Effective date: 29 November 2019
1. GENERAL INFORMATION
1.2 Data controller. The company that is responsible for the processing of your personal data through FunFunding is FUN FUNDING LTD having a registered business address at Rotschild 2, Tel Aviv 6688102, Israel and the company registration number 515735363 (“we”, “us”, and “our”). We act as a data controller with regard to your personal data collected through FunFunding.
1.3 What is FunFunding? FunFunding is an online platform that offers casual games and participation in game tournaments (the “Tournaments”). Please see section (x) of our Terms of Service RULES OF THE TOURNAMENTS AND DONATIONS for more
Please see section (x) of our Terms of Service Rules of the Tournaments and donations for more information.
1.5 Children. FunFunding should not be accessed and used by persons under the age of 13 (Users located outside the European Union) or the age of 16 (Users located in the European Union); therefore, we do not collect personal data of persons under the age of 13 or 16.
2. TYPES AND PURPOSES OF PERSONAL DATA
We collect only a minimal amount of personal data that is necessary for ensuring your proper use of FunFunding. We use your personal data for specified and limited purposes. In this section, we explain what personal data we collect from you, for what purposes we use that data, and on what lawful bases we rely when processing personal data.
2.1 Types of personal data. We comply with data minimization principles. Thus, we collect only a minimal amount of personal data that is necessary for your use of FunFunding. The list of the types of personal data that we collect from you is provided in Section 2.3 below.
2.3 Overview of types and purposes of your personal data. The table below provides a detailed description of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing personal data.
2.4 Additional data. From time to time, we may receive certain additional data if you participate in a focus group, contest, activity or event, request support, interact with our social media accounts, submit your feedback and reviews or otherwise communicate with us. Please note that the provision of such data is optional and you may choose what personal data you would like to share with us. We kindly request you to exercise your due diligence when making your personal data publicly available. We will use such personal data to reply to you, provide you with the requested services, or for pursuing our legitimate business interests (i.e., to analyse and improve our business).
2.5 Sensitive data. We do not collect, under any circumstances, special categories of personal data (“sensitive data”) from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation, unless you decide to provide such sensitive data, at your own sole discretion.
2.6 Failure to provide personal data. If you fail to provide us with the personal data when requested, we may not be able to perform the requested operation and you may not be able to use the full functionality of FunFunding, receive the services provided through FunFunding, or get our response.
2.7 Personal data made public. If you decide to publish information about yourself in groups related to FunFunding, you may decide to reveal certain personal data. Please keep in mind that such data will become available to other users of FunFunding. Therefore, we request you to exercise your due diligence and not to disclose your personal data that is not necessary, extensive, or sensitive as such data can be used by third parties for unlawful purposes. Also, please note that you are not allowed to publish personal data pertaining to other persons if they have not provided you with their prior consent to disclose such data. We will take immediate steps to remove your messages from FunFunding if we become aware that they contain personal data disclosed unlawfully.
2.8 Privacy of communication. FunFunding allows you to exchange messages in groups related to FunFunding. We put reasonable efforts to ensure that any communication data transmitted through FunFunding remains confidential and properly protected. Moreover, we do not intentionally and directly access, manage, correct, delete, share, or disclose your messages, unless it is strictly necessary for provision of FunFunding, enforcement of our terms of service, or we are requested by law enforcement agencies to do so. You are solely responsible for any communication through FunFunding and the content of your messages.
3. NON-PERSONAL DATA
When you use FunFunding, we collect some technical data about your device and visits. In this section, we inform you what non-personal data we collect from you and for what purposes we use that data.
3.1 What non-personal data do we collect? When you use FunFunding, we automatically collect certain technical non-personal data about your use of FunFunding for analytics purposes. Please note that de-identified personal data is also considered to be non-personal data. Although such non-personal data allows us to analyse your use of FunFunding, it does not allow us to identify you. The non-personal data collected by us includes the following information:
The type of device that you use;
Operating system that you use;
The browser that you use;
URL address clicked from FunFunding; and
Your other online behaviour data.
3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response, if any. Where possible, we will de-identify your personal data.
3.3 How do we use non-personal data? We will use non-personal data for the following purposes:
To analyse what kind of users visit and use FunFunding;
To examine the relevance, popularity, and engagement rate of the content available on FunFunding;
To investigate and help prevent security issues and abuse;
To develop and provide additional features to FunFunding; and
To personalise FunFunding for your specific needs.
3.4 Aggregated and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.
4. MARKETING COMMUNICATION
From time to time, you may receive promotional messages from us. In this section, we explain when you may receive notices from us and what you can do to decline our commercial communication.
4.1 Marketing messages. To keep you updated about the latest developments related to FunFunding, our new services, additional features of FunFunding, and our special offers, we may send you marketing messages, such as newsletters, brochures, promotions and advertisements. You will receive such marketing messages or be contacted by us for marketing purposes only if:
We receive your express (“opt-in”) consent to receive marketing messages (please note that your voluntary subscription to our newsletters and updates substitutes such consent); or
We decide to send you marketing messages about our new services that are closely related to the services already used by you.
4.2 Opting-out. You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you or by contacting us directly.
4.3 Informational notices and service updates. From time to time (if we have your email address), we may send you important informational notices, such as service-related, technical or administrative emails, information about FunFunding, your privacy and security, and other administrative matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent.
5. HOW LONG DO WE KEEP YOUR DATA?
We store your personal data only if it is necessary for its specific and limited purposes. In this section, we specify the time period for which we keep your personal and non-personal data in our systems.
5.3 Retention as required by law. Please note that, in some cases, we may be obliged by law to store your personal data for certain period of time. In such cases, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
6. HOW DO WE SHARE AND DISCLOSE DATA?
We may need to cooperate with external service providers and share some personal data with them. In this section, you can find information about third parties that have access to your personal data and the instances when we make data transfers.
6.1 Do we disclose your personal data? If necessary, we will disclose your personal data to the service providers with whom we cooperate (our data processors). For example, we may share your personal and non-personal data with entities that provide certain technical support services to us, such as business analytics, advertising, and email distribution services, or if you explicitly request us to disclose the personal data.
6.2 When do we disclose your personal data? The disclosure of your personal data is limited to the situations when such data is required for the following purposes:
Ensuring the proper operation of FunFunding;
Ensuring the delivery of the services requested by you;
Providing you with the requested information;
Pursuing our legitimate business interests;
Enforcing our rights, preventing fraud, and security purposes;
Carrying out our contractual obligations;
Law enforcement purposes; or
If you provide your prior consent to such a disclosure.
Our hosting service provider Google (https://www.google.com) located in the United States;
Our transactional email service providers Gmail (https://www.gmail.com) located in the United States.
Our Web development and communication partner Wix (https://www.wix.com) located in Israel.
Our offer wall provider PollFish (pollfish.com) Located in the United States.
6.4 Sharing of non-personal data. Your non-personal data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving FunFunding, responding to lawful requests from public authorities or developing new products and services.
6.5 Legal requests. If requested by a public authority, we will disclose information about the users of FunFunding to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
7. INTERNATIONAL TRANSFERS OF PERSONA DATA
Your personal data may be transferred outside the country where you reside. In this section, we explain when we transfer personal data abroad and what safeguards we implement to ensure that your personal is properly protected.
8. PROTECTION OF PERSONAL DATA
We put our best efforts to keep your personal data safe and secure. In this section, we inform you about our technical measures that help us to protect your personal data.
8.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorized access, and disclosure. The security measures taken by us include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymisation of personal data (when possible). In order to ensure the security of your personal data, we kindly ask you to use FunFunding through a secure network only.
8.2 Handling security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
9. YOUR RIGHTS REGARDING PERSONAL DATA
You have the right to control how we process your personal data. Below, we list the rights that you can exercise with regard to your personal data and explain how you can exercise those rights.
9.1 What rights do you have? Subject to any exemptions provided by law, you may ask us to:
Get a copy of your personal data that we store;
Get a list of purposes for which your personal data is processed;
Rectify inaccurate personal data;
Move your personal data to another processor;
Delete your personal data from our systems;
Object and restrict processing of your personal data;
Withdraw your consent, if you have provided one; or
Process your complaint regarding your personal data.
9.2 How to exercise your rights? Please contact us by email at firstname.lastname@example.org and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable time-frame but no later than 2 weeks.
9.3 How to launch a complaint? If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
10. TERM, TERMINATION, AND AMENDMENTS
11. CONTACT US
You can contact us at any time to receive further clarifications. Our contact details are specified below.
Postal address for communication: FUN FUNDING LTD, Rotschild 2, Tel Aviv 6688102, Israel
Contact form: https://www.funfunding.org
Effective date: 29 November 2019
1. Responsible entity (data controller)
The data controller that is responsible for the processing of your personal data through FunFunding is FUN FUNDING LTD having a registered business address at Rotschild 2, Tel Aviv 6688102, Israel and the company registration number 515735363(“we”, “us”, and “our”).
2. What is a cookie?
A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, the website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device for certain period of time. Cookies are designed to allow the recognition of your device and collection of certain information about your use of a website. Thus, over time, cookies allow websites to “remember” your actions and preferences. There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the website itself) and (ii) third-party cookies (placed by third-party websites).
3. What cookies do we use?
We use two types of cookies on FunFunding, namely:
Technical cookies, which are essential to ensure the correct functioning of FunFunding and to provide the services requested by you;
Statistics cookies that allow us to generate statistical reports about how you use FunFunding; and
Marketing cookies that allow us to create and implement our digital marketing campaigns.
The table below provides an overview of our cookies, including their purpose and expiration time.
4. Cookie consent
5. How to disable cookies?
Google Chrome: https://support.google.com/chrome/answer/95647
6. Contact us
Postal address for communication: FUN FUNDING LTD, Rotschild 2, Tel Aviv 6688102, Israel
Contact form: https://www.funfunding.org