Any mention in this policy of “us,” “we,” “Sensers.com,” or “our” refers to Sensers.com.
– The Maltese Data Protection Act (hereinafter referred to as the Data Protection Act, “DPA” – Chapter 586 of the Laws of Malta), as well as any subsidiary legislation dealt with under the DPA, may be amended from time to time and
– Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons concerning the processing of personal data and the free circulation of these data and which repeals Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “Regulation” or “GDPR”).
The DPA and the GDPR will hereinafter be collectively referred to as the “Data Protection Laws.”
Sensers.com determine the means and purposes of the processing of Personal Data and therefore act as a “Data Controller” under the Applicable Data Protection Laws.
The person in charge of the processing
“The Data Controller” will be a natural or legal person, public authority, agency, or any other body that, by itself or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by national law or regulation, the data controller or the specific criteria applicable to his or her appointment;
The data processor
The natural or legal person, public authority, service, or any other body that processes personal data on behalf of Sensers.com;
“Personal data” refers to any information identifying you or belonging to an identified or identifiable natural or legal person.
PERSONAL DATA PROTECTION
The personal data we collect and store is protected using the industry’s highest security processes and systems. Our commitment to protecting your personal information is not only through high-quality standards but also through the best and most efficient application of the law. We are obliged to only process personal data based on a legitimate and genuine reason to do so, based on one of the legal bases established in the GDPR.
PROCESSING BASED ON OUR LEGITIMATE INTERESTS
A legitimate interest will exist when we have a commercial or business reason that requires us to process personal data. In this case, we will protect all your personal data and how said data has been processed to ensure that it is not unfair to you or your interests.
Suppose we decide to process your personal data based on legitimate interest. In that case, we will inform you of what that legitimate interest is, and you will be given access to a process in which you can make any objections and/or questions that you may have in relation to said process. It is important to note that Sensers.com is under no obligation to stop processing your data unless specially requested.
PROCESSING BASED ON YOUR CONSENT
Consent is not the only way we have to obtain permission or be obliged to process your personal data. We will only process personal data with your consent if we are unable or choose not to apply any underlying legal basis (such as to comply with a legal obligation or legitimate interest). If we process your personal data based on your consent, you have the right to withdraw your consent at any time and in the same way as you previously provided. If you exercise your right to withdraw your consent, we will determine whether we can or are required to process your personal data based on any legal basis other than consent. In such a case, you will be notified in the appropriate manner.
To avoid any uncertainty, we would like to point out that in those limited cases where we cannot or choose not to rely on a legal basis (for example, our legitimate interests), we will process your personal data based on your consent.
In cases where we process the data based on your consent (which we will never take for granted, and you must provide consent clearly), YOU HAVE THE RIGHT TO WITHDRAW your consent at any time way it was given.
Suppose you exercise your right to withdraw your consent at any time (by writing to us via electronic mail). In that case, we will determine whether there is an alternative legal basis for the processing of your personal data at that stage (for example, based on the legal obligation to which we are subject) where we would be legally authorized (or even obliged) to process your personal data without the need to have your consent and, if we do, you will be adequately informed.
When we ask you for such personal data, you can always refuse; however, if you refuse to provide us with the necessary data that we ask you to provide you with the requested services, we do not guarantee that we will be able to provide those services (especially if consent is the only legal basis available to us).
To be clear, consent is not the only basis that allows us to process your personal data. In the previous section, we have mentioned the different bases we rely on when processing your personal data for specific purposes.
- Your use of Sensers.com (such as timestamps, clicks, scrolling, browsing times, browsing heatmaps, searches, referral/exit pages, cookies on/off, and activity and interactions in our game clients, including chat logs);
- Your computer or device (such as IP addresses, mobile network information, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, geographic location, screen resolution, color depth, and similar settings);
- How Sensers.com perform, including problems you may encounter (such as loading errors and response times).
We may use technologies like cookies, scripts, and our own servers to help us collect and store this information, including in log files.
We may need to use and retain personal information for loss prevention and protect our rights, privacy, safety, property, or those of others according to our legitimate interests.
We will retain data for limited periods when it is needed for business or legal reasons. We need to ensure that our services protect information from accidental or malicious deletion. Because of this, there may be delays between the time you delete something and the copies from our backup system are deleted. If you need more information, don’t hesitate to contact us.
AUTHORIZED DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
When any personal data has to be transferred outside the EEA – European Economic Area, we will ensure that the necessary and appropriate precautions are taken. We may also share your personal information with other affiliated or subsidiary companies and business partners or successors to our business. The manner in which data is transferred outside the EEA is detailed below. Your personal data will never be shared with third parties for marketing purposes (unless you give your consent).
SHARING PERSONAL DATA WITH OTHER CATEGORIES OF RECIPIENTS
Any other authorized disclosures will be made in accordance with Data Protection Laws (for example, all of our processors are contractually bound to comply with the requirements of such data protection laws, including a strict obligation to maintain the confidentiality of all information they receive by ensuring that your employees or staff also have that similar obligation). These service providers (our managers) are also subject to a series of obligations (particularly those established in Article 28 of the GDPR).
Your personal data will never be shared with third parties for marketing purposes (unless you give your consent).
You are aware that data sent over the internet may be transmitted across international borders, even when the sender and recipient are from the same country. We cannot be held responsible for any actions taken or omitted by you or any third party in relation to personal data prior to our receipt of it, including but not limited to any transfer of personal data to us through a country with a lower level of data protection than that of the European Union and through any electronic means (for example, WhatsApp, Skype, Dropbox, etc.).
Furthermore, we will not accept any responsibility for the security of your data. At the same time, it is being sent over the internet unless our responsibility is made explicit based on a law that has an effect in the country.
ACCURACY OF PERSONAL DATA
Reasonable steps are taken to keep all our personal data about you up to date and as accurate as possible. At any time, you can check what information we have about you by contacting us in the means we described earlier. If we find any inaccuracies, we will correct them, and when requested, we will delete them if necessary. Please see below for a detailed list of your legal rights based on any terms where data protection law may apply.
LINKS TO THIRD PARTY PAGES
TRANSFER OF DATA OUTSIDE THE EEA
Your personal data will only be transferred outside the EEA or to some other non-EEA country where the European Commission has deemed it to have an adequate level of protection (also referred to as “white list countries,” mentioned below https://ec.Europa.EU/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) in the following circumstances: Where you have given us your express consent to do so; when it is necessary to establish or perform a contract between you and Sensers.com; or to comply with all of our legal obligations and duties.
In the event that personal data is transferred outside of the EEA, whether to Sensers.com or to a Sensers.com business partner, we ensure that all appropriate safeguards are in place to ensure that the same level of protection is offered and that the same standards as within the EEA. You are entitled to receive a copy of such warranties by contacting us.
Contracts that have the EU standard contractual clauses (EU Model Clauses) will be used, which will require the entity receiving this personal data to use the standards to which they would be subject within the EEA. If some data is transferred to the US and the entity receiving the information is registered under the Privacy Shield (a framework that ensures personal data protection), it will have the same level of protection approved by the European Commission.
RIGHTS OF THE INTERESTED PERSON
Sensers.com is committed to assisting you in the best possible way if you choose to exercise any of your rights with respect to your personal data. We may need to verify your identity in some specific cases before granting your request to exercise any of your corresponding rights.
Right of access
You have the right to ask us if we are processing any personal data that affect you, and, if this is the case, you will have the right to access said personal data, as well as the following information:
- What personal data we have,
- Why we process them,
- With whom we share them,
- How long do we plan to keep them,
- If we are going to transfer them out of the country and the measures we take to protect them,
- What are your rights,
- How you can make a claim,
- Where we have obtained your personal data and if we have carried out any automated decision-making (including profiling) and the associated information.
Right to rectification
You have the right to ask us to rectify and/or complete any incomplete or inaccurate personal data concerning you.
Right to delete data (the “right to be forgotten”)
You have the right to ask us to erase your personal data, and we must comply without undue delay, but only when:
- The personal data is no longer necessary for the purpose for which it was collected, or
- You have withdrawn your consent (in cases where we process the data based on your consent), and we have no other legal basis to process your personal data; or
- When we have successfully exercised your right to object (as explained below); or
- Your personal data has been unlawfully processed; or
- When there is a legal obligation to which we are subject; or
- When there are special circumstances related to certain rights of minors.
In any case, we may not be legally obliged to comply with requests to erase your data if the processing of your personal information is necessary to comply with legal obligations imposed on us.
Right to restriction of processing
You have the right to ask us to restrict the processing of your personal data. However, you can only exercise this right in the following cases:
- If the accuracy of your personal data is disputed (see above the right to rectification of data), allowing us to verify the accuracy of the personal data; or
- If the processing is unlawful and you oppose the deletion of your personal data; or
- If we no longer need the Personal Data for the purpose for which it was collected, but you need the Personal Data to establish, exercise, or defend your legal claims; or
- If you exercise your right to object and verification of our legitimate grounds for overriding your objection is still pending.
If you successfully exercise this right, we will only be able to process your personal data:
- Where we have your consent; or
- To establish, exercise, or defend legal claims; or
- To protect the rights of another natural or legal person; or
- For important reasons of public interest.
Right to data portability
You have the right to ask us to provide you with your personal data, which will be those that you have previously provided to us. We will provide such data to you in a structured, commonly used, machine-readable format, or (where technically possible) we may have submitted the data to another data controller, providing this data does not adversely affect the rights or freedoms of others. You can only exercise this right in the following cases:
- The processing is based on your consent or performance of a contract we have with you; and
- The processing is carried out by automated means.
Right to object to processing
In certain cases, you have the right to object to the processing of your personal data. We only process your personal data based on one of the following purposes:
- The processing is necessary to carry out a task of public interest; or
- When the processing is necessary for the purposes of the legitimate interests pursued by a third party or by us.
The processing will only end if the data controller has not provided a convincing and legitimate basis that has overcome the objections you have made to your request and requires the process to continue.
If your data is being processed for different marketing purposes, you have the right to object to processing your personal data at any time.
This general right to object will not persist in other situations than those mentioned above.
Right to make a claim.
In relation to your data, you can file a claim at any time with any data protection supervisory authority if you believe that your rights have been affected by Sensers.com.
Notwithstanding this right, please try to resolve any issues you may have with us before filing a complaint.
It is important to note that notwithstanding these rights, Sensers.com may deny any such request if it can reasonably justify such a decision.
If you have any questions/comments about privacy or wish to exercise any of your individual rights, don’t hesitate to get in touch with us.