PRIVACY POLICY – GDPR

1. General

Romain Bayer processes personal data in the course of its activities.

Personal data should be understood as any information about an identified or identifiable person.

Processing should be interpreted broadly and is any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

As Romain Bayer values and respects the privacy and security of personal data, such personal data will only be processed in accordance with (i) the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, better known as the General Data Protection Regulation (GDG) or the General Data Protection Regulation (GDPR), as well as with (ii) all applicable national regulations.

This privacy policy aims to provide you with transparent information regarding:

1. The controller of your personal data
2. The purposes for which your personal data are processed
3. The period for which personal data will be stored
4. Your rights in relation to this processing
5. Our obligations in relation to such processing
6. Cookies

2. The controller of your personal data

Romain Bayer, registered in the Crossroads Bank for Enterprises under number 0794.427.129, with its registered office at 2900 Schoten on Villerslei 71, is the controller of your personal data.

Romain Bayer establishes the purposes and means of processing personal data.

Romain Bayer does so in its capacity with whom you have a contractual relationship (directly or indirectly) as a customer or as a supplier, or from whom you visit the website.

3. The purposes for which your personal data are processed

How. Romain Bayer collects personal data through (i) agreements that you conclude (directly or indirectly) with us, (ii) voluntary provision of such data by the data subject (whether or not via contact forms), (iii) through the use of our website and social media (which includes associated technologies such as cookies).

What: Personal data collected by Romain Bayer are:

• App info and performance.
• Personal information (User Ids)
• Precise and approximate location
• Financial info for Purchase history
• App activity

Why? Personal data are always collected and processed by Romain Bayer for one or more specified purposes. The purposes for which Romain Bayer processes personal data are the following: (i) to perform the contracts concluded with it, (ii) to comply with applicable legal obligations, (iii) for marketing purposes (which you may object to at any time), (iv) to improve our services.

Consequence when not providing? The provision of personal data is a necessary condition to conclude an agreement. If the required personal data is not provided, a contract cannot be concluded.

4. The period for which personal data will be stored

Your personal data will be kept for as long as necessary to achieve the purpose for which it was collected, in line with the legal, regulatory and internal requirements in this regard, and no longer than 2 years after the end of the contractual relationship. This provision obviously does not affect your rights as shown infra sub. 5.

5. Your rights in relation to this processing

Right to withdraw consent: You always have the right to withdraw your consent as described infra sub. 6 to withdraw it. Naturally, this does not affect the lawfulness of the processing prior to this withdrawal.

Right of inspection: You always have the right to obtain from Romain Bayer conclusive information on whether or not your personal data are being processed, as well as to inspect them.

Right of rectification: You always have the right to obtain rectification of inaccurate personal data from Romain Bayer without delay.

Right to data erasure: You have the right to obtain from Romain Bayer the erasure of personal data without unreasonable delay in the following cases: (i) the personal data are no longer necessary for the purposes for which they were collected, (ii) the consent on which the processing is based is withdrawn, (iii) you object to the processing which is justified by public or legitimate interest, or which is done for the purpose of direct marketing, (iv) the personal data have been processed unlawfully, (v) the personal data must be erased in order to comply with a legal obligation, (vi) the data were obtained in connection with an offer of information society services to a child.

Right to restriction of processing: In a number of exhaustively listed situations, you also have the right to restrict processing, notably.: (i) where the accuracy of the personal data is contested, and for a period enabling the controller to verify the accuracy of the personal data, (ii) where the processing is unlawful and the data subject objects to the erasure of the personal data, (iii) where Romain Bayer no longer needs the personal data for the purposes of the processing, but the data subject needs them for the establishment, exercise or defence of legal claims, (iv) where the data subject has objected to the processing.

Right to data portability: You have the right under certain circumstances to obtain your personal data in a structured, common and machine-readable form, and to transfer it to another controller.

Right to oppose marketing purposes: You have the right to oppose the use of your personal data for direct marketing purposes at any time.

6. Our obligations in relation to such processing

Principles of processing: Romain Bayer will always process personal data in accordance with the following principles: (i) in a manner which is lawful, proper, and transparent in relation to the data subject, (ii) for specified, explicit and legitimate purposes, (iii) relevant and limited to what is necessary for the purposes for which they are processed, (iv) data will be accurate and, where necessary, kept up to date, (v) will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, (vi) all appropriate technical or organisational measures will be taken to ensure that personal data will be processed in a manner that ensures adequate security and that they are protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

Lawfulness of processing: Romain Bayer is entitled to process personal data only if one of the following conditions is met: (i) you have given your express consent to do so, (ii) the processing is necessary for the performance of a contract to which you are a party (directly or indirectly), (iii) the processing is in the context of a legal obligation of Romain Bayer, (iv) the processing is necessary to protect your vital interests or those of other natural persons, (v) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, or (vi) processing is necessary for the protection of the legitimate interests of the controller (except where such interests are overridden by the interests of the data subject).

Sharing of personal data: Your personal data is only accessible at Romain Bayer by himself, his employees and collaborators who need to access this personal data as part of their duties. These employees and collaborators are bound by strict internal rules regarding the processing of personal data. When Romain Bayer uses external parties for the purpose of processing personal data, it will only use parties that provide adequate guarantees so that the processing complies with legal requirements and your rights are safeguarded.

7. Cookies

Cookies are small files that the server installs on your computer, necessary for browsing. Certain other cookies have other functions, such as remembering the Internet user’s details when logging in as a registered member on a website. Certain pages of the website use cookies to remember preferences or for technical reasons.

You will be asked to consent to the placing of cookies on your device when using the Romain Bayer website (with the exception of purely technical cookies that do not require explicit user consent).

Cookies are not kept longer than necessary with a maximum retention period of 90 days .

Romain Bayer uses Unity Privacy Policy (https://unity.com/legal/game-player-and-app-user-privacy-policy) to collect the following data:

1. App info and performance for Diagnostics App functionality & Analysis.
2. Personal information (User Ids) for App functionality.
3. Precise and estimated location for App functionality, Analytics, Advertising or marketing,
   Fraud prevention and Security / compliance.
4. Financial info for Purchase history : Analysis & Advertising or marketing.
5. App activity for Analysis, Advertising or marketing, Fraud prevention, Security & compliance.

Romain Bayer also uses MailerLite ( https://www.mailerlite.com/legal/privacy-policy) for its newsletters based on collected e-mail addresses, subscription dates and location of subscribers.

• If you do not want cookies to be placed on your computer, your browser settings can be adjusted accordingly.

8. In conclusion

This privacy policy may be modified at any time in the future, with future changes or modifications always being communicated to you in advance.

We have endeavoured to provide you with transparent information on your rights and the obligations of Romain Bayer in connection with the processing of personal data through this privacy policy. Should there nevertheless still be any uncertainties, should you require further information or have any questions, we will be happy to help you.

To contact us, or to exercise any of Your Data Protection Rights, please send an e-mail to privacy@bayergames.com or a letter to Romain Bayer. When exercising Your Rights, your letter or e-mail should be accompanied by a copy of your identity card or passport so that your identity can be verified.

Should you have any complaints and/or suggestions regarding the way we process your personal data, we would be happy to hear from you. Romain Bayer attaches great importance to safeguarding your rights. We also inform you that you always have the right to lodge a complaint with the supervisory authority, i.e. the data protection authority.