforce our terms. When no longer required, data is deleted, destroyed or anonymised.
CROSS-BORDER TRANSFERS
Transfers of EU personal data outside the EU are made using one of the following mechanisms: (i) transfers to territories with an adequacy decision; or (ii) transfers to territories without an adequacy decision, using Standard Contractual Clauses (SCCs) approved by the European Commission, or other appropriate safeguards. In limited circumstances, we may rely on an applicable derogation, including your explicit consent.