In this Policy, references to “we”, “us” or “Leopoly” are references to Leopoly Inc. This Policy only applies to data collected by Leopoly via https://store.steampowered.com/app/571890/Shapelab/ (the “Site”).
HOW TO CONTACT US
Questions, comments, and requests regarding this Policy should be addressed to our Data Protection team through the following means:
Data Protection Team
Homokszem utca 3-5.
Email Address: [email protected]
We will collect personal information when you use the Site and the associated services, and as part of the normal course of business. This Policy sets out how we collect and use personal information, and your rights regarding our use of your personal information. Leopoly works with existing and prospective users and this Policy applies to them.
1. INFORMATION THAT WE COLLECT ABOUT YOU
For users (ShapeLab): Overview of user behaviour to optimise development and business goals
|Information we collect about your use of our app.
|Categories of information collected based on voluntary consent for direct and selective contact with our users for marketing and business purposes.
|Categories of information collected based on voluntary consent for sending tutorials
|We collect this information because we have a legitimate business interest in using it
1.2 Further Information
You have given your consent (where required under applicable law) to use your information for marketing. Where we rely upon your consent, you have the right to withdraw this consent by contacting us using the information above or unsubscribing via the opt-out functionality provided in our marketing communications to you. For marketing communications, we use Mailchimp.
Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.
Your personal information may also be processed if it is necessary to respond to a lawful request from a law enforcement or regulatory authority, body or agency, in the defense of legal claims or in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats, to the physical safety of any person or violations of any of our Site terms.
Payment Card Information
When applicable, you may pay for Leopoly products or services using your payment card and in such cases we will collect your personal data connected to your payment card. We use this personal data in order to process your payment with the assistance of a payment service provider.
2. WHEN WE DISCLOSE YOUR INFORMATION
We may disclose your personal information to third parties as follows:
- When we have your consent or authorization to do so;
- To third parties who work on our behalf to help us administer our Site, or to service or maintain business contact databases and other IT systems, such as suppliers of the IT systems which we use to process personal information, or who provide other technical services;
- To third parties providing services to us who have a need to access your information, such as our professional advisors (e.g. auditors and lawyers);
- To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (such as disclosing data in appropriate situations for national security or law enforcement purposes);
Your personal information will also be transferred to other third party organizations in certain scenarios (subject to applicable law):
- If we are defending a legal claim, our property, our website or other users, Information may be transferred as required in connection with defending such claim.
- If there is an emergency which requires us to share your data or for the health and safety of our Site’s users or the general public.
We also may share aggregate or anonymous information about you (which does not contain any personal information) to develop content and services and further improve your digital markets experience.
3. DATA SUBJECT RIGHTS
In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address or other information reasonably required). Where we receive your request to exercise one of these rights, we will respond without undue delay within the time required by applicable law. We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.
|How you can exercise this right
|Right to access and/or correct your personal information
|You have the right to access personal information we hold about you, and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.
|Right to restrict use of your personal information
|You have the right to ask us to restrict processing of your personal information where one of the following applies:
|Right to request deletion of your personal information
|You have the right to ask us to delete your personal information in most circumstances. If you want to opt-out from receiving marketing communications, the best way to do so is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
|Right to object to processing of your personal information
|You may object to our use of your personal information for marketing purposes. You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
|Right to data portability
|In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.
|Right to lodge a complaint with a supervisory authority
|If you object to our processing of your personal information, you have the right to complain to the data protection authority in the country where you reside, where you work, or where an alleged infringement of data protection laws has taken place.
5. RETENTION PERIODS
We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it. In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:
- the period required by tax and company laws and regulations; and
- as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.
6. CHOICES ABOUT YOUR INFORMATION
We believe it is important to give you choices about the use of your Information. We will use your personal information as described in this Policy. If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so. Marketing Communications We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information with third parties (for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.
We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access ShapeLab service or account, and you must report suspected unauthorized activity to us. We make reasonable efforts to restrict access to information to only those employees, contractors, who need such access in order to operate, develop, improve, or deliver our programs, products, and services.
8. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”. Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you. We also include web beacons in e-mail messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Site. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies.
We provide links to other websites or resources that are not part of the products, programs, or services run by Leopoly. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy notices of those sites and not this Policy.
9.2 Changes to this Policy
From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on the Site. We recommend you regularly review the Site to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.
Last Updated: February 2023