EU Privacy Policy for Customers
Last updated March 08, 2022
This Privacy Policy (hereinafter “Policy”) informs you how Return Entertainment Oy (hereinafter “we”, “us” or “our”) collects, uses, and otherwise processes your personal data in connection with your use of our website wackybash.com and our game Wacky Bash (hereinafter together “Services”). It is important that you read this Policy carefully before accessing or using our Services so that you are aware of how we use your personal data.
1. Data controller
The data controller in accordance with the applicable data protection law is Return Entertainment Oy.
Contact details of the data controller:
Return Entertainment Oy
Business ID: 3088344-9
Address: Lapinlahdenkatu 16,
00180 Helsinki
Contact email for privacy matters: legal@returnentertainment.com
2. Categories of Personal data
The personal data processed by us is collected directly from you when you register, use the Service or interact with us. As you interact with our Services, we can also automatically collect technical information which may be associated with you, including through cookies and similar technologies. For more information about the use of cookies, please see our Cookie Policy.
The personal data we process includes e.g. the following categories of data:
- Contact data, such as your email address provided by you;
- Player data, such as player ID associated with your player account, information about your use of the game and your progress in the game and language preferences information
- [Correspondence data, such as messages and information that you provide when you contact us and your feedback and service-related communications provided to you by us
- Technical data, such as the device used to play the game, device type, operating system, application settings, location inferred from IP address (country, state, city), time stamps, language
- [Marketing data, such as your preferences in receiving marketing from us, information how you were referred to our game, information about ads displayed and marketing consents
- [Purchase data: such as billing information, payment method and contact details used for billing purposes
- Captcha data, such as IP address, information on how long you have been on the website or app and mouse movements
We do not process any special categories of personal data, such as personal data related to e.g. ethnic origin, political opinions, religious or philosophical beliefs, health, sex life or sexual orientation
1. Purpose and legal bases for processing personal data
We have set out below a chart of all the purposes for which we process your personal data, and which of the legal bases we rely on when doing so. We have also identified what our legitimate interests are where appropriate.
Where our processing is solely based on your consent you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal (please see section 7 of this Policy).
| Purpose | Legal basis | Type of data |
|---|---|---|
| We will use the described data to create and maintain your player account in our game and provide you the game and associated features to enable you to play. | This is necessary for the performance of a contract with you or to take steps at the request of you prior to entering a contract. | Contact Data Player Data Technical data Purchase Data |
| We will use the described data to send you service-related communication, such as security alerts and information about new features in our Services. We will also use the described data when you interact with us and when we respond to you and when you solicit feedback about our products and when we provide customer support. | This is based on our legitimate interest to provide you with relevant service-related information and provide support and enable you to provide feedback at your discretion. | Contact Data Player Data Correspondence Data |
| We will use the described data to operate our Services, to ensure security, and to develop and improve our Services. | Our legitimate interest to ensure that our Services function as intended, has an appropriate level of security, and that we have sufficient and relevant information at hand to develop our Service. | Player Data Technical Data |
| We will use the described data to personalise your game experience based on your activity in the game. | Our legitimate interest to ensure a better player experience. To the extent cookies and similar technologies are used for this purpose, the processing is based on your consent. | Player Data Technical Data |
| We will use the described data to promote our Services to you. For this purpose we may either send you news and offers about our Services or show you ads based on your activity as well as analyse and measure our advertising and their effectiveness. We can use third party advertising partners for this purpose. | In general, processing is based on our legitimate interest to promote our Services and analyse their effectiveness to our existing customers. Newsletters and similar materials by email are only sent where you have consented in receiving such material. To the extent cookies and similar technologies are used for this purpose, the processing is based on your consent. | Contact Data Player Data Marketing Data Technical Data |
| We may collect or use described data to comply with applicable law, such as accounting and tax legislation or with any requests by competent authorities under law. | Legal obligation to comply with applicable law and requests made by competent authorities. | Purchase data Data requested by competent authority |
| We use the hCaptcha anti-bot service on our website to check whether the data entered on our website (such as on a login page or contact form) has been entered by a human or by an automated program. This service is provided by a third-party provider Intuition Machines, Inc., a Delaware US Corporation (“IMI”). For more information about hCaptcha, please visit the following links: https://www.hcaptcha.com/privacy. | This is based on our legitimate interest to ensure that our Services function as intended, has an appropriate level of security | Captcha data |
When processing of personal data is based on our legitimate interest as mentioned above, we have conducted a so-called balancing test for those interests to ensure that our interest is not overridden by your interests or fundamental rights and freedoms. Please contact us by email at legal@returnentertainment.com if you wish to receive more information on the balancing test. Please note that you may object to processing based on legitimate interest at any time (please see section 7 of this Policy).
2. Transfers and disclosures of personal data
We may disclose personal data to third parties:
- when required by law, e.g. to comply with requests by competent authorities or related to legal proceedings; and
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets.
In addition, we may use third party service providers for the purpose of analytics. These service providers work on behalf of us and under our instructions. We will control and be responsible for the use of your personal data at all times.
3. Transfers of personal data outside the EEA
Some of our third-party service providers are established outside the EEA, including in the US, so their processing of your personal data will involve a transfer of data outside the EEA. However, to ensure that your personal information receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer, including where the European Commission have deemed the country to provide an adequate level of protection for personal data; or by use of specific contracts approved by the European Commission (Standard Contractual Clauses).
If you require further information on our current service providers established outside the EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by email at legal@returnentertainment.com.
4. Retention of personal data
We will keep your personal data during early access phase. We may periodically delete or de-identify unnecessary data.
5. Your rights
Under certain circumstances, you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party (also known as data portability). Where our processing is solely based on your consent you have the right to with-draw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
If you think there is a problem with the way we are handling your personal data, you also have a right to file in a complaint to your national data protection authority in the EU. In Finland you can lodge a complaint with the Office of the Data Protection Ombudsman at https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman. The list of all data protection authorities in the EU can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you wish to exercise any of the privacy rights that are available to you then please send your request to us by email at legal@returnentertainment.com.
6. Security
We maintain reasonable security measures (including physical, electronic, and administrative) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and contractors who need to know the information in the course of their work tasks.
7. Changes to this Policy
We may change this Policy from time to time. If we make any changes to this Policy, we will let you know it on our website at wackybash.com, where you will also find the latest version of this Policy.
8. Contact us
If you have any questions regarding this Policy or the personal data we process about you, please contact us at legal@returnentertainment.com.
Cookie Policy
Last updated March 07, 2022
This Cookie Policy explains how Return Entertainment Oy (hereinafter also “we”, “us” or “our”) uses cookies and other similar techniques on our website https://wackybash.com (“Website”) and our game Wacky Bash. You may access and change your cookie preferences at any time by clicking here.
1. What are cookies?
A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server. Cookies are typically used to remember your device, for example, to enable functionality and to store your preferences, such as language, for a certain period of time.
We also use other forms of technology, such as web beacons and pixel tags, which serve a similar purpose to cookies and which allow us to monitor and improve our Website. When we talk about cookies in this Cookie Policy, this term includes these similar technologies.
2. What cookies do and how long?
Our Website uses variety of cookies for different purposes. We use the following categories of cookies:
- Strictly necessary cookies are required to enable core functionality. They include, for example, cookies that enable us to deliver website content to you. Strictly necessary cookies are always active and cannot be disabled.
- Functional cookies are not essential but enable various helpful features on our Website. For example, these cookies may be used to remember your preferences and the presentation of the Website (such as the font size).
- Analytical cookies are used to measure how users interact with our Website and we use this information to improve the user experience and performance of Website. These cookies collect technical information such as the last visited pages, the number of pages visited, whether or not email communications are opened, which parts of our Website or email communication are clicked on and the length of time between clicks.
- Social media cookies allow you to share what you’ve been doing on our Website on social media and allow us and third-party providers to offer you a more personalized and engaged experience, for example, by offering you advertisements on your social media channels that are more relevant to you while allowing you to share your experiences via social media.
- Advertising cookies are used to deliver relevant ads to you and to make advertising more relevant to you and your interests. These cookies are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. Similarly, our third-party providers may use cookies to determine whether we’ve served an ad and how it performed or provide us with information about how you interact with them.
Strictly necessary cookies cannot be disabled. For other type of cookies we will ask for your consent and you can at any time change your cookie settings in this respect (See Section 4).
Each cookie lasts for a different period of time. We use both session cookies and persistent cookies.
- Session cookies will last only while your browser is open. When you close the browser, session cookies will be deleted automatically. Persistent cookies will survive even after closing the browser.
- Persistent cookies will for example recognize your device when you browse the Internet by opening the browser again. Persistent cookies are placed on the hard drive of your device and stored until they expire, or until you delete the cookies.
3. List of our cookies
The cookies can be set by us (so called “first-party cookies”) or by a third party (so called “third-party cookies”).
Your use of Website may result in some cookies being stored that are not controlled by us. This may occur when the part of Website you are visiting makes use of a third party analytics or marketing automation/management tool or includes content displayed from a third party website, for example, YouTube or Facebook. You should review the cookie policies of these services to find out how these third parties use cookies.
Below we have listed information on all our cookies, including the cookie type as well as the provider, purpose and duration of the cookie.
3.1 Strictly necessary cookies
| Cookie type | Provider | Purpose | Duration |
|---|---|---|---|
| Strictly necessary cookies | Return Entertainment Oy | To store and remember user’s cookie preferences | Persistent cookie, retention period 24 months |
| Strictly necessary cookies | Return Entertainment Oy | To authenticate the user once logged in through series of page requests | Persistent cookie, retention period 1 month |
3.2 Other cookies used only with your consent
| Cookie type | Provider | Purpose | Duration |
|---|---|---|---|
| Analytical cookies | Google Analytics | To measure audience, estimate number of visitors, to detect the most preeminent search engine keywords, to track down website navigation issues | Persistent cookie, retention period 24 months |
| Marketing cookies | Google Ads | To provide targeted advertising | Persistent cookie, retention period 6 months |
| Marketing cookies | Facebook Pixel | To provide targeted advertising | Persistent cookie, retention period 6 months |
| Marketing cookies | TikTok Pixel | To provide targeted advertising | Persistent cookie, retention period 6 months |
3. How do you manage these technologies?
You can manage your cookie settings and/or withdraw your consent by clicking “Manage Cookies” link in the footer of our Website.
You can also manage the use of cookies from your browser settings. You can delete all cookies that are already on your device by clearing the browsing history of your browser. You can also at any time change your browser settings and/or block all or some of cookies that are set on your device in the future through your browser settings.
4. Changes to this Policy
We may change this Cookie Policy from time to time. If we make any changes to this Cookie Policy, we will let you know it on our website at wackybash.com, where you will also find the latest version of this Cookie Policy.
5. Contact us
If you have any questions regarding this Cookie Policy or the personal data we process about you, please contact us at legal@returnentertainment.com.