Updated 10.10.2024
This document, referred to as \"This Policy\", details how Game Lounge Limited manages the information and personal data you share with us, enabling us to successfully facilitate our relationship with you.
Our Policy is applicable to all websites, applications, products, and services that either link to this privacy policy or lack a separate one (collectively referred to as Our services). The aim of this privacy policy is to clarify the statistics we gather, the reasons for collecting such data, the methods of processing it, the third parties with whom we may share your personal data, your rights concerning the handling of this data, as well as any other relevant aspects concerning privacy and security.
All personal data that you provide us—or that we already possess—will be processed according to the guidelines and practices outlined in this Privacy Policy. Information will be collected through any of the Game Lounge websites (referred to as \"The Website\") or other channels that Game Lounge may offer from time to time.
By reviewing This Policy, you agree to the processing of your personal data as described herein. If you do not consent to the terms of this Privacy Policy, we kindly ask you to refrain from using the Website or providing us with your Personal Data.
References in this Policy to \" Game Lounge \", \"Us\", \"We\", or \"Our\" denote the Data Controller, specifically, Game Lounge Limited , a Maltese company registered under number C 53144 , with its registered office located at Level 5, Spinola Park, Triq Mikiel Ang. Borg, St Julians, SPK 1000, Malta , and owner of the website librairiemonette.com.
The processing of Personal Data by Game Lounge as described in this Privacy Policy will be undertaken in accordance with the following regulations:
- The Maltese Data Protection Act (referred to as the \"DPA\" – Chapter 586 of the Laws of Malta) and any related regulations issued under the DPA, which may be updated periodically; and
- Regulation (EU) 2016/679 enacted by The European Parliament and The Council on April 27, 2016, concerning the Protection of Natural Persons with respect to Personal Data Processing and the Free Movement of Such Data, which revokes Directive 95/46/EC (commonly known as the \"General Data Protection Regulation\" or \"GDPR\").
Both the DPA and GDPR will be collectively referred to as the \"Data Protection Laws\" henceforth.
Game Lounge is responsible for determining how and why your Personal Data is processed, acting as the \"Data Controller\" as stipulated by applicable Data Protection Laws.
Definitions
Cookies
"Cookies\" refer to small files of data that are stored on a User's device.
"Game Lounge Group\" encompasses any organization that owns shares in Game Lounge, whether directly or indirectly, or any entity that Game Lounge holds shares in, which is owned (either directly or indirectly) by a common shareholder, where \"ownership\" implies holding at least one share in the respective entity, including any associated companies within the Group.
The Data Controller
Game Lounge Limited, registration number C53144, is located at Level 5, Spinola Parks, Triq Dun Mikiel Ang Borg, St Julians, Malta.
DPO contact Email:
The Data Processor
"The Data Processor\" refers to any individual or legal entity, including public authorities or agencies, that processes personal data on behalf of the Data Controller.
The Data Subject
"The Data Subject\" indicates the individual whose Personal Data is concerned.
Personal Data
"Personal Data\" consists of any identifiable information that refers specifically to you, or is connected to a person who can be recognized.
Usage Data
"Usage Data\" refers to information that is collected automatically through the website (or via third-party services utilized by Game Lounge), which may include IP addresses, timestamps for each visit, and navigational details outlining the sequence of pages accessed, along with specifications concerning the device's operating system and/or user's technical environment.
User
"User\" refers to the individual utilizing librairiemonette.com, and, unless indicated otherwise, correlates with the Data Subject.
Security
Game Lounge secures your Personal Data digitally, using encrypted hard drives.
Personal Data Protection
The Personal Data we retain is safeguarded through top-tier industry-standard security measures and protocols. Our commitment to protecting your personal data extends beyond mere quality and high standards; it also encompasses the most effective adherence to legal obligations. We can only process personal data if that processing is justified and based on one of the legal grounds established by the GDPR.
Personal Data You Give Us
You may give us your personal by:
- Subscribing to our newsletter
- Filing the contact Us forms
We will outline the specific data we require from you, whether mandatory or optional, for every process you may engage in.
| Process Name | Mandatory personal data | Optional personal data |
|---|---|---|
| Contact form services | This includes your Name, email address, Usage data, and details concerning cookies. | None |
| Subscribing to our newsletter | We collect your Email address, Usage data, and cookie information. | None |
Personal Data may be gathered via your device.
We utilize Usage Data and Cookies to maintain and optimize our website, ensuring that content is displayed effectively for you and your device. For further details about cookies, you can refer to our Cookie Policy.
Legal Basis for Personal Data Processing.
| Process Name | Lawful basis for processing |
|---|---|
| Subscriptions | Consent |
| Contact form services | Legitimate interest and Consent |
Processing Based on Our Legitimate Interests.
A legitimate interest exists when there is a valid business or commercial reason for processing personal data. We commit to protecting your personal data during this process and ensuring that it is handled fairly and without compromising your interests.
Processing Based on Your Consent.
Consent is not the only justification we may have for processing your personal data. We will only use your personal data based on your consent where no other legal basis (like compliance with a legal obligation or legitimate interests) can be applied. If we use your consent for processing, you retain the right to withdraw your consent whenever you choose, using the same method you previously provided it. If you opt to withdraw your consent, we will assess if we can continue processing your personal data based on a different legal premise. If so, we will inform you appropriately. Please note that withdrawing consent does not invalidate any previous processing actions carried out before you retracted it.
To clarify, in limited circumstances where we cannot or opt not to rely on another legal basis (like our legitimate interests), we will process your Personal Data relying solely on your consent.
In those instances where we process your data based on consent (which we will not assume but will obtain clearly from you), YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME in the same way you initially provided it.
If you decide to withdraw your consent (by contacting us through the mailing address or email provided below), we will evaluate whether an alternate legal basis exists for processing your Personal Data (such as a legal obligation compelling us to do so) that allows us to process your Personal Data without needing your consent, and if this is the case, we will notify you accordingly.
When we request such Personal Data, you are free to refuse; however, if you decline to provide necessary information for services we offer, we may not be able to fulfill those requests (especially if consent is the sole legal basis we have).
Just to clarify, consent is not the only condition allowing us to process your Personal Data . In the previous section, we enumerated various bases that we may rely on while processing your Personal Data for distinct purposes.
Other Purposes
We may also need to use and maintain personal information for purposes related to loss prevention and to safeguard our rights, privacy, safety, or property, as well as those of others, in accordance with our legitimate interests.
Data Retention
We are obligated to retain your Personal Data according to Our Data Retention Policy. The GDPR does not define specific time limits for how long Personal Data must be retained, so the criteria for determining retention periods (as detailed in Our Data Retention Policy) depend on the type of Personal Data involved. Generally, we consider if any applicable EU and/or national regulations (concerning licensing, taxation, or corporate matters) require us to keep specific Personal Data for a mandated duration (in this case, we will retain data for the longest duration prescribed by such regulations). If there are no such legal requirements, we will evaluate any legal or contractual obligations that may arise from you and/or third parties and define the relevant timeframes for such claims. In such cases, we will maintain any pertinent Personal Data necessary to defend ourselves against potential claims or actions from you and/or third parties.
After the duration specified in Our Retention Policy has concluded, your Personal Data will be securely deleted or anonymized, with irreversible measures implemented. Personal data retained for service notifications will remain until you inform us that you no longer wish to receive such information. If you require more information regarding retention durations, please reach out to us.
We store information only for a specified time frame when it is necessary for valid business reasons or legal compliance. We prioritize protecting data against unintentional or harmful deletion. Consequently, there could be a lag between the moment you remove data and when the corresponding backups are completely erased from our systems.
Do We Share Your Personal Data?
To ensure you receive optimal service, we collaborate with third-party vendors to share your personal information.
| 3rd Party | Service | Place |
|---|---|---|
| Google Ireland Limited | Google Analytics allows us to monitor and analyze traffic on librairiemonette.com, while Google Tag Manager helps manage our tags; additionally, we use Google Drive for saving and organizing backups. | Ireland |
| Xtremepush | Xtremepush serves as a versatile analytics and engagement platform that we utilize for various purposes, including analytics, completing web forms, enabling web push notifications, and facilitating marketing efforts. | Ireland |
Disclosing Personal Information to Various Parties
As required and in compliance with Data Protection Laws, we will appropriately share relevant information with members and employees of Game Lounge, along with other affiliated organizations, particularly when fulfilling legal requirements and obligations.
- To administer offers and promotion;
- We will assess and evaluate market strategies, trends, and conduct market research and training activities.
- We aim to address your requests for access and respond to any inquiries regarding GDPR.
- When we genuinely believe that sharing your personal information is essential for protecting your rights, ensuring safety for others, detecting fraud, or responding to government inquiries.
- To grant you secure access to and maintain our website.
- To assert, exercise, and defend our legal rights.
- We are committed to meeting our legal responsibilities to regulatory bodies, in addition to adhering to relevant laws and regulations in different jurisdictions.
- For the investigation, prevention, and prosecution of criminal activities.
- To assist customers by responding to inquiries and complaints.
Details regarding the categories of recipients who may receive your personal data include:
- Marketing Partners : This encompasses social media sites and various business partners who assist in executing marketing initiatives like advertising campaigns, optimization, and market analysis on our behalf.
- Marketing Consultants : Experts who provide strategic marketing insights and guidance to us.
- Communication/Marketing Service Providers : Companies responsible for facilitating communication with you through email, chat, SMS, and phone calls.
- Technical Support Providers : Vendors who support the functioning of our website and its technical systems, overseeing both front-end and back-end operations.
- Database Administrators : Technical personnel tasked with the maintenance of our Group’s databases.
- Cloud Service Providers : Firms that deliver cloud services, such as data storage and hosting solutions.
- Data Analytics and Business Intelligence Providers : Service providers that aid us with data analysis and business intelligence pursuits.
- Game Lounge Group Companies : Other entities within the Game Lounge Group that contribute various services and operational support.
- Professional Advisors : Legal experts, financial institutions, auditors, and insurance agents who provide consultancy and professional services.
- Payment Service Providers : Companies that handle payment transactions on your behalf.
Additionally, the Company may disclose your personal information to:
Other third parties if required to: (i) comply with governmental requests, judicial orders, or applicable legal standards; (ii) prevent unlawful use of our website, violations of its terms, or our policies; (iii) defend against claims from third parties; and (iv) aid in investigating or preventing fraud.
Any other third party that you have allowed us to share your data with.
Corporate restructuring : We may share your personal data with other entities, including those in our Group of Companies, to facilitate business operations or in scenarios such as selling, transferring, or merging parts of our business. If we experience a merger, acquisition, or sale, your personal data would generally be included in those transactions. Likewise, if another business merges with us or we acquire it, your personal information may be used according to the terms set forth in our privacy policy. In such cases, we will notify you via email and/or updates on our website, or as required by applicable guidelines, rules, or regulations. We will create or already have agreements in place with these entities to comply with confidentiality, ensure appropriate security measures, and prevent misuse of your personal data.
Authorised Disclosures of Personal Data to Third Parties
Without limiting anything else in this Privacy Policy, your personal data may be shared with authorized third parties, whether inside or outside the EU/EEA, if such disclosures are allowed or required by Data Protection Laws and/or any relevant legislation. These authorized third parties can include not only entities within Game Lounge, but also various external organizations like law enforcement agencies, accounting and auditing collaborators, regulators, and digital marketing providers. We may share your personal data with organizations that introduced you to us, third parties you’ve authorized, or any other entities necessary for supplying the products and/or services you requested. The extent of data shared will depend on the products and/or services you select.
If any personal data must be transferred outside of the EEA, we will ensure that necessary and appropriate safeguards are implemented. Personal information may also be disclosed to associated companies, subsidiaries, and business partners. The procedures for data transfer outside the EEA are outlined below. We will never share your personal data with third parties for marketing purposes without your explicit consent.
Any authorized disclosures, whether they occur within or outside the EU/EEA, will be conducted in accordance with Data Protection Laws (for instance, all our processors are required by contract to adhere to these laws, including a strict confidentiality obligation, ensuring their staff are equally bound). Our service providers also comply with several other obligations stipulated, particularly in Article 28 of the GDPR.
Your personal data will never be shared with third parties for their marketing purposes (unless you give your explicit consent).
Internet Communications
It's important to note that data transmitted over the internet could travel across international borders even if the sender and recipient are in the same country. We cannot accept responsibility for any actions taken by you or any third party regarding your personal data before we received it, including any transfers made via countries with lower levels of data protection than those enforced in the European Union, using any technology (like WhatsApp, Skype, Dropbox etc.).
Furthermore, we accept no liability for the security of your data while it is being transmitted over the internet unless our accountability arises directly from legal obligations effective in Malta.
Accuracy Of Personal Data
We make every effort to maintain the accuracy and currency of any personal data we hold about you. You can check the information we have at any time by contacting us through the specified methods below. Should you discover any inaccuracies, we will rectify them and, if necessary, delete the incorrect data. To ensure your privacy and security, we will also take appropriate steps to verify your identity before granting access or making corrections. Please review the comprehensive list of your legal rights under applicable data protection laws below.
Links To Third Party Sites
Links to third-party websites that we provide are distinctly labeled, and we bear no responsibility for, nor do we endorse in any manner, the content on those sites (including their privacy policies or data processing practices). We recommend reviewing the privacy policies of any third-party websites.
Transfer Of Data Outside Of The EEA
Your personal data will only be transferred outside of the EEA or to any country not within the EEA considered by the European Commission as providing an adequate level of protection (also referred to as “white-listed countries” – see https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) under the following circumstances: When you have expressly given us your consent; when it is essential for fulfilling or executing a contract that exists between you and Game Lounge; or to ensure compliance with legal obligations.
In the case that personal data is transferred outside the EEA, whether within Game Lounge or to its business partners, we ensure that appropriate measures are implemented to maintain the same level of protection and standards that apply within the EEA. You have the right to request a copy of such protections by contacting us at the address provided below.
Contracts that incorporate the EU Standard Contractual Clauses, also known as EU Model Clauses, will be implemented. These clauses mandate that the organization receiving personal data adheres to the same standards that are expected within the European Economic Area (EEA). Furthermore, personal data will only be allowed to be sent to the United States if the receiving entity is registered under the EU-U.S. Data Privacy Framework, which is designed to safeguard personal data, and we have ensured through thorough assessments that the recipient complies with the principles outlined in this framework.
Data Subject Rights
Game Lounge is committed to supporting you effectively if you decide to exercise any rights concerning your Personal Data. There may be situations where we need to confirm your identity before handling your request related to your rights. The main rights you possess are listed below; however, keep in mind that some of these rights may have certain exceptions:
- Access to your Personal Data
- You have the right to receive an electronic copy of your Personal Data and the option to transfer this information to another third party (data portability), which will be given in a standard, widely used, and machine-readable format.
- You can request corrections to your Personal Data in case it is either incomplete or incorrect.
- You may also request the deletion or restriction of your Personal Data in certain situations according to the laws that apply.
- You possess the right to limit or express objections to the processing of your Personal Data.
- The right to withdraw consent
- You have rights related to automated decision-making and profiling processes.
The Right to Lodge a Complaint
You can file complaints with the appropriate Data Protection Supervisory Authority. Since our primary establishment within the EU is located in Malta, the Maltese Information and Data Protection Commissioner (IDPC) acts as our Lead Supervisory Authority. We kindly ask you to try to resolve any issues directly with us first, although you always retain the right to contact the relevant authority at any time, as previously indicated.
Information We May Require From You
When you reach out to us to exercise your rights, we may need to request certain information to confirm your identity and to ensure you have the right to access your personal data or to enact any other rights you possess. This is a precautionary measure to safeguard against unauthorized sharing of personal data. Additionally, we may contact you for further details related to your request to ensure a prompt response.
Response Time Limit
We strive to respond to all legitimate inquiries within a month, unless a shorter timeframe is specified by law. In instances where your request is particularly complicated or if there are multiple requests from you, it might occasionally take longer than a month for us to get back to you. If that happens, we will inform you and provide updates on the status of your request.
Other info about user data storage
We have integrated tools on our website, such as a comparison feature and a sticky banner, to enhance your browsing experience. When you interact with these features, we utilize functionalities that save certain information in the session storage of your browser, like what you clicked on or added to the comparison tool. No personal data is processed through these functionalities. Additionally, we save the visual state of the comparison toolbar, showing whether it is 'open', 'closed', or 'minimized'. This state information helps us retain your preferred toolbar layout during your future visits to our website.
Changes to this Privacy Policy
Game Lounge retains the right to modify the privacy policy whenever necessary. We recommend that you check this page regularly while referring to the date of the most recent update. If any changes impact activities based on the User's consent, Game Lounge will obtain new consent from the User as needed.