PRIVACY POLICY

PRIVACY POLICY

Last updated 19th July 2024



Surf Punk Interactive, Inc. ("SPI", "we", "us", "our") is committed to protecting and respecting your privacy. This Privacy ​Policy explains how we collect, use, and safeguard personal data when you use our game Retropy and related services ​("Services"), or visit our websites ("Websites").


1. INTRODUCTION


This Policy covers our collection, processing, and use of personal data when you engage with our Services or Websites. It's ​important that you read this Policy carefully, as well as any other privacy notices we may provide on specific occasions ​when we are collecting or processing personal data about you.


By using our Services or Websites, you're agreeing to be bound by this Policy. If you disagree with any part of this policy, ​please discontinue use of our Services and Websites.


2. WHAT IS PERSONAL DATA AND WHAT DO WE COLLECT?


Personal data refers to any information about an individual from which that person can be identified. We may collect, use, ​store and transfer different kinds of personal data about you, which we have grouped together as follows:


a) Identity Data: This includes first name, last name, username or similar identifier.


b) Contact Data: This includes email address and telephone numbers.


c) Technical Data: This includes internet protocol (IP) address, your login data, browser type and version, time zone setting ​and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you ​use to access our Services or Websites.


d) Usage Data: This includes information about how you use our Services and Websites.


e) Game Data: This includes your in-game progress, purchases, and interactions within the game.


3. ANALYTICS DATA


We collect anonymized data about your use of our Services to improve our products and understand player behavior. This ​may include:


- Frequency and timing of game usage

- In-game events and progress

- Hardware configuration and specifications


This Analytics data is anonymized and not linked to your personal data. You may be able to adjust your device settings to ​limit the Analytics data we can obtain.


4. HOW AND WHY WE USE YOUR PERSONAL DATA


We use your personal data for the following purposes:


a) To provide and maintain our Services

b) To notify you about changes to our Services

c) To allow you to participate in interactive features of our Services when you choose to do so

d) To provide customer support

e) To gather analysis or valuable information so that we can improve our Services

f) To monitor the usage of our Services

g) To detect, prevent and address technical issues


5. LEGAL BASIS FOR PROCESSING PERSONAL DATA


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the ​following circumstances:


a) Where we need to perform the contract we are about to enter into or have entered into with you.

b) Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those ​interests.

c) Where we need to comply with a legal or regulatory obligation.


6. SHARING YOUR PERSONAL DATA


We may share your personal data with:


a) Any member of our corporate group, including subsidiaries, our ultimate holding company and its subsidiaries.

b) Selected third parties including business partners, suppliers and sub-contractors for the performance of any contract

we enter into with them or you.

c) Analytics and search engine providers that assist us in the improvement and optimization of our Websites.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law.


7. DATA SECURITY


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or ​accessed in an unauthorized way, altered or disclosed. We limit access to your personal data to those employees, agents, ​contractors and other third parties who have a business need to know.


8. DATA RETENTION


We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the ​purposes of satisfying any legal, accounting, or reporting requirements.


9. YOUR LEGAL RIGHTS AND DATA DELETION REQUESTS


Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the ​right to:


a) Request access to your personal data

b) Request correction of your personal data

c) Request erasure of your personal data

d) Object to processing of your personal data

e) Request restriction of processing your personal data

f) Request transfer of your personal data

g) Right to withdraw consent


Data Deletion Requests:

You have the right to request that we delete any personal data we have collected about you. To submit a data deletion ​request, please contact us at privacy@surfpunk.xyz with the subject line "Data Deletion Request".


Upon receiving your request, we will delete your personal data from our records unless we are legally required to retain ​certain information. We will process your request within a reasonable timeframe and notify you once the deletion is ​complete.


Please note that once your data is deleted, we will no longer be able to provide you with certain services that require this ​information. However, we respect your right to have your data deleted and will honor all deletion requests, regardless of ​the circumstance, unless we are legally required to retain the data.


If you wish to exercise any of these rights, including data deletion, please contact us using the details provided in the ​"Contact Us" section below.


10. CHILDREN'S PRIVACY


Our Services are not intended for children under 13 years of age. We do not knowingly collect personal data from children ​under 13. If you become aware that a child has provided us with personal data, please contact us. If we become aware that ​we have collected personal data from children without verification of parental consent, we take steps to remove that ​information from our servers.


11. CHANGES TO THIS PRIVACY POLICY


We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy ​on this page and updating the "Last Updated" date at the top of this Privacy Policy.


12. CONTACT US


If you have any questions about this Privacy Policy, please contact us at:


Surf Punk Interactive, Inc.

8 The Green Ste R

Dover, DE 19901

United States


Email: privacy@surfpunk.xyz


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