Effective Date: July 1, 2024Last update date: August 2, 2024
UNUSUALL VENTURES, S.L. (hereinafter, "UnusuAll" or the "Company"), along with its subsidiaries and affiliates, collects, uses, and discloses personal data of each user ("User") in accordance with the Legal Notice. The processing of your personal data will be governed by this privacy policy ("Privacy Policy") and any future replacements. Any User who does not agree with the Privacy Policy or the Legal Notice should refrain from accessing, completing forms, or otherwise using our games, websites, applications, and other services (hereinafter collectively referred to as the "Software").
This Privacy Policy applies to the processing of any information that allows the direct or indirect identification of a person. Such information may include, among other things, your name, postal address, email address, and phone number (hereinafter, "Personal Data").
Information that has been anonymized or aggregated in such a way that there is no possibility of using it to identify a person, either on its own or in combination with other information, will not be considered Personal Data.
1. Data Controller
The entity responsible for the collection and processing of your personal data on the Software is UnusuAll, with tax identification number B-01589100, registered office at C/Fornells, 9, Las Rozas de Madrid, Postal Code: 28290, Madrid, Spain, and email address for this purpose privacy@unusuall.com.
The Company is committed to the privacy of personal data of its Users and, for this purpose, has a data protection officer to whom notifications can be addressed. The contact details of the data protection officer are as follows:
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Company |
UNUSUALL VENTURES, S.L. |
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NIF |
B-01589100 |
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Registered office |
Calle Fornells, 9, Las Rozas de Madrid, C.P.:28290, Madrid, España. |
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2. Your consent to collection, use, and disclosure
We collect, use, and disclose your Personal Data with your consent or as permitted or required by law. How we obtain your consent (i.e., how we use it) will depend on the circumstances and the sensitivity of the information collected. Under applicable laws, your consent may be express or implied, depending on the circumstances and sensitivity of the Personal Data involved. By choosing to provide us with your Personal Data, we assume that you consent to its collection, use, and disclosure as outlined in this privacy policy.
Generally, we seek your consent at the time of collecting your Personal Data. If we intend to use your Personal Data for a purpose not previously disclosed at the time of collection, we will seek your express consent before using that information for the new purpose.
3. Information collected on the Software
The Company collects different information that User submit directly or indirectly:
Data received directly
a) Account data: It is not necessary for the User to create an account to play our games. However, we may provide the ability to create a public username.
b) Gamer programs: If the User signs up for one of our gamer programs, we may collect other information such as their name, email address, and postal address. Additionally, we may collect other information from influencers or collaborating parties, depending on the nature of the relationship.
c) Purchase data: If you choose to purchase any virtual products as part of your use of the Services, to the extent available, we or third-party service providers may collect your purchase history. All payments made through our Services are processed by external payment processing agencies: we do not collect or store any payment card or banking information entered through our Services, but we may receive data associated with your payment card information (e.g., billing details).
d) Communication with us: When the User requests information about our services, seeks customer support or technical assistance, or communicates with us in any other way, we may collect Personal Data such as their email address, phone number, or postal address.
e) Surveys: We may contact the User to participate in surveys. If they choose to participate, we may collect their Personal Data related to the survey.
f) Interactive features: We and others using our Services may collect Personal Data that the User submits or discloses through our interactive features (e.g., messaging and chat functions, comment functions, forums, blogs, and social media pages). Any information provided through the public interaction features of the Services will be considered "public," unless applicable laws require otherwise, and will not be covered by the confidentiality protections referred to herein. Please exercise caution before disclosing information that could allow others to identify you in the real world.
g) Sweepstakes and contests: We may collect Personal Data that the User provides to us for sweepstakes or contests offered through our Software or on our social media profiles.
h) Conferences, trade shows, and other events: We may collect Personal Data from individuals when we organize or attend conferences, trade shows, or other events.
i) Business development and strategic collaboration: We may collect Personal Data from individuals and third parties to evaluate potential business opportunities.
j) Job applications: On our website, we post our vacancies and job opportunities. If the User responds to one of these postings, we may collect their personal data to begin the corresponding selection process. This data will be retained for the legally established period of one year.
Data received indirectly
Additionally, the Company may collect User data when accessing the Software through cookies and other similar technologies. For more information in this regard, please refer to our Cookie Policy.
4. Purpose of processing
UnusuAll processes personal data for a wide range of both commercial and administrative purposes, including:
4.1. Providing products, services, and requested information, which includes managing User information and accounts; responding to questions, comments, and other requests; providing access to certain areas, features, and tools of our services; responding to customer or technical support requests; and allowing you to register to participate in events.
4.2. Measuring interest and participation in our Software; conducting research and development activities; improving or developing new products and services; ensuring internal quality control;
4.3. Verifying the identity of a person, for example, for requests to exercise their rights under this Privacy Policy; communicating with the User regarding their account, activities in our Services, and changes to our policies; processing their financial information and other payment methods for purchased products or Services; processing requests and transactions;
4.4. Preventing activities that could be prohibited or illegal; and enforcing our terms.
4.5. Offering for sale our products and Services, which includes providing material about offers, products, and Services that may be of interest, including new content and Services. We may provide such material as permitted by applicable law. Some of the ways we offer products include email campaigns, targeted advertising to specific audiences, and "interest-based" or "personalized" advertising, which may include cross-device tracking. Such uses include tailoring content, notices, and offers to each profile; notifying about offers, products, and services that may be of interest; providing Services to the User and our sponsors; and other purposes to which each User agrees and is informed of when providing their personal data.
4.6. We may use personal data and other information about each User to create anonymous or aggregated information, such as anonymous demographic information, anonymous location information, trends, reports, or aggregated statistics, anonymous or aggregated information about the computer or device from which they access our Services, and other analyses that we generate.
4.7. We may implement automated decision-making, including user profiling. For example, we may implement it to match users with similar skill levels in online games.
5. Use of data and legal basis
The precise manner in which the Company uses Users' Personal Data will ultimately depend on each User's use of the Software.
In any case, the Company allows Users to change their preferences regarding the use of their Personal Data for any of the described purposes. However, Users are aware that any changes in this regard may result in the User losing certain quality and features in the services provided through the Software.
The Personal Data provided will not be shared or used for purposes other than those outlined in this Privacy Policy.
6. Who has Access to Users’ data? Who are the recipients?
The personal information of Users will only be accessible in accordance with this Privacy Policy and to the following recipients:
6.1. UnusuAll. For internal administrative and management purposes.
6.2. Service Providers. The Company may use other companies to provide certain services under its guidelines. For the provision of such necessary services for the operation of the Software (for example, consultancy, auditing, or IT maintenance), these third-party companies may need certain information and data from Users. The Company ensures that, in such cases, these third parties will have limited access to Users' information to the extent necessary to perform the assigned tasks, will sign a data processing agreement with the Company, and will be obligated not to disclose the information or use it for purposes other than providing the corresponding service.
6.3. Business Partners. The Company may share User information and data with other business partners to offer certain products, services, or promotions.
6.4. Other Users. When a User shares personal information or interacts in public areas with other users, such information may be viewed and may be publicly distributed outside. If the User interacts with other users or registers through third-party social networks, their information may be accessible to this third party, as well as other users, to facilitate communication among them.
6.5. Disclosures Required by Law. The Company may disclose Personal Data and information provided by Users when required by law, in a judicial proceeding, to investigate suspicious activity, or otherwise to protect its own rights and those of Users. In such cases, the Company undertakes to notify Users that their data has been legally requested, to the extent possible and where such notification is not incompatible with the purpose for which the data was initially disclosed.
This outlines who may access Users' data and under what circumstances, ensuring transparency and compliance with privacy regulations.
7. Data retention
The Company retains most of the Personal Data for as long as necessary to fulfill the purposes outlined above. Once these purposes are fulfilled, the Company will retain the Personal Data, blocked, to the extent that liabilities may arise for the Company or as otherwise legally required. Where possible, information will be anonymized once the User has closed their account.
8. Where are the Personal Data stored?
The Company collects, stores, and processes Users' Personal Data on various servers located in the United States of America, Ireland, Japan, and Israel through the Wix platform.
9. Representations and warranties
Users warrant that the Personal Data provided is true and accurate, and undertake to notify any changes or modifications promptly. They will be responsible for any loss or damage caused to the Software, the Company, or any third party due to the communication of false, inaccurate, or incomplete information.
10. Security of Users’ Personal Data
UnusuAll cares about the security and protection of its Users' Personal Data and strives to prevent security breaches.
To this end, the Company adopts and implements necessary technical and organizational measures to ensure the confidentiality, integrity, and security of personal data, and to prevent its loss, alteration, unauthorized access, or processing, taking into account the state of technology and the nature of the stored data. Additionally, the Company regularly monitors its systems to detect potential vulnerabilities and attacks.
However, Users are aware that internet security is not infallible, and there is no guarantee that data cannot be accessed, disclosed, altered, or destroyed in the event of a breach in any of the installed security measures.
11. Additional Information for Residents of California, Virginia, Connecticut, Utah, Colorado, and Nevada
Personal Data we Collect and Share:
The information we have collected within the last twelve (12) months about you, as well as the categories of third parties with whom we have shared this information, are described in the table below.
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Category of Personal Data Collected by UnusuAll |
Category of Third Parties Personal Data is Disclosed to for a Business Purpose |
Category of Third Parties to Whom Personal Data is Sold And/or Shared |
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Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
· Service providers · Other users · Advertising partners · Data analytics providers · Social networks |
· Advertising Partners · Data analytics providers · Social networks |
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Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number, or financial information. |
· Service providers · Advertising partners · Data analytics providers |
· Service providers · Data analytics providers |
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Protected classification characteristics under California or federal law Age. |
· Service providers · Advertising providers · Data analytics providers |
· Service providers · Advertising providers · Data analytics providers |
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Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
· Service providers · Advertising partners · Data analytics providers |
· Service providers · Advertising partners · Data analytics providers |
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Geolocation data Physical location or movements. |
· Service providers · Advertising partners · Data analytics providers |
· Service providers · Data analytics providers |
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Sensory data Audio, electronic, visual, or similar information. |
· Service providers · Other users · Advertising partners · Data analytics providers · Social networks |
· Advertising Partners · Data analytics providers · Social networks |
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Inferences drawn from other Personal Data to create a profile about a consumer Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
· Service providers · Other users · Advertising partners · Data analytics providers · Social networks |
· Advertising Partners · Data analytics providers · Social networks |
11.1. Use of Personal Data:
We may use or disclose the Personal Data we collect for the purposes outlined in Use of Information above. Where required under applicable law, we will not collect additional categories of Personal Data or use the Personal Data we have collected for materially different, unrelated, or incomplete purposes without first providing you notice.
11.2. Sales/Sharing/Targeted Advertising:
Some of our disclosures of Personal Data may be considered a “sale” or “share” as those terms are defined under applicable law. In many states, a “sale” is broadly defined to include a disclosure for something of value, and, in California, a “share” is broadly defined to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the categories of Personal Data as described in the table above.
11.3 Your Rights:
Subject to applicable law (and verification as applicable) you have the right to request the following from us:
We will not discriminate against you, in terms of price or services that we offer, if you exercise any of the rights listed above.
Verification and Appeal Process: We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If we are unable to process your request via you authenticating yourself on the Services, we may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and phone number. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.
If you are a resident of Colorado, Virginia, or Connecticut, you have the right to appeal a request we deny when we have verified your identity and still decline to honor your request. The process for that appeal will be sent to you separately if your request is denied.
Authorized Agent: Depending on where you live, you may have the right to use an authorized agent on your behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a user to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the consumer. If you are an authorized agent trying to opt out of selling, sharing, and targeting advertising on behalf of a consumer, then you can make a request on the consumer’s behalf by mail at UnusuAll Ventures SL C/ Fornells, 9. 28290. Las Rozas de Madrid. Spain., or by contacting us at privacy@unusuall.com. If you are an authorized agent trying to exercise data access, correction, or deletion rights on behalf of a consumer, then you can make a request on the consumer’s behalf by mail at UnusuAll Ventures SL C/ Fornells, 9. 28290. Las Rozas de Madrid. Spain., or by contacting us at privacy@unusuall.com. If you are an authorized agent trying to exercise any other privacy right on behalf of a consumer, you may contact us at privacy@unusuall.com. To the extent permitted by applicable law, such requests must include the following information: (1) a written authorization from the consumer that includes the consumer’s first name, last name, and valid email address used by the consumer to interact with us, that is signed by the consumer and clearly bestows upon the agent the proper authority; and (2) a certificate of good standing with your state of organization. Alternatively, an acting agent can provide a valid power of attorney signed by the consumer on the agent’s behalf and a valid email address used by the consumer to interact with us. The email address of the consumer will be used to separately verify the agent’s authority with the consumer. The consumer may then be directed to submit a request through the designated methods above.
Refer-a-Friend, Promotions, and Similar Incentive Programs: We may offer referral programs, promotions such as sweepstakes, or other incentivized information collection programs. We may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide Personal Data regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) Alternatively, we may ask you to provide your Personal Data in exchange for a reward or participation in a promotion. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your information to us depends on how you ultimately use our Services, whereas the value of the referred party’s information to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program. You may withdraw from the incentives at any time. In order to withdraw from the financial incentive, please contact us as described below.
Shine the Light Disclosure: California residents are entitled to ask us for a notice that identifies the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and provides contact information for such affiliates and/or third parties. If you are a California resident and would like this information, please submit a written request to us using the contact information below.
12. International Transfer
All Personal Data collected by UnusuAll may be transferred, processed, and stored anywhere in the world, including but not limited to the United States in order to provide the Services. As such, your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you choose to provide Personal Data to us, UnusuAll will transfer your Personal Data in accordance with the table below in order to provide the Services.
If we transfer Personal Data which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for internal transfers of your Personal Data, please refer to the table below or contact us as set forth below.
Table titles:
- Transferee: Transferee & Contact Information
- Country: Country of Transfer (location of storage subject to change from time to time)
- Date: Transfer Date & Method
- Purpose: Purpose of Transfer
- Types: Types of Personal Data Transferred
- Period: Retention Period
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Transferee |
Country |
Date |
Purpose |
Types |
Period |
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Jam City, Inc. privacy@jamcity.com |
United States |
Online transfer when using the Services |
Providing the Services; Analytics – User Behavior and Demographics Analysis; Advertising – Market Our Products and Services; Customer Support – Answer Requests for Customer or Technical Support |
D0evice ID, Username, IP address, Cookies |
Until no longer necessary to provide the Services or fulfill the purposes below |
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Google, LLC: Opt-out: http://tools.google.com/dlpage/gaoptout |
United States |
Online transfer when using the Services |
Providing the Services; Advertising – Market Our Products and Services |
Device ID, Username, IP address, Cookies |
Until contract ends |
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Microsoft Co. Opt-out: https://go.microsoft.com/fwlink/?LinkID=286759 |
United States |
Online transfer when using the Services |
Providing the Services |
Device ID, Username, IP address |
Until contract ends |
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Meta Platforms, Inc. Opt-out: https://www.facebook.com/privacy/policy?section_id=6-HowCanYouManage |
United States |
Online transfer when using the Services |
Providing the Services; Advertising – Market Our Products and Services |
Device ID, Username, IP address |
Until contract ends |
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Adjust, Inc. https://www.adjust.com/terms/privacy-policy/ |
United States |
Online transfer when using the Services |
Analytics – User Behavior and Demographics Analysis |
Device ID, Username, IP address |
Until contract ends |
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Helpshift, Inc. privacy@helpshift.com |
United States |
Online transfer when using the Services |
Customer Support – Answer Requests for Customer or Technical Support |
Device ID |
Until contract ends |
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Apple Inc. https://searchads.apple.com/privacy |
United States |
Online transfer when using the Services |
Advertising – Market Our Products and Services |
Device ID, IP address |
Until contract ends |
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Unity Technologies ApS https://unity.com/legal/game-player-and-app-user-privacy-policy |
United States |
Online transfer when using the Services |
Advertising – Market Our Products and Services |
Device ID, IP address, Cookies |
Until contract ends |
13. Your Rights
13.1. In accordance with applicable law, Users who have provided their Personal Data may request the exercise of their rights to access Personal Data, rectify or delete it, limit its processing, object to its processing, and the right to data portability, as well as withdraw consent given, by written notification addressed to: privacy@unusuall.com
a) Data Access. Users may access their Personal Data at any time and request information regarding the processing of their data.
b) Data Rectification. Users have the right to request the rectification of Personal Data that is inaccurate or incomplete.
c) Limitation of Data Processing. Users have the right to request the limitation of the processing of their Personal Data when legally established.
d) Objection to Processing. Users may object to the processing of their Personal Data when legally established.
e) Data Portability. Users have the right to receive their Personal Data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
f) Withdrawal of Consent. Users may withdraw the consent given at any time when this is the legal basis for processing. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
If necessary for the unequivocal identification of the User, the Company may request a copy of the User's ID card, passport, or other valid identification documents, in legally established cases.
In any case, Users may also file a complaint with the competent supervisory authority, in this case, the Spanish Data Protection Agency through its website.
If you are a resident of Colorado, Virginia, or Connecticut, you have the right to appeal a request we deny when we have verified your identity and still decline to honor your request. The process for that appeal will be sent to you separately if your request is denied.
Shine the Light Disclosure: California residents are entitled to ask us for a notice that identifies the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and provides contact information for such affiliates and/or third parties. If you are a California resident and would like this information, please submit a written request to us using the contact information below.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@unusuall.com with the subject line ‘Nevada Do Not Sell Request’ and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.
14. Children’s Privacy Policy
We take additional steps to limit access to our Services based on the user’s age. For these services, when a user indicates they are under 13 (or the applicable age in their territory), we will limit their access to certain features, such as social media plug-ins, chat features, and certain types of notification alerts. For known underage users, we also limit personal data collection and sharing to only what is necessary to support the internal operations of our Services.
If you are a parent or guardian and have any concerns regarding the service, wish to review information collected from your child, or have that information modified or deleted, you may contact us at privacy@unusuall.com. If we become aware that a child has provided us with Personal Data, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.
15. Change on Privacy Policy
The Company reserves the right to modify this Privacy Policy based on new legislative or regulatory requirements, for security reasons, or to adapt the policy to the instructions of data protection supervisory authorities or new processes.
When significant changes are made to this Privacy Policy, Users will be notified through the Software to give all Users the opportunity to review the changes and, if necessary, accept them before they take effect.
16. Contact
For any questions or inquiries about this Privacy Policy, please do not hesitate to contact us by sending an email to privacy@unusuall.com.
If you have any questions regarding the content, data processing, exercise of rights, or any inquiry related to this Privacy Policy, please contact us by sending an email to the following address: privacy@unusuall.com or by mail to UnusuAll Ventures SL C/ Fornells, 9. 28290. Las Rozas de Madrid. Spain.