Welcome to retrobobby.com!

Introduction

Background

Welcome to Bandaloop Games GmbH privacy notice. This document explains how and why we use your personal data, when using any of our services on www.retrobobby.com or any other Bandaloop Games GmbH website or application.

If you have any questions or need clarification about this privacy notice, please contact us using the contact details provided at the bottom of this document.

This privacy notice will be updated from time to time and any such updates will be communicated to you in writing.

Applicable laws

The main privacy laws which apply to B2S, as a company established in Estonia, are:

The Personal Data Protection Act (PDPA)
The General Data Protection Regulation

The above shall together be referred to as the “Data Protection Laws”.

Content of this privacy policy

Contents

Introduction
The Information we collect
1. Data we collect from you
2. Special categories of personal data
3. Additional information
4. Accuracy of your personal data
5. Third party links
Why and how we use your data
1. Legal Bases
2. Purpose for processing
Retention
Recipients of Your data
1. Why we need to share your data
2. Who we share your data with
3. Data sharing outside Estonia
Direct Marketing
Your Rights
1. List of your rights
2. We may need additional information
3. Automated decision making
Contact us

1. The Information we collect

‘Personal data’ means any information that identifies you or that can identify you as a natural person.

Any data which does not fit this definition will not be considered personal data and will therefore not be covered by the Data Protection Laws or this privacy notice. For example, data relating to legal persons (i.e. companies) does not relate to a natural person and is therefore not personal data.

Anonymous data is also not personal data. Whilst where feasible we try to make use of anonymous data, this is not always possible. B2S is nevertheless dedicated to ensuring that your personal data is handled carefully, securely and in line with the Data Protection Laws.

We do not knowingly permit persons under 18 years of age to use the website, and we do not knowingly collect, use or disclose personal data from anyone under 18 years of age. If we become aware that we have unknowingly collected personal data from a child under the age of 18, we will make reasonable efforts to delete such information from our records.

1.1 Data we collect from you

When providing our services or when using this website we collect your personal data. Below you will find groups of personal data which we usually collect from you when you access our website or engage with any of our services.

Identification details: including name and surname.
Registration details: including username, date of birth, gender and nationality.
Contact details: including email address, permanent address and telephone number.
Financial details: including bank account details, credit card information and transaction details (e.g. record of deposit, withdrawals etc.)
Website data: including IP address, login data, GPS data and location data as well as preferences e.g. language etc.
Communications: Any data we may collect in our communications with you.

1.2 Special categories of personal data

B2S does not collect or intend to collect any special categories of personal data, such as any data relating to your health, race and beliefs. We also do not collect any data relating criminal convictions and offences.

1.3 Additional information

We normally collect data directly from you. That said, in some instances we also collect data from other sources. Such sources include:

Third party providers such as those providing KYC services who provide us with background information relating to you including, for example, data relating to whether any sanctions have been imposed on you;
Other entities belonging to the same group of companies as B2S, for example to comply with legal obligations.
Publicly available sources such as social media platforms, Google search, and other publicly accessible databases.

We also collect certain data automatically by means of cookies when you visit/use the website.

1.4 Accuracy of your personal data

We make reasonable efforts to hold accurate and up-to-date records of your personal data. You have the right to check, correct or delete any of your personal data by exercising your data subject rights below.

1.5 Third party links

This website may contain links to other websites that are not owned by us. Please be aware that we have no control over the information that is collected by such other websites, so please consult their own privacy notices before submitting any personal data to them.

2. Why and how we use your data

2.1 Legal Bases

We will only process your personal data when we have a valid legal basis to do so. Generally, we only collect personal data when we:

Need to provide you with our services e.g. to allow you to participate in games and provide similar services;
Need to comply with laws/regulations;
Believe it is necessary for our legitimate business interests e.g., to contact you about our goods and services.

In other rare instances that we do not rely on any of the above legal bases to process your data we will rely on your consent. When we do rely on your consent, you have the right to withdraw it at any time.

2.2 Purpose for processing

In line with the legal bases that we identified above, the table below describes the ways that we plan to use your personal data, i.e. for what purposes and the legal bases we rely on to do so. The following table describes how and why we intend to use your data:

Purpose	Legal Basis
To allow you to register as a player and allow you to participate in games	Performance of a contract with you
To communicate with you and handle your enquiries, requests, and complaints	Performance of a contract with you
To personalize the services, understand which services you like to use, show you relevant advertising, and recommend services that we think you will be interested in (such as games)	Legitimate interest (to promote our own or our partner's services and to improve our services)
To manage loyalty programs and offer you bonuses and other similar benefits	Legitimate interest (to promote our own or our partner's services and to improve our services)
To subscribe you to a mailing list or newsletter and be able to provide you with marketing material	Consent (where we need this) Legitimate interest (to promote our own or our partner's services and to improve our services)
To process payments	Performance of a contract with you
To monitor and investigate the website and use of our services to help us discover and investigate suspicious behavior (such as fraud and other risks)	Compliance with legal obligations Legitimate interest (to detect and prevent fraud)
To comply with our regulatory and legal obligations such as those anti-money laundering legislation and due diligence	Compliance with legal obligations
In case of any mergers, acquisitions, or similar corporate transactions	Legitimate interest (to be able to effectively facilitate transactions)
To perform business analytics	Legitimate interest (to improve our products/services)

If B2S needs to process your data for a purpose which is completely unrelated to the above, we will inform you in writing before doing so. In such a case you may exercise your rights as appropriate and as listed below.

Finally, it is important to understand that without your personal data we may not be able to provide you with our services, or guarantee the proper functioning of our website.

3. Retention

Whenever your personal data is no longer required by us, we will anonymise or permanently delete it.

Your personal data shall continue to be required by us for as long as it continues to be necessary to the purpose that it was originally collected or as otherwise required to continue to provide you with services or to comply with a legal obligation. What is considered necessary depends on the nature of the personal data in question.

Necessity could arise from a legal obligation which requires us to retain personal data for a certain amount of time, such as anti-money laundering legislation, corporate or taxation laws. In such cases we shall retain the data for the maximum period dictated by the law. Moreover, we may also retain your data in order to defend ourselves against any claims, and for such purpose will retain your data for the amount of time in which it may be legally possible for a third party to make such claim against us.

4. Recipients of Your data

To provide our services to you and to comply with our legal obligations we may be required to share your personal data with third parties.

4.1 Why we need to share your data

B2S relies on various service providers, business partners and suppliers to provide our various services and ensure the proper functioning of our website. In sharing personal data B2S ensures that your personal data is processed only based on our instructions and only limited to the intended purpose. We also make sure that any third party with whom we entrust your data has an adequate level of security to protect your data. Finally, B2S ensures that when sharing your data with any third party it is authorised to do so under one of the legal bases identified above, such as where necessary to perform a contract with you.

4.2 Who we share your data with

In the interest of full transparency, we want you to know that we are authorised to share your data to certain third parties. Generally, the third parties with whom we share your data are:

Payment Service Providers
Game providers
Marketing suppliers
Technical suppliers including cloud services providers and IT suppliers at front/back end
Compliance providers (e.g. in relation to regulatory obligations)
Data analytics suppliers
Professional service providers including lawyers, accountants, auditors, insurers
Other entities within the B2S group

4.3 Data sharing outside Estonia

It may be the case that certain recipients of your personal data are based outside Estonia. Whenever your personal data is transferred to an entity which does not afford a similar level of protection as the Estonian Data Protection Laws, we will take the necessary steps to ensure that appropriate measures and safeguards are in place to protect your data. For example, where possible we will rely on the fact that the privacy/data protection laws outside Estonia are deemed to have an adequate level of protection (e.g. the UK). If not, we ensure that the recipient in question is tied with strict rules to ensure that your personal data is given the same protection as it would in Estonia (i.e. by implementing Standard Contractual Clauses).

5. Direct Marketing

When authorised to do so, we may inform you by email, text, SMS from time to time, about similar products and services to the ones we currently offer. These might include any new games, services, offers, promotions, bonuses or any other changes to our games and services.

You should know that you can opt out of receiving any such communication by:

Following the “unsubscribe” link at the bottom of such communications
By contacting us using the contact details below
Or by changing your preferences on your profile

Please allow us up to ten (10) business days for changes to your email preferences to take effect. Opting out of receiving direct marketing does not mean that you will never receive any communications from us. We might need to contact you in the future to send important information from which you cannot opt out, such as delivery status updates.

6. Your Rights

You may have the following rights in respect of your personal data. Please note that the applicability of certain rights is determined by the circumstances of the processing. We try to respond to any of your legitimate requests within one month. However, when your request is complex, or we are faced with a large number of requests it may take us longer to reply.

6.1 List of your rights

Right of access: The right to receive a copy of your personal data.
Right to rectification: The right to correct or complete any inaccurate and/or incomplete your personal data.
Right to erasure: The right to have your personal data deleted. You should note however that this right is not absolute, for example it will not apply where we are legally obliged to retain your data.
Right to data restriction: The right to ask us to restrict our processing of your personal data. For example, while we are verifying the accuracy of your personal data at your request.
Right to data portability: Should you want your personal data “ported” to another data controller, you have the right to ask us to provide your personal data in an appropriate format to enable such transfer.
Right to object to certain processing: Where we are relying on the legal basis of our legitimate interests you shall have the right to object to our processing of your personal data.
Right to withdraw consent: If we process your personal data based on your consent (it should be noted that in most cases we rely on other legal bases e.g. as necessary to perform the contract), you have the right to withdraw your consent for the specific processing operation for which you gave your consent.
Right to lodge a complaint: You have the right to lodge complaints about our data processing activities with the Estonian Data Protection Inspectorate.

6.2 We may need additional information

When you decide to exercise any of the rights above, we always want to make sure that we deal with the request as best as we can. In particular, we usually ask certain questions to you to confirm your identity. We do this to ensure that we do not disclose your personal data to anyone who is not authorized to have it.

6.3 Automated decision making

We do not use your personal data to make any automated decisions about you (decisions that are made solely by automated means without any human input) including profiling.

7. Contact us

If you have any questions or concerns, please do not hesitate to contact us. If you wish to contact us by email, please contact us at [email protected]

If you wish to write to us, our contact address is:

Bandaloop Games GmbH
Leonard-Bernstein-Straße 10, 1220
Vienna
Austria

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