Below you will find the main information on the application of Lancio Entertainment S.p.A. Ballz Circle Challenge (on Apple Store and Google Play Store) (hereinafter the “App“) for smart devices (smartphones, tablets, etc) provided pursuant to art. 13 of the General Data Protection Regulation no. 679/2016 and also pursuant to the provisions set forth in the Opinion 02/2013 – WP 202 on applications for smart devices adopted by the Group of the European Data Protection Authorities on February 27, 2013 (hereinafter the “Opinion“).
Ballz Circle Challenge (on Apple Store and Google Play Store) app is an application for smart devices provided freely by Lancio Entertainment S.p.A., Data Controller of the related data processing. The App includes exclusively information contents and games.
The Opinion released by the Group of the European Data Protection Authorities requires the Data Controllers to provide users in advance (i.e. before the download and installation phase of the App is completed) with a minimum, fundamental information on the processing, which is referred to below.
Data Controller – Contact details.
Lancio Entertainment S.p.A. (hereinafter also referred to as “LancioE”)
Legal seat: Viale Bruno Buozzi, no. 58 – zip code 00197 Rome, Italy
Tel: +39 06 3350644
Fax: +39 06 3350632
Email: [email protected]
(PEC): [email protected]
Web Site: www.lancio-e.com
Data Protection Officer (DPO) – Contact details.
Also as required by the Guidelines on the Personal Data Protection Officer (RDP / DPO) WP243 / 2016, the contact details of the Data Protection Officer (DPO) are also provided. It must be specified, as permitted by the Guidelines on the Personal Data Protection Officer (RDP / DPO) WP243 / 2016, that the dedicated contact details of the DPO are exclusively represented by his electronic mail address, while the telephone number is generic and not dedicated (the data controller can alternatively indicate either a dedicated email or a dedicated telephone number of the DPO).
As for the telephone number indicated, the user shall be in any case quickly put in contact with the DPO.
Viale Bruno Buozzi, no. 58 – zip code 00197 Rome, Italy
Tel: +39 06 3350644
Dedicated email: [email protected]
Purposes of the processing. Categories of personal data collected by the App and methods of processing.
The App pursues the following purposes. The methods of processing are electronic or in any case automated data processing.
Allowing the download of the App and its operations thereof.
It is possible for any user to download the App and browse it without having to register or authenticate in any other way. In this case, the Data Controller does not collect or process identification data or the user’s identity. As regards the technical data of the device, such as for example unique identification codes such as IMEI, ICCID, IMSI, UDID, they are subject to temporary processing only for technical purposes of installing the App on the user’s device or to identify the user’s device only for the phase of providing remote technical assistance in the event of errors or malfunctions. Such technical information shall be deleted after the carrying out of the installation or assistance operations thereof.
Furthermore, no tracking technologies are used to collect and/or monitor the users’ device. The sole access to the user’s device by LancioE occurs to make the installation of the App possible, following the download requested by the user. The purposes are represented by the need to allow the download and the installation of the App and by the need to meet the users’ request for installation on their devices.
Allowing the performance of game functions and the use of the other options provided by the App.
Following the downloading and the installing of the App, users can use all the game options and other features provided by the App. Users shall also have in-app purchase options through the “Shop” section of the App (for example, user can buy gaming credits by paying the relative value in euros or purchase other digital elements, according to the contractual conditions provided). It must be highlighted that when the user accesses the “Shop” section from within the App he/she is redirected to third parties’ digital stores and/or e-commerce platforms managed by third parties (e.g.: Google Play Store or Apple Store, etc). LancioE is not involved in any way in such digital stores or e-commerce platforms managed by third parties, nor it process and/or receive users’ personal data is said context. Users – according to the terms and conditions applicable to them by the operators/owners of the digital stores and/or e-commerce platforms concerned – may be subject to the processing of their identification data (e.g.: email, accounts and similar) for authentication purposes by these third-party platform managers for letting the concerned user to proceed with the purchases.
Allow anonymous statistical surveys on the use of the App.
LancioE further pursues statistical purposes when collecting and processing aggregated and anonymized information about the use of the App by all users (not identifiable on an individual basis), taken from Google Analytics. LancioE draws from the set of anonymized information statistical reports concerning completely anonymous aggregate data such as: number of downloads, number of game sessions, overall scores, more or less used features of the App, average time spent in the App, device brand, access to the Shop, overview of the first activations or the number of sessions during which the App was opened for the first time in a device, total number of new users, their operating systems, version of the app and the country / area, data on traffic sources, aggregated data on the types of main mobile devices used, data on the versions of the operating system on which the App is running, total number of screens viewed per session, screen display order, number of technical errors, including App crashes, frequency of users returning to the App, duration of sessions, loading time of individual elements of the App, actions on certain specific contents of the App, such as a recommendation on a social network , etc.
Excluded, as specified above, the collection of data and / or contents stored on the user’s mobile device, LancioE further clarify for maximum transparency that the purposes of the processing above do not pursue any purpose of profiling users, whose data shall be processed anonymously, in aggregate and without the possibility of tracing the identity of a specific user.
Users’ data processing by third parties.
Provided that LancioE does not communicate or disseminate personal data nor it receive identification data from third parties, users are informed that producers of operating systems and devices, app stores, or application distributors and telecom operators can autonomously collect as independent (and sole liable) data controllers technical information from the user’s device (which constitute personal data). Said third parties – depending on the case and in accordance with the aforementioned Opinion 02/2013 – are not “third parties” but autonomous data controllers obliged on their own to comply with all the data protection rules. It must be highlighted that even in the event that users decide to set up a long-lasting subscription to the App (which is an option available), the activation and set up of the subscription occurs on third parties’ digital stores and is fully managed by the owners thereof in the quality of Data Controllers as regard to the data processing. The managers of digital stores and/or of e-commerce electronic platforms such as Google or Apple, etc. also manage some functions of the App as autonomous Data Controllers, such as the “leader Board” which lists the best scores associated with a user. It must be specified that LancioE – despite being able to access the ranking of the best game scores – is not able to identify users (identified only by nicknames) nor to identify them through association or correlation with other personal information.
User’s consent and legitimate ground of the processing.
Once the end users have been informed about the basic functions of the App, a positive action by the user before the App is downloaded and installed (ie click on the “Install” button or similar) satisfies the requirement of acquisition and providing of consent to data processing. In the case of the App – based on the provisions of the aforementioned Opinion 02/2013 and the Opinion of the Group of the European Data Protection Authorities no. 9/2014 on the collection of technical data of and from the device, as illustrated in this Information Notice – it is necessary to collect the user’s consent to let LancioE to access the user’s device for the sole purpose of allowing the installation or maintenance of the App following the download requested by the user, according to the above (data are then deleted). Consent is given by the user through his/her positive action of clicking on the button or link or other icon provided to start the download and installation of the App on his/her device.
Modalities through which users can exercise their rights, in terms of withdrawal of consent and deletion of data.
Users can exercise their rights of access, rectification, cancellation and opposition to the processing of data. Within the App, users can click on the dedicated link to send requests for the exercise of the data protection rights mentioned above to the single contact point specified in this Information Notice. Furthermore, users may always withdraw their consent where required or mandatory – in a simple way, also by uninstalling the App with the consequence of deleting all personal data Ballz Circle Challenge.