(Effective
August 24TH,,
2023)
Table of Contents
Introduction
The
Friv4school website
Data
Controller
Our
Legal Framework
General
Information
Customer
Support
Personal
Data Collection
Activity
How
we use your Information and Legal Basis
Our
Data Processing Activites
Third
Parties we use
Data Retention
Data
Security
Your
Privacy Choices
European
Economic Area Users
United
Kingdom Brexit Notice
United
State California Notice of Collection
Commitment
Business
Transfers
Which cookies are used?
Contact Us
PLEASE READ THIS PRIVACY STATEMENT
CAREFULLY
Introduction
Thank you for choosing the Friv4school
site accessible at or
https://Friv4school.io
(the "Site"), operated by Rovers
Webdevelopment. When this
Policy mentions Friv4school or
Rovers Webdevelopment,
it refers to “we”, “us”, or “our”,
and we will be acting as your Data Controller.
We require every user on our site to be
at least 13 years of age and, if you are under 18, you agree to use
the service only with the permission and supervision of your parent
or legal guardian.
Our privacy promises:
We value your privacy & data
security
We do not use your data for commercial
purpose
We comply with the GDPR
We will never sell your data
You control your data.
After that, you’re all set to use
our Service. By accessing the
website, you hereby consent to our Privacy Policy and agree to the
terms described herein. Please
notice that this Privacy Policy and Cookie Policy only applies to the
above-mentioned Services.
For Friv4school
processing of your personal data in our games, please review the
applicable privacy policy which can be found the Friv4school website.
We reserve the right to change this Privacy Policy at any time. If we
make changes, we will notify you by revising the date at the top of
the policy and re-post the policy in the "Privacy" section
of our website. Depending on the specific changes, we will provide
you with additional notice or require a renewed consent.
Please review this Privacy Policy and
Cookie Policy from time to time in order to stay informed about how
we process your personal data and use cookies
Data
Controller
>
Friv4school,
a company duly incorporated under the Netherland Laws, bearing
Chamber of commerce number: {17155973}, with registered address at
Vliegerthof 2, Postal Code:
5424 VZ, City: Elsendorp and Country: Netherland (hereinafter
“Friv4school”, “Rovers
Webdevelopment”, “us”,
“we”, or “our”), is responsible for the
collection of personal data via the site https://Friv4school.io/,
(“our site”).
When this Policy mentions Friv4school
it refers to your Data Controller. You can always contact us if you
have questions about the processing of your personal data, or if you
have any requests in regard to your rights under the General Data
Protection Regulation ("GDPR"). We encourage you to
primarily contact us through Customer Support ([email protected]),
where you will get the fastest response
Our data privacy officer may also be
contacted at [email protected]
Our
Legal Framework
This
policy has been drafted on the basis of the Netherland laws and
guidance that seeks to protect children, including but not limited
to:
The
Children Act 1989 and 2004
The
Data Protection Act 2018
The
United Convention of the Rights of the Child 1991
The
Protection of Freedoms Act 2012
The
Sexual Offences Act 2003
All
relevant governmental guidance on safeguarding children
We recognise that, the welfare of a child
is important in today’s society, as provided in the Children
Act 1989 and 2004. All children, regardless of their age, gender,
disability, religious
belief, racial heritage, sexual orientation or identity, have a right
to equal protection from all types of child harm or abuse.
General
Information
The terms “We”, “Us”,”
Our” mean Friv4school.
The terms “You” and “Your” refer to You, as a
user, or visitor of our website provided Services. The term “personal
data” refers to all information relating to an identified or
identifiable natural person (hereinafter referred to as “data
subject”); an identifiable natural person is one who can be
identified directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data,
an online identifier or one or more specific characteristics
expressing the physical, physiological, genetic, psychological,
economic, cultural or social identity of that natural person, as set
out in the GDPR. In addition, personal data comprises data of legal
persons.
The Friv4school website
To access and use the Friv4school
platform is free, however, to save your favorite game, you will be
required to register an account with the platform, in such cases, we
will request that you provide us important information about
yourself, i.e, email address, date of birth etc. If you choose not to
share certain information with us, we may not be able to offer you
our Service. Any information you provide to us that is not required
is voluntary.
We use technologies such as cookies and
web beacons for specific purposes: such as to understand how you
interact with our platform and services, and to provide a better
experience.
Customer
Support
Friv4school
collects information you voluntarily submit when using our Customer
Support. The type of processed data, the purpose and legal basis for
the processing When engaging with our Customer Support, we may ask
you to provide general personal information voluntarily in order to
respond to your inquiry. This information may include your name,
email address, contact details, payment related information), device
ID and the nature of your request or communication. We request that
you do not provide sensitive information (racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade
union membership, genetic data, biometric data, data concerning
health or data concerning a person’s sex life or sexual
orientation), or personal identification numbers. Such data will
immediately be deleted.
We collect this information in order to
better assist you with any issues you might encounter with our
products. We reserve the right to
use this information in any manner permitted by law, to respond to
Your communication. The processing of your personal data for feedback
or customer support processing is based on Art. 6, para. 1, d) or f)
of the GDPR. Our processing for the above purposes is necessary for
the performance of a contract to which you are party in order to
facilitate the delivery of requested products and services by
providing Customer Support, see Article 6(1)(b) of the GDPR.
We will not disclose your personal data
to third parties, but we may use data processors who process personal
data on our behalf.
Personal
Data Collection
We take processing of your personal data
very seriously. We ensure a reasonable and transparent processing in
accordance with the rules on processing of personal data. For the
purpose of clarity, we have separated the description of our
processing activities into different categories.
You agree to provide only true and
correct information about yourself.
When you use and interact with
our services. We may collect, and use some personal identifiable data
("Personal Data") such as;
Personal
Information: Such as your
email address, date of birth, or unique online identifier, or
similar identifier.
Your
Usage Data. We may
automatically collect certain details of your access to and use of
the site, including traffic data, logs and other communication data
and the resources that you access and use on or through the site.
Technical
Data includes internet
protocol (IP) address, your login data, browser type and version,
time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices
you use to access the platform and website.
Usage
Data includes data about how
you use our website, products and services.
These personal data is neccessay to
provide a better experience of our products and services.
We only store your information for up to 6 months after which we will
delete or anonymize it
Activity
When You use the platform, We receive and
store certain information which may include Your Personal Information
and anonymous information, regarding Your use of the Services. We
also collect data around usage of the Services such as a user
activities, their performance on games and activities, in order to
send you reports and recommend the most appropriate games and
activities.
If you do not want us to collect these
information, you can request to remove it by sending us a message via
our email, or use the contact us option on the site.
How
we use your Information and Legal Basis
Any processing of data requires a legal
basis. If the processing is necessary for the performance of a
contract to which the data subject is a party, or for the
implementation of pre-contractual measures taken at the request of
the data subject, the processing may be based on Art. 6, para. 1, b)
of the GDPR.
Our processing of personal data is
necessary to safeguard our legitimate interests as a data controller.
We process and use the information we collect in various ways, in
addition, We may also collect, hold and use your personal information
for:
Providing
our service. We use your
information to provide and maintain our Services, to process and
fulfill your requests or orders, to communicate with you about your
use of our Services, to respond to your inquiries, and for other
customer service and business administration purposes.
To
Improve Our Services. We use
your information to understand and analyze our user base and how you
use the Services, to improve and enhance the Services, and to
develop new products, services, features and functionality.
Communication:
we use your information to send you offers and other communications
such as product updates, notices, support, and administrative
communication that may be of interest to you,
Data
Security and fraud prevention:
we use your data to protect our website user data and our server
from malicious or dangerous activity;
Investigation:
Prevent and investigate unauthorised access to the Services,
including other illegal activities;
Legal
Obligation; Comply with
specific legal obligations, and enforcing our agreements.
We also process data that cannot be
assigned to any person. These are data that do not personally
identify you, including anonymous information and aggregated data.
This information helps us better understand how our visitors use the
Services, analyze demographics, interests and behaviors of our
visitors, improve the Services, provide customized services and
information to visitors, and similar purposes. You hold the right to
opt out of receiving any of these communications as described under
"Your Privacy Choices" section below.
Our Data Processing Activites
DATA | LEGAL |
Providing | Contract |
Providing | Legitimate |
Registering | contract |
Compliance | Legal |
Keeping | Legitimate |
Preventing | Legitimate |
Improving | Legitimate |
Customer | Legitimate |
Third
Parties we use
We use the information that we collect
from our users in a number of ways: for instance we will use your
email address and date of birth details to save your favorite game,
register you on the platform and improve our services. Below are
information about the third-parties we may share or use your
information to operate our platform:
Advertising partners.
We may include an ad-supported service. Subject to your settings, we
provide certain Information to advertisers who will use them to
serve you with ads within the website, and we measure who sees and
clicks on their ads. We also share advertising identifiers, along
with the interests or other characteristics of a device or the
person using it, to help partners decide whether to serve an ad to
that device or to enable them to conduct marketing, brand analysis,
personalise advertising, or similar activities. For more information
on how to limit or opt-out from personalized advertisement.
Cloud service providers
who rely on for data storage, i.e. Google Cloud (Google Web Server)
and/or AWS (Amazon Web Server).
Analytics providers.
We work with a number of analytic providers, segmentation and usage
measurement services who help us understand our user-base. These
includes Google Analytics, etc.
Google Analytics:
This is a web analytics service offered by Google that tracks and
reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other
Google services. Google may use the collected data to contextualize
and personalize the ads of its own advertising network. For more
information on the privacy practices of Google, please visit the
Google Privacy Terms web page:
http://www.google.com/intl/en/policies/privacy
Law enforcement agencies,
public authorities or other judicial bodies and organisations. We
disclose Information if we are legally required to do so, or if we
have a good faith belief that such use is reasonably necessary to
comply with a legal obligation, process or request; enforce our
terms of service and other agreements, policies, and standards,
including investigation of any potential violation thereof; detect,
prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third
party or the public as required or permitted by law (including
exchanging information with other companies and organisations for
the purposes of fraud protection).
Business transfer or Change of
ownership. If we are involved
in a merger, acquisition, bankruptcy, re-organisation, partnership,
asset sale or other transaction, we may disclose your Information as
part of that transaction.
We will not share your data with any
third parties for the purposes of direct marketing. We have contracts
in-place with these thirdparties. This means that they cannot do
anything with your personal data unless we have instructed them to do
it. They will not share your personal data with any organization
apart from us. They will hold it securely and retain it for the
period we instruct.
Data
Retention
For the sake of the GDPR, we are entitled
to keep your Personal data only for as long as we need it for
legitimate business purposes and as required by applicable law. We
will take reasonable steps to erase any Data that we hold from you,
where:
we
no longer need the Data for the purposes for which it was collected
and we are not otherwise entitled to retain such data; and
we
are not required or obligated by law, regulation or court order to
retain the data.
If certain data has been provided to
third parties in accordance with this Privacy policy, retention of
that data will be subject to the policies of the relevant third
party.
Data
Security
We have put in place numerous technical,
organizational and physical safeguards measures designed to protect
the personal data of users. However, no online security measures are
guaranteed. You agree that your use of The site is at your own risk
Your
Privacy Choices
Under the General Data Protection
Regulation {GDPR}, you are entitle to the choices below;
Exercise of Rights:
You can exercise your rights as defined in GDPR, please send a
request via e-mail
[email protected], to
exercise your rights.
Revocation of Consent:
You hold right to revoke your consent for processing of your data in
the future at any time. However, this does not affect the lawfulness
of Data processing based on the consent before the revocation.
Right of Access:
You have the right to obtain (i) confirmation as to whether or not
your Data is being processed by us and, if so, (ii) request for more
specific data on the Data.
Right to Rectification:
You have the right to obtain from us the rectification of inaccurate
Data concerning you. In case the Data processed by us is not
correct, we will rectify these without undue delay and inform you of
this rectification.
Right to Erasure:
Should you decide that you do not want us to process your data any
further, please send a request via e-mail to [email protected].
We will erase your Data immediately and inform you of this process.
Should mandatory provisions of law prevent such erasure, we will
inform you without undue delay thereof.
Right to Restriction of Processing:
You have the right to obtain from us a restriction of processing of
your Data;
Right to Data Portability:
You have the right to (i) receive your Data in a structured,
commonly used and machine-readable format and (ii) transmit those
Data to another controller without hindrance from us.
Right to Object:
You have the right to object at any time to the processing of Data.
Right to Lodge a Complaint:
You have the right to lodge a complaint with a supervisory
authority, if you think that the processing of Data infringes
applicable law, especially the GDPR")
Learn more about these rights, and find
out how you can exercise your rights by sending us a message.
European
Economic Area Users
If you are a resident of the European
Union (“EU”), United Kingdom, Australia or Netherland,
you may have additional rights under the EU General Data Protection
Regulation (the “GDPR”) with respect to your Personal
Data, as outlined below.
For this section, we use the terms
“Personal Data” and “processing” as they are
defined in the GDPR, but “Personal Data” generally means
information that can be used to individually identify a person, and
“processing” generally covers actions that can be
performed in connection with data such as collection, use, storage
and disclosure.
Friv4school
will be the controller of your Personal Data processed in connection
with the Services. Note that we may also process Personal Data of our
customers’ end users or employees in connection with our
provision of certain services to customers (e.g. educational
institutions) , in which case we are the processor of Personal Data.
If we are the processor of your Personal Data (i.e., not the
controller), please contact the controller party in the first
instance to address your rights with respect to such data.
Please note that, we process your
personal data in reliance on the legal bases below. Where the purpose
of processing is:
To provide and improve our Services
and the Site: We process
your personal data as necessary to perform the contract under which
we provide our Services to you or to allow you to access our Site.
To comply with the law: We
process your personal data as necessary to comply with applicable
laws and our legal obligations.
For compliance, fraud prevention, and
safety: We have a
legitimate interest in processing your personal data, as described
in this Privacy Policy, and our reasons for doing so outweigh any
prejudice to your data protection rights. We also process your
personal data as necessary to comply with our legal obligations.
To send marketing communications; or
for research and analytics: We
have a legitimate interest in processing your personal data, as
described in this Privacy Policy, and our reasons for doing so
outweigh any prejudice to your data protection rights.
With your consent: We
process certain of your personal data with your consent. You may
withdraw your consent at any time in the manner indicated when you
provided consent to the collection of your personal data through
your interactions with the Services or the Site.
United
Kingdom Brexit Notice
Based on the agreement between the UK and
the EU, until 2025 all the personal data transfers from the EU to the
UK are not considered as transfers to a third country. For the
transfer from the UK to the EU, UK finds this transfer as transfer
with adequate protection, so currently there are no additional
requirements needed for such personal data transfers.
United State California
Notice of Collection
If you are a User in
the United State, who In the past 12 months used the platform, we may
have collected the following categories of personal information
enumerated in the California Consumer Privacy Act (CCPA). We collect
and use these categories of personal information for our business
purposes described in the “Data Collection and Personal
Information Use and legal basis” section, including to provide
and manage our Service.
Right to Know and
Delete
If you are a
California resident, you have rights to delete your personal
information we collected and know certain information about our data
practices in the preceding 12 months. In particular, you have the
right to request the following from us:
The categories of
personal information we have collected about you;
The categories of
sources from which the personal information was collected;
The categories of
personal information about you we disclosed for a business purpose
or sold;
The categories of
third parties to whom the personal information was disclosed for a
business purpose or sold;
The business or
commercial purpose for collecting or selling the personal
information; and
The specific pieces
of personal information we have collected about you.
To exercise any of
these rights, please contact us using the details provided in this
privacy policy.
Commitment
We take the responsibility to protect the
security and privacy of our users seriously. We have established
effective policies that define our commitment to data security and
the information technology we manage. We are continually reviewing
policies and procedures to assure that they are appropriate and
effective in meeting our commitments to our community, our users,
customers and ourselves. Any suspicious attempt to breach our terms
and policies, or to engage in any type of unauthorized action
involving our information systems, is regarded as potential criminal
activity. All suspicious computer mischief will be reported to the
appropriate authorities.
Business
Transfers
In connection with, or during
negotiations of, sale of company assets, any merger, financing, or
acquisition of all or a portion of our business. We may share or
transfer your data (including your personal data) for business
transfer purposes. You will be notified via email and/or a prominent
notice on the website of any change in ownership or related uses or
disclosures of your data, as well as any choices you may have
regarding your data in such circumstances.
Which
cookies are used?
We use first party cookies from the
website itself in order to facilitate and optimize the use of the
website and for traffic measurement. These cookies are persistent
cookies. We also use third party cookies belonging to Google
Analytics and social networks in the form of Facebook, Twitter,
Youtube, Google+, etc. The purpose is to guide the webpage visitor to
social networks that have more information and videos regarding
Friv4school.
These companies are based in the USA and in compliance with Privacy
Shield.
How to delete and avoid cookies
You can always choose to opt-out of
cookie or disable them entirely on your device via plugins or from
your browser settings. Alternatively, you can set your device to
alert you when cookies are being sent to your device; however,
disabling cookies may affect your ability to use our Services.
It is also possible to deactivate cookie
through a consent tool such as
http://www.youronlinechoices.com/uk/your-ad-choices (serviced by
EDAA).
Contact
Us
We hope that we can
satisfy any queries you may have about the way in which we process
your personal information, so we encourage you to submit your claim
to our Data Protection Officer at; [email protected]
However, if this does
not satisfy you, you also have the right to complain to the data
protection authority in the location in which you live, work or
believe a data protection breach has occurred.