thumbr is a trade name of thumbr B.V. (hereinafter referred to as: "thumbr"). thumbr collects personal data about you when you use the online and mobile websites and platforms that are managed by or on behalf of thumbr (hereinafter referred to jointly as: “thumbr platform”). The way thumbr processes your personal data depends on the way you use the thumbr platform. This Privacy Statement describes how thumbr processes your personal data.

PROCESSING OF PERSONAL DATA – GENERAL

This general section describes which personal data thumbr can process in any event if you use the thumbr platform, also if you have not registered with thumbr. This section also contains other general relevant provisions with regard to the processing of personal data by thumbr.

Data that is collected

Cookies: When you visit the thumbr platform, we can send cookies to your computer or your mobile device. Cookies are small files with a series of alphanumeric characters. We use cookies to identify your mobile device or computer, which allows you to log in faster and navigate faster through the thumbr platform. Cookies can also transmit information about how you use the thumbr platform.

We use permanent cookies and session cookies. Permanent cookies remain on your hard disk or mobile device after you close your browser, and these cookies are used the next time you visit the thumbr platform. These cookies can be removed by changing your privacy settings on your browser.

Session cookies are temporary and disappear when you close your browser.

You can set your browser to refuse all cookies or to inform you when cookies are sent. Take note that some functions of the thumbr platform may possibly not function properly if the possibility of accepting cookies is switched off.

Identifiers: thumbr can gain access to so-called "identifiers" and collect, monitor and store them. If you have access to the thumbr platform via a mobile device, this involves device identifiers; if you have access via your computer, it involves your browser. “Device identifiers” are small data files or similar data structures that are stored or linked to your mobile device and that can identify your mobile device uniquely and be used by thumbr to improve your use of the thumbr platform. Device identifiers can be stored in connection with hardware and/or software data of your mobile device or in connection with other information that thumbr has sent to your device.

Identifiers can contain information about how you use the thumbr platform. Device identifiers do not collect any personal data about you, but can be used in combination with other information in a way that does concern personal data. An identifier can be stored on your mobile device or computer so that you can log in faster to the thumbr platform and make better use of our services. Take into account that if you block or limit the use of the device identifiers, some functions or parts of the thumbr platform may not function properly.

Log file information: Log file information is reported automatically by your browser every time you access a web page. If you use the thumbr platform, our server automatically stores the log file information. This information can consist of, but is not limited to: Internet Protocol (“IP”) address, type of browser, referring / exit pages and URLs, the number of clicks, information about links, domain names, landing pages, pages viewed, and other similar information.

Web beacons: When you use the thumbr platform, we can use so-called “web beacons”. They are pieces of data that are used to follow the online usage patterns of users from one web page to the next in order to improve the use of the thumbr platform.

In addition, we can also use web beacons in HTML-based email messages that are sent to our registered users to find out which email messages are opened. This information is used to optimise the effectiveness of our marketing efforts and improve the thumbr platform for our users.

Purposes of processing personal data

thumbr offers media and entertainment services on its platforms in the broadest sense. These services were developed by thumbr itself or originate from third parties.

thumbr uses the above-mentioned personal data, as well as the personal data that you provided to thumbr if you registered with thumbr, to perform the services that you use on or by means of the thumbr platform, for statistical analysis and for improving the thumbr platform. thumbr also uses your personal data to inform you about services and promotions.

Providing personal data to third parties

thumbr can call in third parties, so-called processors of personal data, for the performance of its services and for the purpose of processing personal data. These processors work on the instructions of thumbr and will only process your personal data on behalf of and for use by thumbr.

If thumbr wants to effect a merger, takeover, sale or other transaction whereby its database can be acquired by a third party, thumbr may disclose your personal data to its advisors and to the third party, both before and after the transaction, exclusively for the purpose of the possible facilitation and effecting of that transaction. If such a transaction is completed, you will be informed about the transaction and thumbr will transfer the ownership and the management of your personal data to the third party, subject to all provisions and limitations of this Privacy statement. If the transaction is not completed, thumbr will require of the third party that it does not use your personal data or disclose it in any way and that it will delete it fully.

thumbr can also transfer your personal data to a third party to which it transfers its rights and obligations on the basis of its agreement with you.

thumbr can provide your personal data to third parties if thumbr believes in good faith that this is necessary (a) in order to comply with the law or court rulings; and (b) in order to protect or defend the rights of thumbr.

Permission from parents

Minors younger than 16 years must ask their parents for permission before they provide personal data to thumbr. If personal data is collected without such permission, thumbr, as soon as it discovers this, will remove the personal data concerned as soon as possible.

Transfer of personal data outside of the EEA or your own country

Currently thumbr stores its personal data file centrally in the Netherlands. You agree that thumbr can transfer your personal data to third parties in other countries for the purpose of centralising the files or for processing as described in this Privacy statement. Some of those countries might not be part of the European Economic Area (‘EEA’) or are outside your own country. Countries outside of the EEA or countries other than your own country might not have the same laws for data protection as the EEA or your own country. If thumbr transfers your information to countries outside the EEA or your own country, we will take measures to ensure that your privacy rights remain protected in the same way as inside the EEA or your own country. In addition, your data, if you use our services while you are outside the EEA, can be transferred outside the EEA in order to supply you with these services. By agreeing to this Privacy statement, you also provide permission for the transfer of your perso al data outside the EEA or your own country for the purposes described. At your request we will provide you with a list of the countries to which your personal data is transferred.

Retention period/opting out

Your personal data is stored by thumbr for no more than two years after your last visit to the thumbr platform, unless thumbr, for reasons of any statutory provision, is obliged to store (parts of) your personal data for a longer period.

If you i) no longer wish to receive any communication from thumbr or if you, ii) after registering with thumbr, do not want us to provide your personal data to external marketeers or business partners for the purpose of marketing communication or if you want iii) thumbr to delete all your personal data, you can send an email free of charge to info.ww@thumbr.com and state this. In that case, thumbr will only use your personal data for supplying the services of the thumbr platform or for satisfying statutory obligations. thumbr will in that case no longer send you any information other than that necessary for the performance of the services in the context of your use of the thumbr platform. Additionally, your personal data will no longer be provided to third parties.

This deletion does not take care of deletion by third parties of the information that had already been collected and possibly already shared with these third parties. You must contact these third parties directly who will possibly contact you, in order to make sure that the personal data that they use to contact you is likewise deleted. On your request, thumbr can provide you with a list of parties to whom your personal data was provided. You can send an email for this purpose to info.ww@thumbr.com.

Access to data

On request, you can inspect the personal data that we have collected about you, and if necessary, correct it. In order to make use of this right, you can send an email to info.ww@thumbr.com.

Security

thumbr treats all your data confidentially and will take all reasonable measures to protect your personal data. However, thumbr cannot guarantee the security of the data that you provide online. You accept the inherent security risks of providing information and transactions via the internet and you cannot hold thumbr liable for a breach of the security, unless this is the result of negligence or intentional failure of thumbr.

Changes to the Privacy statement

This Privacy statement came into effect on 1 April 2012. thumbr reserves the right to change or amend this Privacy statement at any time and for any reason. If material changes take place in this statement or in the way thumbr processes your personal data, thumbr will publish these changes prominently so that you can become aware of the change in question before the change takes effect.

Regardless of later updates, thumbr will adhere to the procedures with respect to confidential information as described in this Privacy statement at the moment that you provided your data to thumbr.

Contact

For questions about this Privacy statement you can contact: thumbr B.V., Stadhouderskade 85, 1073 AT Amsterdam, the Netherlands, info.ww@thumbr.com

 

PROCESSING OF PERSONAL DATA – AFTER REGISTRATION WITH THUMBR

If you register with thumbr, besides the above-mentioned provisions, the following also applies and you agree expressly to this.

Personal data that is collected

The personal data that we collect if you have registered and make use of the services on the thumbr platform, include but are not limited to:

Registration Information: When you register with the thumbr platform, we will ask you to create a login and we can request, but not exclusively, your email address, name, address and date of birth. We can link this information to the other information that we collect about you.

Chat and discussion-related information: If you are registered, you can make use of forums, chat rooms and other forms of instant messaging communication. If you make use of these services, we process, among other things, information related to the contents of the messages, the author and user name, time stamps, and other relevant information for administration purposes. Information that you place on forums and chat rooms and via instant messaging is public and can be read by other users of the thumbr platform.

Location data: If you have given permission to this aim, thumbr can, when you make use of the thumbr platform on or via a mobile device of computer, gain access to your location data (e.g. GPS coordinates or similar information about the location of your mobile device) and collect, manage and/or store this information. Location data can give us insight into how you use the thumbr platform. Take into account that if you switch off your location facilities on your mobile device or computer, some functions or parts of the thumbr platform may not function properly.

Purchase information about Virtual Goods: If you purchase virtual goods on the thumbr platform, we store the information that is related to this purchase, such as Device information, currency unit and exchange rate, Location data, product information and quantity. We use this information to store your supply of virtual goods on our servers so that you can use it or retrieve it later on a different device. If this supply changes, we keep track of those changes.

Data from third parties: thumbr can also collect personal data about you that it has obtained legally from third parties. For the purposes described in this Privacy statement and for updating your personal profile, thumbr can combine the personal data about you that it has received.

Use of your personal data by thumbr

If you have given permission to this aim, thumbr can use your personal data to approach you about programmes, products, services, offers or actions of third parties for direct marketing purposes of these parties about a wide range of subjects. thumbr can do this via post or telephone, as well as via email, MMS, SMS or similar electronic means.

Providing personal data to third parties

If you have given explicit permission to this aim, thumbr can provide your registration details to its sponsors. These sponsors, often advertisers or marketing agencies, are stated explicitly when you leave your personal data with thumbr. These sponsors can contact you for direct marketing purposes about a wide range of subjects related to their own programmes, products, services, offers or actions, as well as those of third parties (advertisers). They can do this via post or telephone, as well as via email, MMS, SMS or similar electronic means.

Providing personal data to third parties

If you have given explicit permission to this aim, thumbr can provide your registration details to its sponsors. These sponsors, often advertisers or marketing agencies, are stated explicitly when you leave your personal data with thumbr. These sponsors can contact you for direct marketing purposes about a wide range of subjects related to their own programmes, products, services, offers or actions, as well as those of third parties (advertisers). They can do this via post or telephone, as well as via email, MMS, SMS or similar electronic means.

You also provide permission for thumbr to provide your registration details to third parties that can approach you for direct marketing purposes about a wide range of subjects by post or by telephone.

Special personal data

Certain personal data that you provide to thumbr can be designated as ‘special personal data’. Examples of this kind of personal data include information about your racial or ethnic background, political beliefs, religion, state of health or sexual preference. By agreeing to this Privacy statement, you give thumbr explicit permission to process such data in accordance with this Privacy statement if you have provided it to thumbr. However, thumbr does not pass special personal data on to third parties for direct marketing purposes.

 

GAMES

If you make use of Games on the thumbr platform, in addition to the above-mentioned, the following provisions also apply.

Player information: thumbr collects player information such as your user name, your online and chat status, your most recently played game and scores, other game achievements (such as high scores) and profile photo (if applicable). This information is used to identify you as a player and will be visible to other players.

Game-specific information: thumbr collects Game-specific information, that is, information about each player and the game they are playing. This information includes information about the game concerned that is being played, Player information, device hardware information, total dashboard launches and the duration of the played game, the total online game sessions and the duration, the country code and the IP address. The purpose of this is to analyse Game experiences in order to improve the Games, as well as to be able to make targeted communications for direct marketing purposes.

thumbr shares Game-specific information in aggregated format with the developers of the Games. This aggregated information can, for example, contain the number of unique players who have logged in on a particular day, the number of Game sessions that are played and the number of players who have made a specific achievement in a Game.

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