This is the privacy policy of PUPGAM STUDIOS. It has been updated in August 2020.

The goal of Pupgam Studios is to create educational applications aimed at children. We are committed to being transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when using our services (described below). We offer our users different options about the data we collect, use and share, as described in this Privacy Policy and in the Cookie Policy.

Services

This Privacy Policy, which includes our Cookie Policy, applies to your use of our Services, that is, it applies to pupgam.com, Pupgam Studios branded applications and other sites related to Pupgam Studios, communications and services («Services»), including Services offered outside the website.

Changes

Changes to the Privacy Policy apply to your use of our Services after the «effective date».

Pupgam Studios S.L.U. («We») may modify this Privacy Policy and, if we make any material changes, we will notify you through our Services, or by other means, to offer you the opportunity to review the changes before they become effective. If you do not agree to any of the changes, you can close your account.

You represent that your continued use of our Services after posting or sending a notice about our changes to this Privacy Policy implies that the collection, use, and sharing of your personal data are subject to the updated Privacy Policy.

1.1. The data you provide us

You provide us with data to create an account in the Pupgam Studios s.l.u. applications, as well as when buying licenses in our Online Store, when you contact us or comment on the articles on our website.

Registry

To create an account, you must provide us with information such as your email address, as well as a password. If you buy in our Online Store, in addition to the email you must provide the payment and billing information. If you contact through the contact page you must fill out a form with your name and an email. If you leave a comment, you must enter an email.

1.2. Use of the Services

We record usage data when you play with our applications, also on our website, such as when you view or click on content (for example, a training video), perform a search, install or update one of our mobile applications. We use logs of device information and Internet Protocol («IP») addresses to identify you and record your use at Pupgam Studios s.l.u.

1.3. Cookies and other similar technologies

As described in our Cookie Policy, we use cookies and similar technologies (for example, pixels, ad tags, and device identifiers) to recognize you and / or your device or devices across the different Services and devices. We also allow other people to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also check the self-exclusion option so that we do not use cookies or similar technologies that track your behavior on other websites for third-party advertising. For Visitors, the self-exclusion option is found here.

1.4. Other information

We are improving our Services, which means that we receive new data and create new ways to use the data. Our Services are dynamic and we frequently introduce new functionality, which may require the collection of new information. If we collect very different personal data or if we change the way we use your data to a large extent, we will notify you and we may also change this Privacy Policy.

We use the data we have about you to provide and personalize our Services (including advertisements), with the help of automated systems and the inferences we make, so that they can be more relevant and useful both for you and for others.

2.1. Services

Our Services allow you to stay informed about news, events and ideas about the topics that interest you.

2.2. Communications

We will contact you by email or from the Pupgam Studios s.l.u applications. We will send you messages about the availability of our Services, security or other issues related to the services provided.We will also send you messages about how to use the Services, network updates, reminders, suggestions and promotional messages from us. You can change your communication preferences at any time.Please note that you cannot exclude yourself from our service messages, including security and legal notices.

2.3. Advertising

We do not show ads on our website or in our apps, but we do show them (and measure their performance) to our users and othersoutside of our Services directly or through a variety of partners, using the following data, independently or in combination:

* Data from advertising technologies on and off our Services, such as pixels, ad tags, cookies, and device identifiers.

* Data provided by Members (eg email).

* Data about your use of our Services (for example, search history, activity feed, content you read, opinion in comments, page visits, videos you watch , etc.), including what is described in section 1.3.

Information for advertisers: We will not share your personal data with any advertiser or with ad networks for their advertising, except: (i) device identifiers or labels (to the extent that they are not considered personal data in some countries); (ii) with your explicit permission (for example, through the lead generation form); or (iii) data that is already visible to any user of the Services. However, if you view or click on an ad on or off our website or applications, the advertiser will receive a signal that someone has visited the page displaying the ad and may determine that it was you through the use of mechanisms such as cookies. Our advertising partners may associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such cases, we contractually require those advertising partners to obtain your consent to explicit before doing so.

2.4. Marketing

We use data and content about users for communications that promote greater number of users and growth in interaction and our Services.

2.5. Customer service

We use the data (which may include your communications) to investigate, respond and resolve complaints and problems with the Service (for example, errors).

2.6. Security and investigations

We use your data (including your communications) if we think it is necessary for security reasons or to investigate possible fraud or other violations of our Terms of Use or this Privacy Policy, and / or attempts to harm our Members or Visitors.

3.1. Service providers

We may use other companies to help us with our Services.

We use third parties to help us provide our Services (for example, maintenance, analytics, audits, payments, fraud detection, marketing and development). Such third parties will have limited access to your information to the extent necessary to perform these tasks on our behalf and they are obliged not to disclose it or use it for other purposes.

3.2. Disclosures required by law

We may have to share your data when we think it is necessary by law or to protect your rights and security, ours or those of third parties.

We may be required to disclose your information when required by law, in a subpoena or other judicial proceeding or if we believe, in good faith, that disclosure is reasonably necessary to (1) investigate, prevent, or act against alleged illegal activities or to assist law enforcement agencies; (2) to enforce the Terms of Use; (3) investigate and defend against claims or allegations from third parties; (4) protect the security or integrity of our Service (such as sharing information with companies facing similar threats); or (5) exercising or protecting the rights and safety of Pupgam Studios slu from our Members, our staff, or others. We will try to notify Members that their data Personal data have been legally requested when we deem it appropriate in our judgment, unless prohibited by law, by a court order or when the request is an emergency.We may challenge these requirements when we consider, to our knowledge, that the requests are too broad, vague, or lack the necessary authority, although we do not undertake to challenge each request. For more information, see our Data Request Guidelines and Transparency Report.

3.3.Change of control or sale

We may share your data when our company is sold to other companies, but it must be used in accordance with this Privacy Policy.

We may also share your personal data as part of a sale, merger or change of control, or to prepare for any of these circumstances. Any other entity that purchases all or part of the company will have the right to continue using your data, but only in the manner described in this Privacy Policy unless you agree otherwise.

4.1. Preservation of data

We will keep the personal data you provide us as long as your account is active or to the extent necessary to provide you with the Services. This includes the data that you or others have provided us or the data generated or inferred from your use of the Services. Even if you only use our Services every several years, we will retain your information and keep your profile open until you decide to close your account.

4.2. Right of access and control of your personal data

You can access or delete your personal data. You have many options when choosing how your data is collected, used and shared.

We provide numerous options to collect, use and share your data, from deleting or correcting the data you include in the profile from applications to marking the option of self-exclusion from emailings to avoid receiving advertising and Communications controls We offer you a configuration that allows you to control and manage the personal data we have about you.For your personal data we have:

* Delete data: you can ask us to delete or delete all or part of your personal data (for example, if it is no longer necessary to offer you Services). Contact via email: info@pupgam.com indicating your request .

* Change or rectify data: you can edit part of your personal data through your account in the Pupgam Studios - Account applications. You can also ask us to modify, update or correct your data in certain cases, especially if they are not accurate.

* Right of access or collection of your data: you can request a copy of your personal data and a copy of the personal data included in machine-readable format from us.

You can contact us using the contact information below; we will handle your request in accordance with applicable law.

4.3. Account closure

If you decide to close your Pupgam Studios slu account, your personal data will no longer be seen on our Services, generally within 24 hours. Normally, we delete information from accounts closed in a period of 30 days from the closing of the account.

5.1. Security

We monitor and try to prevent security breaches. Use the security features available on our Services.

We apply security measures designed to protect your data, such as HTTPS. We periodically monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee the security of the information you send us. There is no no guarantee that data will not be accessed, disclosed, altered, or destroyed if any of our physical, technical, or managerial security measures are breached. Visit our Security Center for more information on how to use our Services in a secure, including two-factor authentication.

5.2. Cross-border data transfers

We process data both inside and outside of Spain and we rely on legal mechanisms to legally transfer data between countries. The countries in which we process data may have different laws, and possibly provide less protection, to the legislation of your country.

5.3. Legal grounds for processing

We have legal grounds for collecting, using and sharing your data. You can choose how we use your data.You can withdraw your consent at any time by contacting info@pupgam.com

We will only collect and process your personal data as far as the legal grounds allow. The legal grounds include consent (if you have given it), contract (if processing is necessary for the realization of a contract with you to provide the Services you have requested, for example) and «legitimate interests». Your consent is necessary for the processing of personal data, and you can withdraw or revoke it at any time. Similarly, you can raise objections to our legitimate interests.

We may process your personal data for purposes relating to our legitimate interests or those of third parties (for example, your employer or company), provided that such processing does not violate your rights and freedoms. For example, we may process your personal data to:

* Protect yourself, ourselves or others from threats (such as security hazards or fraud)

* Comply with the laws that apply to us

* Enable or manage our business, for example, for quality control, consolidated reporting, and customer service purposes

* Manage corporate transactions, such as mergers or acquisitions.

* Understand and improve our business activity or customer relationships in general.

If you have any questions about the legal grounds on which the collection and use of your personal data is based, please contact our Data Protection Officer via email at info @ pupgam. com

5.4. Contact information

If you have any questions or complaints about this Policy, contact Pupgam Studios online first. You can also contact us by mail. Pupgam Studios has the offices at C / Noguera Pallaresa, 22, local 2 - 08014 Barcelona, ​​Spain. If after contacting us your complaint is not resolved, there are other options available.