Effective Date: May 25, 2018
Our guarantee to you:
Now that you're at ease, don't forget to have fun with our content :)
wearetests Entertainment Ltd. ("wearetests", "we", "our" or "us") develops, publishes and operates leisure and social games and applications ("Games"). We also operate the website www.wearetests.com, its subdomains and its related features ("Site", and together with the Games, collectively – the "Services").
We are strongly committed to making our Privacy practices more transparent and fair. This Privacy Notice describes how we collect, store, use and disclose personal data regarding individuals who visit our Site or play our Games ("you"), and it applies whenever you visit our Services or play our Games, interact with us or otherwise access or use any of our Services.
Specifically, it describes the personal data we typically receive or collect, how and for which purposes we may use such data (including for tracking and advertising), where we store and for how long we retain it, with whom we may share it, our use of communications, our security practices, your choices and rights regarding such data, our policy concerning children, and how to contact us if you have any concerns regarding your Privacy or this Notice.
We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still play most of our Games without connecting your Facebook account, but you will not be able to fully enjoy their social features).
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services (as detailed in Sections 4 and 6 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 7 below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of users of our Services, as well as any in-Game events.
We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver contextual or otherwise more effective advertisements and content; to optimize our ad management and our users' viewing experience, and to improve the overall user experience and performance of our Services. For more information about our advertising uses, please see Section 4 below.
Data received from you: you may provide us Personal Data voluntarily, such as your name, e-mail address and company name when you contact us (through Facebook, Messenger, the "Contact" form on the Site, e-mail or any other channel), your images and profile pictures (if you choose to upload them to the Game), when you post on our public forums or groups, when you sign-up to receive e-mail updates, when you place any purchases via our Services, or when you choose to connect your Facebook account to any of our Games.
Data received from Facebook and other channels: Once you connect any of our Games to your Facebook account, we will receive access to your Facebook public profile. Such access will allow us to collect the following parameters (to the extent you defined them as "public", or specifically permitted the Game to access it): your full name, e-mail address, profile picture, Facebook User ID (generated for the specific Game), gender, date of birth, list of friends (and their public profile pictures), posts, photos, comments, tags and tagged pictures, locale and time zone.
In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession (to learn more about our advertising practices, please read Section 4 below).
Data generated by us: Some of our Games include the generation of new data or content, such as rendered versions of the images or content you submit or that is otherwise collected via the Game. For example, we may generate a rendition of your submitted profile picture, which depicts an altered version of yourself or any of your friends.
Transaction Data: Some of our Games allow you to place purchases, such as for ordering a print of the image rendition generated through your use of our Games. As part of the purchase process you will be required to provide certain billing and shipping information. Such information will be collected and processed by the relevant Service Provider that manages our online store and order shipping process (as noted on the purchase page). We will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to your order, such as your name, billing and shipping address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.
Accordingly, we use Personal Data for the following purposes:
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Services as a whole. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the user.
A list of the cookies we use can be found here.
Our Services also utilize advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying contextual and interest-based advertising, as well as targeting, ad measurement and attribution systems. The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.
Such data includes your IP address, cookies, pixels and other unique identifiers, data related to your connected Facebook profile (if any, such as your gender, age group, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described in Section 3 above). Please note that we do not share the data you provide us through your connected Facebook account with our advertising partners.
Please note that this Privacy Notice does not apply to the processing of your data by our advertising partners and networks. We recommend that you review their privacy policies for more information (a list of our advertising partners and networks and their policies can be found here). (CHECK LAST PAGE)
How to adjust your preferences regarding cookies and interest-based advertising While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
If you wish to prevent the use of your identifiers for interest-based advertising, you may change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu).
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.yourchoicesonline.com (for European users).
Please note that if you reset your cookies or opt-out of interest based advertising, you may still see advertisements in our Services, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context , such as your activity in our Games or Services, or your language preferences. Please note that such actions may result in a less enjoyable user experience
Your Personal Data may be maintained, processed, accessed and stored by wearetests and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. wearetests Ltd. is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, wearetests has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We typically retain images for up to 30 days. We retain your other Personal Data for a longer period, in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our Data Retention Notice. If you have any questions about our Data Retention Notice, please contact us at [email protected]
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Notice:
Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. image processing services, hosting services, data analytics services, marketing agencies and advertising services and tools, e-commerce, manufacturing and shipping services, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording services, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook account to a certain Game or to place purchases, in which case you will be bound by the terms of service and privacy notices of said third parties (e.g., Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
Image processing with FaceApp
The processing of the user's personal data resulting from the photograph is carried out by FaceApp for the sole purpose of the selected function. The photograph is only temporarily stored temporarily for this purpose and is then deleted within five days. Data other than the photograph will not be transmitted to FaceApp. The data is transmitted via an interface to FaceApp, so that FaceApp itself cannot collect any further user data (e. g. no IP address, cookies, etc.).
Personalized videos with Powtoon
Image processing with Pho.to Lab by Vicman
Protecting Rights and Safety: We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of wearetests, any of our users or any members of the general public.
wearetests Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Notice. In addition, should wearetests or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Services.
For the removal of doubt, wearetests may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We will provide such notices through any of the contacts means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. If you wish not to receive such promotional communications, you may notify wearetests at any time by e-mailing us at [email protected] or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) to access, rectify, erase or view your Personal Data held with wearetests please contact us at [email protected], however, please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with our Data Retention Notice.
Please note that in some cases, as we may rely on Facebook's and our Service Providers' APIs and systems, your requests may require up to a few weeks to process.
Despite the playful nature of our Services and Games, they are not designed to attract children under the age of 16. We do not knowingly or intentionally collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services or playing any of our Games, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us at [email protected]
Updates and amendments: We may update and amend this Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you. Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Privacy, please contact us at [email protected]
wearetests has appointed Privacy veteran Aner Rabinovitz of PrivacyTe.am as its Data Protection Officer, for monitoring and advising on wearetests's ongoing Privacy compliance, and serving as a point of contact on Privacy matters for data subjects and supervisory authorities. Aner may be reached at [email protected]
wearetests has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. For Data Subjects in the EU: We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/14102729 Contact GDPR-Rep.eu GDPR-Rep.eu Maetzler Rechtsanwalts GmbH & Co KG Attorneys at Law c/o wearetests Entertainment LTD Schellinggasse 3/10, 1010 Vienna, Austria Please add the following subject to all correspondence: GDPR-REP ID: 14102729
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