”Data Privacy Laws” means applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (2016/679) (the ”GDPR”).
“Processing” and “Process” means all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
“Services“ means our applications and other products, the Website, email communications, social media accounts and any related services or properties we control.
“Personal Data” means Personal Data that relates to you as an identified or identifiable individual.
All capitalised terms not specifically defined herein shall have the meaning ascribed to such terms in the GDPR.
Our Services are not directed to children and we do not knowingly collect Personal Data from children under 16 years of age.
1. Who we are
The Controller responsible for your Personal Data for the purposes of the GDPR is:
Six Waves Inc
Wanchai, Hong Kong
hereinafter referred to as the “Company”, ”we”, ”us” or “our”.
Data protection Officer
The data protection officer of the Controller for the purposes of the GDPR is:
Name: Peter Birgersson, Deloitte AB
Contact details: email@example.com
2. What information do we collect from you?
We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
3. How do we use your Personal Data?
We use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customise our Services to you, these include the following processing activities:
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
4. Who we share your information with
Other companies in the Stillfront Group, where they help us develop or operate our Services or other Services will receive access to all available Personal Data. For information on the entities within Stillfront Group, see the most recent annual report published on https://www.stillfront.com/en/reports-presentations/, as updated from time to time.
For analytical purposes, we collect automatically generated data such as your recent visits to our services and how you move around different sections, in order to make our services more intuitive and evaluate user needs and preferences. This data will be shared with a limited group of employees in the 6waves Group IT team.
Persons or companies that provide services to us and process Personal Data on our behalf when providing those services, for example, services that help us develop and operate our Services.
Professional advisors such as external legal and audit services etc. Personal Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means.
Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers such as Dropbox, Amazon Web Services, etc. Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means.
Competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation, such as the Authority for Privacy Protection in relation to any scrutiny of compliance with GDPR.
Any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests.
Please note this list is non-exhaustive and there may be other examples where we need to share data with other parties in order to provide the Services as effectively as we can.
When Personal Data is shared with our business partners, group affiliates or other trusted entities stated above, we always require them to only use information in accordance with our instructions.
5. Appropriate Safeguards to countries outside the EU/EEA-area
Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means. You are under Data Privacy Laws upon request entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outside the EU/EEA. You can do so by reaching out to our Data Processing Officer firstname.lastname@example.org.
6. How long do we keep hold of your information?
Your data is secured by appropriate safeguards, taking into account the circumstances, the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to protect your Personal Data against unauthorised or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorised access.
8. Your rights
In relation to our processing of your Personal Data you have, under certain circumstances, the right to exercise the following rights:
You may request confirmation whether or not Personal Data is processed and, if that is the case, access to your Personal Data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal Data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
Object to certain processing
You may object to the processing of your Personal Data on the basis of a legitimate interest, on grounds relating to your particular situation and to the processing for direct marketing purposes.
To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.
You have at any time the right to have inaccurate Personal Data rectified, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Data completed.
You may have your Personal Data erased under certain circumstances such as when your Personal Data is no longer needed for the purposes for which it was collected.
Restriction of processing
You may ask us to restrict the processing of your Personal Data to only comprise storage of your Personal Data under certain circumstances, such as when the processing is unlawful, but you do not wish your Personal Data erased.
Withdrawal of consent
You have the right to at any time withdraw your consent to processing of Personal Data to the extent the processing is based on your consent. This does not affect the lawfulness of processing based on consent before its withdrawal.
You may ask to receive a machine-readable copy of Personal Data processed and ask for the information to be transferred to another Controller (where possible). This only refers to such Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you and only to the extent the Personal Data has been provided to the Company by you (data portability).
Complaints to the supervisory authority
You have the right to lodge complaints pertaining to the processing of your Personal Data to the relevant data protection supervisory authority.
How to adjust your preferences
To access your data in our Services or to request its deletion, please use the automatic tools provided in our Services. These tools are specific to each of our Services. You will find them in the game settings under “Terms & Privacy” or a similarly named option. On the same page, you can also opt out of our personalized offers, where applicable. If you do not find these options in the game, then please send your request to email@example.com.
If you opt out of interest-based advertising, you will still be able to play our games and you may still see advertising in our games. You can also choose to prevent your device's ad identifier by changing the settings of your device.
We ask you to primarily use these tools to submit requests, because that helps us validate, process, and fulfil your request more quickly and reliably.
Last updated on: April 25 2023