Privacy Policy

This Privacy Policy (hereafter, the “Policy”) has been created to manifest SOCEM (Soluciones de Comunicación Empresarial SL) data processing. This Privacy Policy applies to all apps and games provided by SOCEM.

1. SOCEM processing of Personal Data

SOCEM informs you that it will process Personal Data collected by software, applications and/or services in connection with your user accounts from third party providers, such as social networking websites or software marketplaces. User’s personal data that is collected will be treated with absolute confidentiality and in compliance with the duty of secrecy. We collect non-personal information about your use of our Apps and aggregated information regarding the usages of the Apps. “Non-Personal Information” means information that is of an anonymous nature, such as the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system. We do NOT collect any Personal Information about you. “Personal Information” means personally identifiable information, such as your name, email address, physical address, calendar entries, contact entries, files, photos, etc.

2. Purposes for which SOCEM processes Personal Data

In compliance with the principles of privacy by design, privacy by default and data minimization, SOCEM will only collect the personal data that is necessary for achieving the below purposes. SOCEM does not use illegal, unfair or fraudulent procedures to obtain personal data. The purposes for which SOCEM collects personal data is to provide or offer goods and services to you, to guarantee the operation of the game or app, to any other purpose authorized by law, to provide you with personalized advertisings, and to other purposes authorized by you. Likewise, if the User expressly consent, SOCEM may process his or her data to send informative communications that are related to SOCEM’s activity, offers, events, and future services. These communications may be sent by email. SOCEM will request the User’s prior consent every time his or her data is used for a different purpose than for which it was provided or requested.

3. Rights that Users may exercise before SOCEM or the relevant Supervisory Authority

Any User who wishes to exercise his or her rights of access, rectification, erasure, restriction of the processing, to data portability or of objection must notify SOCEM upon written request send to the email address cso@socem.com. In accordance with GDPR and California Consumer Privacy Act ("CCPA") provisions, the contents of the rights that Users are entitled to are the following: Right of access: The user can request SOCEM to disclose which data relating to him or she is subject to processing by SOCEM as well as the source from which the data was collected and the purpose for which the data is being processed. Right to rectification: The User can request SOCEM to modify any personal data that is not updated. Right to erasure: The User can request SOCEM to delete his or her personal data unless there are justified and valid reasons that allow SOCEM to maintain the data. The Right of Erasure implies a period whereby the personal data will remain blocked in order to comply with any legal obligations that may arise before its definitive deletion. Right of objection: The User can object before SOCEM its use of personal data for certain purposes. Right to restrict the processing: The User can request SOCEM to highlight its personal data as being restricted to the specific purposes that the User accepted. Right to file a complaint before the relevant Supervisory Authority: In the event of disagreement with the way SOCEM collects and processes personal data or have addressed requests for the exercise of User rights, the Users may file a complaint before the Supervisory Authority (Spanish Data Protection Agency).

4. Third-party recipients that may have access to User personal data

SOCEM undertakes not to transfer or communicate your personal data to any third party unless prior and explicit authorization by you. Nevertheless, it is possible that SOCEM allows access to your personal data to third parties that provide service to you. These third parties will acquire the status of Data Processors. As such, they may only process your personal data in accordance with SOCEM’s instructions. We direct all such organizations to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on our behalf or to us. We may share your information with third parties with whom we have a strategic relationship, such as data providers, business partners and advertisers. The information shared with these third parties may be used for the purpose of providing you with information on goods and services we believe will be of interest to you. Any personal information submitted to us online, including via the software and/or services, may need to be processed by a third party. By submitting personal information online or via the software and/or services, you consent to the disclosure of that information to a third party, who may be located overseas, for the sole purpose of processing the submitted information.

5. Third-party services

You may use third-party services (a) to obtain our software, applications and/or services (for example, a software marketplace); and/or (b) in conjunction with our software, applications and/or services (for example, a social networking website). Your use of these third-party services may be subject to separate terms and conditions and privacy policies, and you acknowledge that we are not liable for the use of your personal information by any such third-parties. Our software and services may contain links (including via advertisements) to third party websites or other third-party content or services. This policy does not apply to such third-party activities, and you should make your own assessment of the privacy policies of these third parties. We strongly recommend you read these third-party policies, and the terms and conditions attaching to the third-party offerings, prior to access or use.

6. Conservation period

Personal data will be kept for attend the purposes mentioned above during the period of 24 hours. Once the conservation period is terminated SOCEM will keep the personal data duly blocked for the periods established by law with the sole purpose of attending to any type of responsibilities that may arise. Once prescribed such responsibilities, your personal data will be deleted.

7. Contact

If you have any questions or comments about this Privacy Policy, or any other issues regarding our apps or services, please contact us at cso@socem.com