Privacy Statement - EEA

Please carefully read the following Privacy Policy

Version 21 July 2021

1. General information

   Imperia Web Network Ltd is committed to protecting the privacy of everybody who uses our website and applications. This privacy statement -"Website Privacy Statement Imperia Web Network Ltd - EEA", or "Privacy Statement" for short, is meant to provide transparency to Imperia Web Network Ltd's privacy practices and principles. It provides data about what we collect through our lupygames.co.uk web platform, our Imperia Web Network Ltd for Developers platform, our mobile applications from website visitors from the European Economic Area (EEA)* ("Website Visitors") Data information. General audience websites and applications (hereinafter together referred to as "Imperia Web Network Ltd Website"). Please click this link for an overview of the domain called "Lupy Games Site". The Imperia Web Network Ltd website is exclusively for website visitors ("Site Visitors") aged 16 and above. If you are under 16, this website is not for you. This site is a safe environment for children under 16 years of age. To view our privacy practices in specific to the Imperia Web Network Ltd for Kids website, please refer to the Children's Site Privacy Statement-EEA. If you have any inquiries about this privacy statement, please contact us at [email protected]. The Imperia Web Network Ltd website and Imperia Web Network Ltd for Kids (collectively referred to as "all Imperia Web Network Ltd websites") are operated by Imperia Web Network Ltd BV (referred to in this privacy statement as "Imperia Web Network Ltd", "we", "our" or " us"). Imperia Web Network Ltd is an entity incorporated under the laws of the "COUNTRY". * Do note that we determine from which region you visit our website by your IP-address, thus if you use a VPN-connection, you may not be shown the Privacy Statement applicable to you.

2. Which personal data is used and for what purposes?

   All functions on the Imperia Web Network Ltd website can be used without registration of website visitors. Site visitors will not be asked for personal data (e.g. email address and phone number). In addition, our game developers will remove all outgoing links and branding/advertising (such as splash screens, social links and app store links) from the games in principle. Nevertheless, Imperia Web Network Ltd does collect certain digital data. We can process this personal data in various ways. Please find general information about our processing of your personal data directly below. Here, you will find a brief review of the various topics that you can click on to learn more details about the processing of your personal data in that context.

General processing purpose

In general, we may process your personal data with the following goal:

• For maintenance, management, and network and security purposes;
• Used for internal control and business operations;
• Used to analyze and improve our products;
• Handle any requests, complaints and disputes;
• Used to determine, exercise and defend our rights;

Comply with legal obligations (including fraud prevention) and the requirements of authorized government agencies. General processing grounds Generally speaking, we may process your personal info according our legal obligations. This means that we will process your personal data as far as legal obligations go. Such as complying with the legal minimum retention period.

Legitimate interest

Sometimes, we may indicate that we process your personal data based on the legal basis of "legitimate interest". This means balancing the interests of dealing with the interests of the service on the one hand and your privacy interests on the other, and the interests of the processing takes precedence. Each topic below contains related legal rights. If you want to know more about that, you can contact us directly through the contact information listed below.

Minors and other people with a legal representative: The Imperia Web Network Ltd website is not addressed to people under 16 years of age. We also do not focus on people who are placed in a legal relationship, such as guardians or people who are supervised or managed by others.

The General Imperia Web Network Ltd Website: We process personal data for providing, maintaining, and improving our websites, our apps, and for our social media activities.

The people involved: Our website visitors: people who visit the Imperia Web Network Ltd website.

Purpose of processing: Should you visit the Lupy Games Ltd website, we will process your personal data for the following purposes:

• Operation of the Imperia Web Network Ltd website (including remembering your settings and agreeing to choices);
• Advertisement and marketing to you, targeted advertising, and provide you with relevant offers;
• Show you the privacy info related to your region (the specific personal data we process depends on the region where you visit the Imperia Web Network Ltd website).

Personal data processed

When you visit the Imperia Web Network Ltd website, we may process the following (personal) information collected automatically:

• IP address;
• device ID;
• Browser type;
• Global geographic region (e.g. country or city level location);
• The advertisements shown to you and your interaction with them (for example, whether you clicked on that advertisement);

Other technical information, such as information about the interaction between your device and our website, web pages visited, links clicked, and log data.

Sensitive data: In the context of the Imperia Web Network Ltd website, we do not process sensitive information in principle. If we decide to process sensitive information under certain conditions, you will be separately notified of this processing and asked for your explicit consent when necessary.

Legal basis for processing

We use your personal data in the context of the Imperia Web Network Ltd website based on one of the following legal grounds:

• Agreement: Sometimes, we process personal data based on the explicit agreement of the relevant person. For example, this applies to cookies and similar technologies that we only agree to use in our cookie pop-up window.
• Legitimate interest: We have legitimate rights and interests in providing and using our website, applications, and social media; and pursuing the other processing purposes listed above.
• Social media platform: Imperia Web Network Ltd uses diverse social media platforms, for example in the context of recruitment, selection, and for marketing purposes. Imperia Web Network Ltd is responsible for the content of the Imperia Web Network Ltd website but is not responsible for the management of the company's social media outlets. For more information on how such social media websites are using your personal data, we will refer to the information already on the websites of these platform providers. Below we provide links to the privacy policies of various social media platform providers:
  • Facebook;
  • Twitter;
  • Instagram;
  • YouTube;
  • LinkedIn;
  • Google;
  • Reddit.

Imperia Web Network Ltd for Developers (secondary domain: developers.lupygames.co.uk)

The people involved: Game developers who provide games for the Imperia Web Network Ltd website through the Imperia Web Network Ltd for Developers platform have signed a contract with us.

Purpose of processing: When you visit our Imperia Web Network Ltd for Developers platform, we will compute your personal info for the following purposes:

• Provide you with information about applicable conditions;
• Provide you with a financial overview of your account and related invoices;

To provide you with information about our SDK (software development kit), for example, in principle, you need to remove all outgoing links and branding/advertisements (such as splash screens, social links, and app store links) from the game.

The personal data that is processed: On our Lupy Games Ltd for Developers platform, we may process the following personal data:

• Full name;
• E-mail address;
• Phone/skype/discord;
• Name company/studio;
• Contract details;
• Financial details;
• Game(s) and related details such as game title and description, No. of app installs, App store URL, Web build URL;
• Communication details incl. how you heard about us.

Legal basis for processing: We use your personal data in the context of developer.lupygames.co.uk based on one of the following legal bases:

• Contracts: If you have signed a contract with us, we will process your personal information in its context. For example, make sure you receive the payment due.
• Legitimate interest: We provide you with a developer platform and legal rights to pursue other processing purposes mentioned above.

About Imperia Web Network Ltd (secondary domain name: about.lupygames.co.uk)

You can find more information about our company on our"About Imperia Web Network Ltd" page. On this page, we will not process any other personal data about you. It contains links to some of the above pages, such as developer.lupygames.co.uk or jobs.lupygames.co.uk.

Job search platform of Imperia Web Network Ltd (second-level domain name: jobs.lupygames.co.uk)

The people involved: Those who apply for a job through our designated website.

Purpose of processing: When you apply for a job at Lupy Games Ltd through jobs.lupygames.co.uk, we will process your personal data for the following purposes:

• Evaluate whether you are suitable for our company;
• Contact you to learn about the further process of your application;
• To further process your application.

Personal data processed: When you apply for a job through jobs.lupygames.co.uk, we may process the following personal data:

• Full name;
• Email address;
• LinkedIn profile;
• Motivation and answers to portfolio questions;
• Resume;
• Telephone number;
• Current company/employer;
• How did you hear about this job;
• Additional information, such as a cover letter. (This information is not mandatory.)

Legal grounds for processing

We use your personal information in regards to jobs.lupygames.co.uk based on one of the following legal grounds:

• Agreement: Sometimes, we will process personal data based on your explicit consent. For example, this applies when you choose Imperia Web Network Ltd and may contact you within one year after the completion of the application process for other future job opportunities that you may be interested in.
• Legal rights: We have a legitimate interest in evaluating your application and other processing purposes mentioned above.

Imperia Web Network Ltd support

The people involved: The person who sends an email to customer support, for example, via [email protected].

Purpose of processing: When you contact Imperia Web Network Ltd customer support or otherwise contact Imperia Web Network Ltd, we will process your personal data for the following purposes:

• To provide you with support;
• Answer any questions you have about us.

Personal data processed

When you contact Imperia Web Network Ltd customer support or otherwise interact with us, we will process the following personal data:

• Email address
• Name (if provided)

Messages and related metadata you send to us.

Legal basis for processing: We use your personal data in the context of Imperia Web Network Ltd's customer service based on legitimate interests. Providing support and answering your questions are part of our legitimate interests.

1. How do we obtain your personal data?We obtain your personal data through various means:
   • Provided by you: Directly from you, such as the information in the message you send us or the information entered in our application form.
   • Acquired internally: From other Imperia Web Network Ltd systems, such as our CRM system.
   • Obtained from a third party: In certain situations, we may obtain personal data about you from other people or external parties, such as website visitors and applicants.
   • Obtained automatically: Some personal data is obtained automatically through the use of cookies and similar technologies when your device interacts with our website.
   • Derived: Certain personal data may be derived from the information we already have, such as information about your preferences and interests.
   You are not obligated to provide us with any information about yourself. However, refusal to provide certain information may affect your experience on the Imperia Web Network Ltd website.
2. Who do we share your personal data with?

   We only share your personal data with third parties if necessary for service provision or with your consent. These parties are obligated to keep your personal data confidential and comply with applicable laws and regulations.

   We may share your personal data with authorized personnel employed by Imperia Web Network Ltd, service providers/subcontractors, game developers, advertising partners, and authorized government agencies.

3. How do we secure your personal data?

   We have implemented appropriate technical and organizational measures to protect your privacy and personal data from unauthorized access or disclosure. All Imperia Web Network Ltd personnel are required to respect the confidentiality of personal data.

   In the event of a data breach, we have a data breach procedure in place to address and mitigate the impact of such incidents.

4. To which countries will we transfer your personal data?

   If your personal data is transferred outside the European Economic Area (EEA), we ensure that such transfers are legal and adequately protected. This may include relying on adequacy decisions, standard contractual clauses, or other appropriate safeguards.

5. How do we determine how long we retain your personal data?

   We retain your personal data for no longer than necessary for the purposes for which it was processed. However, there may be exceptions based on legal obligations or other legitimate reasons for extended retention.

6. What are your privacy rights (incl. right to object)?

   You have various privacy rights under the GDPR, including the right to withdraw consent, access, correction, deletion, objection, restriction, data portability, and to not be subject to automated decision-making. You also have the right to lodge a complaint with the supervisory authority.

   You can exercise your privacy rights by contacting us through the provided contact information. We will respond to your requests promptly and may ask for additional information to confirm your identity.

7. Who is responsible for the processing of your personal data?

   Imperia Web Network Ltd is responsible for processing your personal data in the context of the Imperia Web Network Ltd website. However, this privacy statement does not apply to third-party game providers or externally hosted games, whose data processing is governed by their own privacy policies.

8. How can you contact us?

   If you have any questions or concerns regarding this Privacy Statement or data processing, you can contact us at [email protected] or by mail. Please let us know your preferred contact method and language, and we will assist you accordingly.

   Imperia Web Network Ltd
   14 Kokiche Street
   3000 Vratsa
   Bulgaria
   Contact Person: Plamen Metodiv

Changes

We may update this privacy statement periodically to reflect changes in technology, industry practices, regulatory requirements, or other reasons. You can always view the latest version on the Imperia Web Network Ltd website. We will also notify you of any significant changes.