Privacy Statement
Version of June 2022
We understand that your trust in us, is FIREWISE STUDIO'S' (hereinafter referred to as "FIREWISE STUDIO'S", "we" or "us") most important asset. As such, your privacy is essential to us.
This privacy statement (hereinafter referred to as "Privacy Statement") is applicable, inter alia, to (i) our website https://gazzlers.com (hereinafter referred to as the "Website") and (ii) all (commercial) relations between FIREWISE STUDIO'S and its customers, prospects and business partners.
This Privacy Statement includes information about the personal data collected by FIREWISE STUDIO'S, as well as the manner in which FIREWISE STUDIO'S uses and processes this personal data.
FIREWISE STUDIO'S wishes to emphasize that it always attempts to act in accordance with (i) the Belgian Privacy Law of 30 July 2018 regarding the protection of natural persons in relation to the processing of personal data, (ii) the EU Regulation of 2016 concerning the protection of individuals with regards to the processing of personal data, regarding the free movement of such data and repealing Directive 95/46/EC, and (iii) other applicable data protection legislation.
Visiting the Website, subscribing to the newsletter, making use of the services and/or any other communication with FIREWISE STUDIO'S implies your explicit approval (through disclosure of your personal information or opt-in) of the Privacy Statement and consequently how we collect, use and process your personal data.
Please read this Privacy Statement in conjunction with FIREWISE STUDIO'S' cookie policy.
I. The data controller
The data controller of the processing activities is FIREWISE STUDIO'S BV, with its registered office at Watertorenstraat 2, 3590 Diepenbeek, and with company number 0713.960.877, VAT BE 0713.960.877. The contact details of FIREWISE STUDIO'S can be found under Article XI of this Privacy Statement.
II. The processing activities of FIREWISE STUDIO'S
A. General
How does FIREWISE STUDIO'S process your personal data?
FIREWISE STUDIO'S will process your personal data by the following:
- Providing support/assistance
- Responding to questions
- Optimising the quality, management and content of the Website
- Sending newsletters
- Creating statistics (website)
- Consulting game statistics of Gazzlers through the Oculus platform (Oculus Privacy Policy)
- Optimizing the customer experience on the Website
- Use of cookies, pixel tags and other technologies, as set out in the Cookie Policy on the Website
- Generally through the Oculus platform (aggregated data only)
- By the use of cookies
- Contacting or mentioning us using social media
All personal data, collected by FIREWISE STUDIO'S, are thus expressly and voluntarily provided by you.
Providing certain personal data is (sometimes) a requirement to be able to enjoy certain services (e.g. to gain access to certain parts of the Website, subscribing to the newsletter) In this respect, it shall be indicated which data must be provided mandatory and which data is optional.
What is the legal basis for processing your personal data?
Processing takes place on the following legal grounds, as the case may be:
- You have given consent to the processing of your personal data for one or more specific purposes
- Marketing purposes through social media
- The use of cookies, pixel tags and other technologies (except for strictly necessary cookies)
- Newsletter subscription
- Processing is necessary for the performance of the agreement with FIREWISE STUDIO'S or in order to take steps at your request prior to entering into an agreement
- Sending of quotes and/or issuing invoices
- Providing support/assistance
- Processing is necessary for compliance with a legal obligation to which FIREWISE STUDIO'S is subject
- Invoicing
- Processing is necessary in order to protect your vital interests or those of another natural person
- Processing is necessary for the performance of a task carried out in the public interest
- Processing is necessary for the purposes of the legitimate interests pursued by FIREWISE STUDIO'S or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child)
- Responding to questions: at your request, FIREWISE STUDIO'S will answer questions or provide information through various channels (including e-mail and social media)
- Marketing towards existing customers: FIREWISE STUDIO'S respects the applicable regulations, whereby direct marketing e-mails may only be sent if there is an existing customer relationship regarding similar products or services of FIREWISE STUDIO'S. You will always have the possibility to unsubscribe to such marketing activity.
- The use of strictly necessary and functional cookies on the Website: the use of these cookies is necessary for the functioning of the Website for the purpose for which the visitor visits the Website.
In case the legal ground for processing of personal data by FIREWISE STUDIO'S is legitimate interest, FIREWISE STUDIO'S wil always (i) assess the necessity of the processing activity in relation to the purpose of the processing (proportionality test), and (ii) assess whether you, the data subject, could reasonably expect the specific processing activity to take place, in order to evaluate the possible effects of the processing activity on your fundamental rights and freedoms.
B. Processing activities for use of the Website
| METHOD OF COLLECTION | PERSONAL DATA | PURPOSE | LEGAL GROUND | RETENTION PERIOD |
|---|---|---|---|---|
| Subscribing to the newsletter | Receiving news, promotional messages and info from FIREWISE STUDIO'S and its affiliates | Consent | Until person unsubscribes from the newsletter. | |
|
Cookies
For more information we refer to the Cookie Statement as available on the Website of Gazzlers |
IP address, click behaviour and input | Optimising and personalising your browsing experience. | Legitimate interest for necessary cookies. Explicit consent for non-essential cookies (consent can be withdrawn at any time). | Dependent on type of cookie. |
FIREWISE STUDIO'S also collects certain user and device data when using the Website. This information is anonymous when it does not reveal your identity and may not constitute processing of personal data. Examples of this type of user and device data include information collected through cookies, pixel tags and other technologies. More information about the collection of data via cookies can be found in FIREWISE STUDIO'S' Cookie Policy .
C. Processing activities concerning Gazzlers
| METHOD OF COLLECTION | PERSONAL DATA | PURPOSE | LEGAL GROUND | RETENTION PERIOD |
|---|---|---|---|---|
| Acount creation on Oculus platform | Name, surname, e- mail, user ID | Gamer needs to create an account to play the game | Legitimate interest | Until user ID is deleted via Oculus platform |
| Game achievements | Game related info (playtime, playstyle,...) All aggregated | Maximizing the game experienc e of the gamer | Explicit consent | Until user ID is deleted via Oculus platform |
| Consulting game statistics Oculus | Anonymous data | Analysing game behaviour | Legitimate interest | Until user ID is deleted via Oculus platform |
III. With whom is your personal data shared?
FIREWISE STUDIO'S shall not disclose your personal data to third parties, unless it is necessary in the context of performing the agreement and optimisation thereof. In this respect, your personal data may be disclosed to software providers, cloud partners and service providers.
If it is necessary that FIREWISE STUDIO'S discloses your personal data to third parties, the third party concerned is required to use your personal data in accordance with the provisions of this Privacy Statement.
Notwithstanding the foregoing, it is however possible that FIREWISE STUDIO'S discloses your personal data:
- To the competent authorities (i) if FIREWISE STUDIO'S is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights.
- If FIREWISE STUDIO'S, or the majority of its assets, are taken over by a third party, in which case your personal data - which FIREWISE STUDIO'S has collected - shall be one of the transferred assets.
In all other cases, FIREWISE STUDIO'S will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.
IV. Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer / processing agreement, which shall contain (i) the standard contractual clauses, as referred to in the 'European Commission decision of 4 June 2021 (Decision 2021/915)', or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
V. How long will your personal data be stored?
Unless a longer storage period is required or justified (i) by law or (ii) through compliance with another legal obligation, FIREWISE STUDIO'S shall only store your personal data for the period necessary to achieve and fulfill the purpose in question. Processing activities for use of the Website” and “II.C. C. Processing activities concerning Gazzlers” .
VI. What are your privacy rights?
In light of the processing of your personal data, you as a data subject enjoy the following privacy rights:
- Right of access to your personal data
- The data subject shall at all times have the right to access and inspect the personal data processed by the company. The company will provide a copy of this personal data, if the data subject so requests.
- Right to rectification, completion or update of your personal data
- The data subject shall always have the right to have inaccurate, incomplete, inappropriate or outdated personal data deleted or corrected.
- Right to delete your personal data ('right to be forgotten')
- FIREWISE STUDIO'S wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete resp. request deletion of certain required personal data.
- Right to limit the processing of your personal data
- The data subject has the right to limit data processing if:
- He disputes the accuracy of the data for a period of time that allows the company to verify the accuracy
- The processing is unlawful and he opposes the erasure of the personal data and instead requests restriction of their use
- The company no longer needs the personal data of the individual for the processing purposes, but the data subject still needs them for the establishment, exercise or substantiation of a legal claim
- He has objected to a processing operation, pending the answer to the question of whether his objection is well-founded
- Right to transferability of your personal data
- The data subject has the right to receive the personal data processed by the company in a structured, accessible and digital format in order to save it for personal use or reuse, or to transfer this personal data directly to another data controller. This right applies as far as this is technically possible for the data controller.
- Right to object/oppose to the processing of your personal data
- The data subject always has the right to object to the processing for reasons relating to his specific situation.
- The data controller will immediately cease processing the personal data, unless he demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subjects or which are connected with the establishment, exercise of substantiation of a legal claim.
If you wish to invoke your privacy rights, please contact legal@appwise.be.
If you no longer wish to receive newsletters or information about the products of FIREWISE STUDIO'S , you can unsubscribe at any time by clicking the "unsubscribe" button underneath each of FIREWISE STUDIO'S' emails.
VII. Security of personal data
FIREWISE STUDIO'S undertakes to take reasonable, physical, technological and organisational precautions in order to avoid (i) unauthorised access to your personal information, and (ii) loss, abuse or alteration of your personal data.
FIREWISE STUDIO'S shall store all personal data, which it has collected onsite or in the cloud with data centres in the EU.
Notwithstanding FIREWISE STUDIO'S' security statement, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, FIREWISE STUDIO'S is, in this context, not in a position to guarantee absolute security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.
VIII. Children's Privacy
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
IX. Update Privacy Statement
FIREWISE STUDIO'S is entitled to update this Privacy Statement by posting a new version on the Website. As such, it is strongly recommended to regularly consult the Website and the page displaying the Privacy Statement, to make sure that you are aware of any changes. Each update can be consulted in detal in the version history of the Privacy Statement.
Each update can be consulted in detal in the version history of the Privacy Statement.
X. References to other websites
The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. FIREWISE STUDIO'S does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy statements of these other websites and internet sources in order to be able to judge whether they act in accordance with the Privacy Legislation.
XI. Contact FIREWISE STUDIO'S
If you have questions and/or remarks about this Privacy Statement or the manner in which FIREWISE STUDIO'S collects, uses and/or processes your personal data, please contact us:
- Via e-mail: legal@appwise.be
- Via post: Watertorenstraat 2B, 3590 Diepenbeek
In case you are not satisfied with the way FIREWISE STUDIO'S handled your questions and/or remarks or have any complaints about the way FIREWISE STUDIO'S collects, uses and and/or processes your personal data, note that you have the right to lodge a complaint with the Data Protection Authority:
-
Data Protection Authority (Gegevensbeschermingsautoriteit)
Drukpersstraat 35, 1000 Brussel
Tel: +32 (0)2 274 48 00
E-mail: contact@apd-gba.be