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QCards Online  – Privacy Policy 

This Privacy Policy explains how we use personal data related to playing QCards Online. 
You can learn here what data we collect, how and why we use it, who we share it with and where we store it. You can also check the specific rights you have, when it comes to our processing of your data. 
 
Overview: 
● When you decide to play QCards Online we will need to collect some of your data. 
● We will mostly process your data to let you play QCards Online and to make the game as good as possible for all players. Other purposes include legal and compliance. 
● We will never sell your data or share it with third parties for their advertising purposes. 
● We will share some of your data with our trusted partners who help us operate QCards Online. 
● You can request that we access, update, move or delete your data or file a GDPR complaint. 
● If you have any questions, you can always contact us at contact@qplaylearn.com. 
 
1. WHO WE ARE 
1.1 We are QPlayLearn, a project of Algorithmiq Inc. (further “QPlayLearn”), a Finnish company acting as personal data controller under EU data protection legislation.  
You may contact us via email at contact@qplaylearn.com or by traditional mail: Algorithmiq Oy, Kanavakatu 3 C, 00160 Helsinki, Finland. 
 
1.2 To protect personal data in a better and more efficient way, we designated a Data Protection Officer (or DPO) who is responsible for the oversight and implementation of the data protection strategy and ensures compliance with necessary legal requirements. You can contact our DPO at the following email address: privacy@algorithmiq.fi    
 
2. WHAT THIS PRIVACY POLICY REGULATES 
2.1 This Privacy Policy applies to our video game “QCards Online” and all related services, including (not exclusively) qplaylearn.com website, QCards Online user accounts, customer and technical support, wikis, blogs, and social media services (we will further use the term “QCards Online” to talk about all of these together). 
 
2.2 Specifically, this Privacy Policy governs personal data (further “data”) or, as it is called in the United States, “personally identifiable information”, which we collect from you when you are using QCards Online. It essentially means information which, on its own, or in combination with other information, can be used to identify you. 
 
2.3 We respect your right to privacy and will only process your data in accordance with applicable legislation in the EU and other countries where we offer our games and services. 
 
3. PROTECTING DATA OBTAINED FROM MINORS 
3.1 You must be 16 years old or older to register for QCards Online and to play it. We do not deliberately process any personal data of minors below 16 years of age. 
 
4. HOW WE COLLECT YOUR DATA 
4.1 We may collect or process your data directly from you or through our Trusted Partners (see section 8 “Our Trusted Partners” below). This is basically: 
(a) data you give us via QCards Online, or which you give to our partners in connection with QCards Online; 
(b) data you give us when you contact us or report a problem with QCards Online; 
(c) data about your activity as a user of QCards Online (collected automatically); 
(d) data you put in our voluntary surveys conducted for research purposes. 
 
4.2 We and our partners also collect data about you via cookies. You can find out more about this, as well as manage your consents, by following the link to “Cookie Declaration” you will find in the footer of our websites. 
 
5. HOW WE USE YOUR DATA 
5.1 We may use your data for several purposes, relying on specific legal bases: 
(a) to perform the agreement with you (art. 6.1.b GDPR): 
● to provide you with QCards Online, 
● to maintain, improve and develop QCards Online, 
● to keep the ranking of QCards Online players, 
● to maintain technical support services, 
(b) to meet our legal obligations (art. 6.1.c GDPR): 
● for tax, legal and accounting purposes 
● for the accountability purposes as defined by EU legislation (GDPR) 
(c) to fulfill our legitimate interests, i.e. lawful purposes that could be reasonably expected from us in the context of QCards Online (art. 6.1.f GDPR): 
● to identify incidents of game misuse (anti-cheat analysis, anti-fraud checks), 
● to defend from or pursue legal claims, 
● to calculate scores and other elements of QCards Online performance, 
(d) your consent (art. 6.1.a GDPR): 
● to provide you with marketing information about products or services that you request from us and which we feel may interest you (newsletters), 
● to target and personalize our marketing communication, offers and advertisements that we display on our websites and services as well as those of third parties based on the combined data we have collected about you (profiling). 
For potential other purposes, we may also ask for your consent to process your data. Whenever we process your data based on your consent, you are entitled to withdraw your consent at any time. This will not invalidate the processing conducted before the withdrawal. 
 
5.2. When we transfer your data outside the European Economic Area, we do so on the bases described in section 8 “Our Trusted Partners”. 
 
5.3 Whenever we’re personalizing or targeting our marketing communications, offers and advertisements, we may profile your data. This means that we may adjust the communication addressed to you basen on the data, to better meet your needs. That being said, we don’t use your data for automated decision-making that could affect your legal situation (i.e. we do not use algorithms to make decisions which would have an impact on your individual legal rights or affect your legal status or rights under the agreement between us). For example, we do not make automatic offers based on your behaviour in the game). You can object to the profiling at any time. 
 
5.4 We might process some aggregated and general non-personal data on user behaviour with our partners who assist us in the process of running QCards Online. We may also share non-personal data with data analysis services to help us run QCards Online. For example, this may happen in case we need information about what kinds of kegs are the most popular in a given region. 
 
5.5 You can check the details of the data we collect about you in section 14 “What Data We Collect” at the end of this Privacy Policy. 
 
6. HOW WE HANDLE YOUR DATA 
6.1 We store your data on our secure servers in Europe or – if necessary – outside of Europe, on servers managed by our Trusted Partners (see section 8 “Our Trusted Partners” below). We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. We take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy. 
 
6.2 We will store your personal data for as long as we need it to fulfil the purposes outlined in this Privacy Policy. In more detail: 
(a) when a player creates (hosts) a game, a temporary game room is created, which appears in the list of games for other players; 
(b) after that, once all players leave the game room, no information about users persists. Only your mobile device stores the nickname chosen by the player, the name of the hosted room (also chosen by the player) and a unique ID for each room to synchronize results with other players; 
(c) we may also keep some of your data to defend ourselves from or to pursue legal claims, for no longer than 10 years; 
(d) we will keep your data collected from cookies for as long as indicated in the Cookie Declaration (link in the footer of our websites); 
(e) when we no longer require your data we will delete or anonymize it. 
 
7. WHO HAS ACCESS TO YOUR DATA 
7.1 In general only our authorized personnel have access to your data. 
 
7.2 Some QCards Online services may involve interacting with our Trusted Partners (see section 8 below). In such cases we may need to share some of your personal data with them. 
 
7.3 Please be aware that we are subject to various laws and may be required to release personal data to comply with law enforcement requests and/or other legal requirements. 
 
8. OUR TRUSTED PARTNERS 
8.1 We may share your data with the following Trusted Partners (formally called “data processors”). We always provide them with just the data that they need to perform their QCards Online-related services: 
● Photon Engine https://www.photonengine.com/ - privacy policy https://dashboard.photonengine.com/en-US/account/privacyandcookiepolicy 
● Unity https://unity3d.com/legal/privacy-policy 
● partners who provide us with error tracking and crash reporting tools, 
● partners who help us in data analysis by providing us with analytical tools, 
● social media platforms, for the purpose of personalized and targeted marketing. 
 
8.2 When required by law, we may also share your data with the police or other government authorities (including your IP address and details of suspected unlawful or fraudulent activity). 
 
8.3 Your data may be processed, stored and transferred to countries outside the European Economic Area (EEA), such as Switzerland or the United States. Privacy laws in these countries may not offer the same level of protection as in your country or in the EEA. But whenever we share your personal data outside the EEA, we will do so on the basis of EU standard contractual clauses or other lawful measures, to ensure security of your data. 
 
9. THIRD PARTY SERVICES 
QCards Online may, from time to time, contain or connect you with third party content or services. Our Privacy Policy does not extend to external sites or companies, so please refer directly to their privacy policies. 
 
10. YOUR RIGHTS AND COMPLAINTS 
10.1 You have the right to object to the processing of your personal data at any time, such as for marketing reasons. 
 
10.2 You have the following additional rights: 
● You have the right to access data held about you; 
● You may contact us to request that we delete your data from our system; 
● You may ask us to rectify/correct your data, if appropriate; 
● You may ask us to restrict the processing of your data; 
● You have the right to transfer your data to another entity; 
● You have the right to file a complaint with a data protection authority. 
 
10.3 To exercise your rights or in case of any concerns or questions about your privacy, please contact us and we will do our best to assist you. You can reach us at contact@qplaylearn.com or contact our Data Protection Officer privacy@algorithmiq.fi. 
 
11. CHANGES TO THIS PRIVACY POLICY 
11.1 We may change this Privacy Policy if necessary, for example for legal reasons or to reflect changes in our services. If we do so, we will make the altered Privacy Policy available online and update the “Last Updated” date. 
 
11.2 If you don't agree to the changes (regardless of whether you contact us), you should stop using QCards Online. This stems from the need to have every player observing the same rules, so our services can function properly. 
 
12. WHAT DATA WE COLLECT 
When you sign up for, download, use or play QCards Online, we may collect certain data about you, like your name or any username used to identify yourself, avatars, log of user activity within QCards Online (login time, logout time, log of matches played, number of wins and losses, gathered experience points), IP address, location, language (inferred from your IP address), country of origin, network latency, data about your device/platform, and any other data which you submit to us through QCards Online. 
 
We do not receive nor store any of your payment details. This is fully handled by the relevant payment platform. 
 
When you visit QPlayLearn.com we may collect the following data: 
● technical details about any device which you use to access our services, including: Internet and/or network connection (including IP address), country (inferred from your IP address), any mobile device identifier; your operating system, browser type or other software; or your hardware or other technical details; 
● data collected via cookies and/or similar tracking technologies. 
 

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