Privacy Policy

This Privacy Policy was last updated on the 24th of May, 2018. WitchHut is committed to protecting the privacy of all visitors who use our site and applications, including older users above the age of 13 (“General Users”) and younger users under the age of 13 (“Children Users”), together the “Users”. This privacy policy (“Privacy Policy” or “Policy”) is designed to provide transparency into WitchHut’s privacy practices and principles for information that we collect from General Users through our WitchHut.com web platform. WitchHut.com is owned and operated by WitchHut S.R.L. (referred to in this Policy as “WitchHut”, “we”, “our”, or “us”). WitchHut S.R.L. (“WitchHut”) is an entity incorporated under the laws of Romania. By using WitchHut.com, you agree to observe and be bound by this Privacy Policy and you consent to the processing, collection, use, and disclosure of your information and data in accordance with the terms of this Privacy Policy. Please do not use WitchHut.com if you do not agree to this Privacy Policy. If you are a parent or legal guardian, by allowing your child(ren) to use WitchHut.com, you are agreeing to the terms of this Privacy Policy on your child’s behalf. If you have any questions concerning this Privacy Policy, please contact us here.

The data protection declaration of WitchHut S.R.L. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners.

1. General information

Almost all features on the WitchHut.com are available without the need for registration by Users. No personal data (such as email addresses and phone numbers) is collected.

However, if you open a publisher account with WitchHut.com, you will have to provide data necessary for communication, contracts and invoicing (company data).

2. Data collection and its purposes

Data provided by our publishing partners through their publisher accounts is safely stored on our servers and used solely for communication and invoicing purposes. If for any reason you need to cancel your account, please contact us here, or contact your account manager and we will remove any data related to your account from our servers.

Our servers automatically recognize visitors’ domain names and IP addresses (the number assigned to computers on the Internet). WitchHut.com may gather anonymous “traffic data” that does not personally identify you, but that data may be helpful for marketing purposes or for improving the services we offer. When your computer or mobile device contacts our web servers (for example, when you visit WitchHut.com), our web servers automatically collect usage information. Such usage information includes information about how our visitors use and navigate WitchHut.com. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses. We may use IP addresses to help diagnose problems with our server, to help administer WitchHut.com, or to display the content according to your preferences. Traffic information may also be shared with business partners and advertisers on an aggregate and anonymous basis.  More information about sharing information will follow in part 7. In addition, Advertisers on WitchHut.com might use information gathered by the use of cookies for targeted advertising purposes. Further information regarding the use of cookies can be found here. If you have any questions concerning data collection on WitchHut.com or a request to delete data collected (as applicable), please contact us here.

3. Third party games

This Privacy Policy does not apply to the processing of personal data by data controllers other than WitchHut, such as – as the case may be – providers of third party games that might be available on WitchHut.com. The relevant provider of such a third party game is responsible for ensuring that any processing of personal data by them in the context of a game complies with applicable data protection law.

4. Cookies

Like many websites and applications, WitchHut.com makes use of “cookies” which are installed on the user’s computer. In addition, third party networks serving advertisements on WitchHut.com and inside the games developed by WitchHut (the “Advertisers”) might use cookies.

Detailed information on how WitchHut uses cookies can be found here.

5. Links to third party websites

GirlG.com knowingly links out to the following websites.

  • POP.games
  • GirlG.com
  • GirlsPlay.com
  • GameSheep.com
  • PlayPOD.com
  • eJocuri.ro
  • JocuriFete.ro

 

6. Sharing information

WitchHut may share your persistent identifiers with third parties such as business partners under the following circumstances: Security: We may release information about our Users, including IP address, when legally required to do so, at the request of governmental authorities conducting an investigation or to verify or enforce compliance with the policies governing WitchHut.com and applicable laws. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of WitchHut.com, or any of our respective business partners, customers or others. Aggregate Information: We may disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited WitchHut.com during a specific time period or played a specific game on this Website.

7. Children Users

We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly.

No personal information is purposefully or knowingly collected from Children Users by WitchHut.

 

8. Rights of the data subject

Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

 

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

 

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

 

the purposes of the processing;

the categories of personal data concerned;

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

the existence of the right to lodge a complaint with a supervisory authority;

where the personal data are not collected from the data subject, any available information as to their source;

the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

 

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

 

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

 

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

 

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the WitchHut S.R.L., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the WitchHut S.R.L. or another employee shall promptly ensure that the erasure request is complied with immediately.

 

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of the WitchHut S.R.L. or another employee will arrange the necessary measures in individual cases.

 

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

 

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the WitchHut S.R.L., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the WitchHut S.R.L. or another employee will arrange the restriction of the processing.

 

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

 

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

 

In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by the WitchHut S.R.L. or another employee.

 

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

 

The WitchHut S.R.L. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

 

If the WitchHut S.R.L. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the WitchHut S.R.L. to the processing for direct marketing purposes, the WitchHut S.R.L. will no longer process the personal data for these purposes.

 

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the WitchHut S.R.L. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

 

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of the WitchHut S.R.L. or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

 

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

 

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the WitchHut S.R.L. shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

 

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of the WitchHut S.R.L. or another employee of the controller.

 

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

 

f the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of the WitchHut S.R.L. or another employee of the controller.

9. Revisions to this Privacy Policy

We may change this privacy policy from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. If we update this policy, changes will be reflected on this page and we will update the “last updated” date above. We will obtain prior parental consent for any changes we make if those changes affect Children Users in a way that requires parental.

10. Contact information

If you have any questions concerning this Privacy Policy, or data collection in particular, please contact us here or: WitchHut S.R.L - Carol Davila 34, Bucharest, Romania – www.witchhut.com.