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CremaGames, S.L. is the developer of the game Temtem: Swarm, for individual or online cooperative use with up to three players.
We transparently inform you that we do not process identifying data such as names, nicknames, online identifiers, URLs, or data related to your user account, including payment-related information.
We are a video game development studio with headquarters at Calle de Ulises, 108, 1C, 28043 Madrid (Spain), with tax identification number B86562139, and are responsible for the processing of players’ data. Therefore, we provide this "Privacy Notice" to inform you about the processing of personal data carried out once the game has been acquired and installed.
In general, we process any information related to personal data in accordance with the data protection principles required by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with respect to the processing of personal data and the free movement of such data (hereinafter "GDPR") and Organic Law 3/2018, of December 5, on the protection of personal data and the guarantee of digital rights.
Our aim in publishing this Notice is to provide users with transparent and complete information regarding personal data processing, which we consider fair and based on the collection of only the minimum data necessary to provide the service. We strive to explain this clearly and simply through structured information. This document excludes data processing activities unrelated to CremaGames, S.L., for which we are not responsible, and which are subject to their own policies and legal notices. Therefore, the content of this Notice does not limit, replace, or modify other policies or information provided by third parties.
Controller and Contact Information
Controller Name: CremaGames, S.L. (also referred to as the "Controller" or "RT")
You may contact the Controller by postal mail at: Calle de Ulises, 108, 1C, 28043 Madrid, Spain, or by email at: support@cremagames.com.
Personal Data Processed
During the game’s use, we inform you that as the Data Controller, we will process observed data related to player activity, such as country and gameplay timestamps (e.g., the day of activity). However, we do not process identifying data or data collected by third parties, such as gaming platform data, which are handled according to their own terms and under their responsibility.
We also process other data, which may be considered anonymous since they are not associated with your player profile and are observed from your in-game interaction:
Purposes of Processing Activities
The Controller will use your personal data to perform technical information analysis, which indirectly involves personal data processing, for the following purposes:
Legal Bases
In accordance with the GDPR, the Controller can only process data if it has a lawful basis for doing so. In compliance with the regulations and as a proactive responsibility measure, we inform you about the legal bases used for the data types indicated and the purposes described:
Categories of Data Recipients
Your personal data may be shared with the following third parties who assist the Controller and generally act as processors, including:
Personal Data Transfers
The Controller may transfer personal data to recipients located in countries outside the European Economic Area or to international organizations, in compliance with personal data protection laws, as interpreted by the Court of Justice of the European Union and following the European Data Protection Board recommendations to ensure data processing with all required guarantees.
Personal Data Retention
The Personal Data processed for the purposes stated in this Notice will be retained by the Controller for the time strictly necessary to achieve these purposes, but may be retained longer when necessary to protect the Controller’s interests in potential liabilities related to service compliance.
Data may also be retained for compliance purposes for the period specified by specific legal obligations or applicable legislation, and to fulfill data requests from judicial bodies and competent authorities. At the end of the determined retention period, in accordance with the limitation principle, we delete personal data to ensure it cannot be reconstructed.
Data Subject Rights
Data subjects have the right to obtain a response from the Controller within a month to exercise their data protection rights at the contact addresses provided. These rights include:
Governing Law
This document is governed by the original text in Spanish and Spanish law. Translations are provided only as a guide to facilitate understanding.
November 13, 2024
We transparently inform you that we do not process identifying data such as names, nicknames, online identifiers, URLs, or data related to your user account, including payment-related information.
We are a video game development studio with headquarters at Calle de Ulises, 108, 1C, 28043 Madrid (Spain), with tax identification number B86562139, and are responsible for the processing of players’ data. Therefore, we provide this "Privacy Notice" to inform you about the processing of personal data carried out once the game has been acquired and installed.
In general, we process any information related to personal data in accordance with the data protection principles required by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with respect to the processing of personal data and the free movement of such data (hereinafter "GDPR") and Organic Law 3/2018, of December 5, on the protection of personal data and the guarantee of digital rights.
Our aim in publishing this Notice is to provide users with transparent and complete information regarding personal data processing, which we consider fair and based on the collection of only the minimum data necessary to provide the service. We strive to explain this clearly and simply through structured information. This document excludes data processing activities unrelated to CremaGames, S.L., for which we are not responsible, and which are subject to their own policies and legal notices. Therefore, the content of this Notice does not limit, replace, or modify other policies or information provided by third parties.
Controller and Contact Information
Controller Name: CremaGames, S.L. (also referred to as the "Controller" or "RT")
You may contact the Controller by postal mail at: Calle de Ulises, 108, 1C, 28043 Madrid, Spain, or by email at: support@cremagames.com.
Personal Data Processed
During the game’s use, we inform you that as the Data Controller, we will process observed data related to player activity, such as country and gameplay timestamps (e.g., the day of activity). However, we do not process identifying data or data collected by third parties, such as gaming platform data, which are handled according to their own terms and under their responsibility.
We also process other data, which may be considered anonymous since they are not associated with your player profile and are observed from your in-game interaction:
- Console or device firmware, game versions installed, drivers.
- Data obtained in-game to monitor and improve gameplay.
- Data generated through anonymization techniques or other methods to create infographics or statistics about the game’s performance or milestones, such as total gameplay hours, achievements completed, or the percentage of players choosing specific options.
Purposes of Processing Activities
The Controller will use your personal data to perform technical information analysis, which indirectly involves personal data processing, for the following purposes:
- Obtain player statistics and achievements to draw game performance conclusions and predictions, such as player performance, achievements reached, and categorization by level, game style, or setup.
- Train, develop, and optimize the model to estimate game performance and other games using the collected information and data analytics tools, carried out directly or through specialized third parties, ensuring proper safeguards and focused on improving the gaming experience.
- Perform user analysis through big data techniques to obtain an anonymous player profile using fully automated analytics techniques to draw conclusions for commercial impact purposes or to create precise player models for designing new content and game products, excluding manipulation or discrimination purposes.
- Create aggregate usage statistics and conduct game development and usage analysis.
- Operate and improve the service without using processed data to influence the user.
- Determine liabilities in hypothetical cases of cybercrime against the tool or third parties, protect our rights, property, or safety, both in extrajudicial and judicial phases, and for internal investigations or those carried out by competent authorities.
- Comply with legal obligations that require the Controller to collect and/or process certain types of Personal Data.
Legal Bases
In accordance with the GDPR, the Controller can only process data if it has a lawful basis for doing so. In compliance with the regulations and as a proactive responsibility measure, we inform you about the legal bases used for the data types indicated and the purposes described:
- Obtain player statistics and achievements for game conclusions and predictions, inherent to providing the gaming service, hence we process data based on Article 6.1(b) of the GDPR.
- Train, develop, and optimize the model to generate estimated game performance information, necessary for the gaming service and essential for contract execution or pre-contractual measures, in compliance with Article 6.1(b) of the GDPR.
- Perform user analysis through big data techniques to create an anonymous player profile for new product design or commercial impact purposes, based on the user’s consent, according to Article 6.1(a) of the GDPR, obtained via the purchasing platform.
- Create aggregate usage statistics, conduct game usage and development analysis, and improve the service without using the processed data to influence the user; this data processing is exclusively based on the legitimate interest of the Controller, under Article 6.1(f) of the GDPR and the consent obtained via this Notice communication platform, in accordance with Article 6.1(a) GDPR.
- Determine liabilities in cases of hypothetical cybercrime against the tool or third parties, protect our rights, properties, or safety, necessary for the Controller to meet legal obligations under Article 6.1(c) of the GDPR and also based on legitimate interest, according to Article 6.1(f) of the GDPR.
- Comply with legal obligations requiring the Controller to collect and/or process certain types of Personal Data, for compliance with legal obligations determined by the GDPR and other applicable regulations. Therefore, the data processing is legally based on Article 6.1(c) of the GDPR.
Categories of Data Recipients
Your personal data may be shared with the following third parties who assist the Controller and generally act as processors, including:
- Individuals, companies, or law firms providing support and advice to the Controller.
- Parties necessary for managing and organizing service production and technical and systems maintenance, such as hosting providers or platform providers.
- Other individuals authorized by the Controller to process data necessary for strictly business-related activities and service delivery, who are committed to confidentiality or have a legal confidentiality obligation, such as employees.
- Judicial bodies and competent authorities, when necessary and relevant.
- Analytical service providers we work with to monitor, measure, and analyze data through duly formalized contracts. These providers may collect all necessary aggregated and/or anonymous data for their services, without this information being used to reasonably identify users, and use this data to train, develop, and optimize the model to generate estimated information on performance and future services.
Personal Data Transfers
The Controller may transfer personal data to recipients located in countries outside the European Economic Area or to international organizations, in compliance with personal data protection laws, as interpreted by the Court of Justice of the European Union and following the European Data Protection Board recommendations to ensure data processing with all required guarantees.
Personal Data Retention
The Personal Data processed for the purposes stated in this Notice will be retained by the Controller for the time strictly necessary to achieve these purposes, but may be retained longer when necessary to protect the Controller’s interests in potential liabilities related to service compliance.
Data may also be retained for compliance purposes for the period specified by specific legal obligations or applicable legislation, and to fulfill data requests from judicial bodies and competent authorities. At the end of the determined retention period, in accordance with the limitation principle, we delete personal data to ensure it cannot be reconstructed.
Data Subject Rights
Data subjects have the right to obtain a response from the Controller within a month to exercise their data protection rights at the contact addresses provided. These rights include:
- Access to your personal data to learn whether your data is being processed and, if so, to obtain clear and precise information on processing purposes, your rights, and additional information on the processing.
- Rectification or update of your personal data processed by the Controller if incomplete, outdated, or inaccurate, and to obtain its rectification.
- Deletion of your personal data from the Controller’s databases when applicable, such as when processing is unnecessary or data is processed unlawfully.
- Restriction of the processing of your personal data by the Controller, for example, to suspend processing or retain data because it is needed for claims.
- Data portability to obtain a structured, commonly used, and machine-readable copy of the data concerning you, or to request transmission to another Controller.
- Object to the processing of your personal data if it is based on public interest or legitimate interest purposes, or for direct marketing, including profiling.
- Not be subject to automated individual decisions, including profiling, that have legal effects or similarly significant impacts on you.
- Withdraw consent for processing your personal data for any of the purposes for which it was provided.
Governing Law
This document is governed by the original text in Spanish and Spanish law. Translations are provided only as a guide to facilitate understanding.
November 13, 2024