Privacy Policy – Bertheussen IT AS

Bertheussen IT respect the privacy rights of our users and are committed to protecting the information collected through Wordfeud and other products (together “Services”). Bertheussen IT has adopted this privacy policy (“Privacy Policy”) to explain how Bertheussen IT collects, stores, and uses the information collected in connection with Bertheussen IT's Services.

Bertheussen IT AS is a Norwegian company. We are committed to comply with all applicable laws and regulations, including the General Data Protection Regulation 2016/679 (“GDPR”).

The Data Controller for our processing of personal data is Bertheussen IT AS.

Contact info

Should you have any questions relating to this Privacy Policy or our processing of personal data, please contact us at support@wordfeud.com.

1. The purpose and legal ground for the processing

Bertheussen IT collect and process your personal data for the following purposes:

Bertheussen IT may combine non-personal data with personal data. Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you.

Bertheussen IT will only use your personal data for a specific purpose if we have a legally valid ground to do so. The legal grounds that we rely upon and examples of use based on such legal grounds are:

2. Personal data that are processed

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies or can identify you as an individual.

Likely situations where you make personal data available to Bertheussen IT include, but are not limited to:

The types of personal data may vary depending on the type of activity you are engaged in. The personal data Bertheussen IT may collect and process may include, but are not limited to;

If you consent to allow your social networking site to make information available to Bertheussen IT and also provided that your social networking site permits it, Bertheussen IT may collect certain information from your social networking profile including but not limited to;

Bertheussen IT may associate and/or combine as well as use information collected by Bertheussen IT and/or obtained through such social networking sites in accordance with this Privacy Policy.

3. Your rights

You have several rights according to the GDPR when it comes to our use of your personal data, which are described below. If you want to make use of any of your rights we ask you to contact us at support@wordfeud.com.

The right to access and rectification

You have the right to request access to the personal data that we process and that relates to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing.

You also have a right, upon request, to access information about any evaluation or assessment of the balancing test we are required to conduct when we process your personal data based on our legitimate interest.

You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete.

Right to object

You have the right to object, on grounds relating to your particular situation, to the processing of personal data relating to you. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that overrides your privacy interest.

Right to erasure

You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, if the processing is based on your consent and you withdraw your consent for a specific process and there is no other legal ground for processing your personal data, if you object to the processing of personal data where we do not have an overriding legitimate interest, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement.

Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground.

Right to Data Portability

If you request access to personal data about you that you yourself have provided and if the personal data is being processed automatically with your consent or in accordance with a contract (or the terms) between you and Bertheussen IT, you may request that the data is provided in a structured, commonly-used and machine-readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.

Right to restrict

You are entitled to request Bertheussen IT to restrict the processing of your personal data in certain cases, pursuant to GDPR article 18.

Right to lodge complaints

If you are concerned or dissatisfied with how we process your personal data, you are always welcome to contact us on support@wordfeud.com. Once we have confirmed your identity, we will handle the request in accordance with applicable law.

Please note that even if you object to certain processing of personal data, we may still conduct the relevant processing if permitted or required to do so by law, for example to be able to fulfil legal or contractual requirements.

You always have the right to lodge a complaint with the relevant supervisory authority in particular where you live, work or where an alleged infringement of the GDPR has occurred. You can find the relevant authority in your country here:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

4. Disclosing and transfer of data

Bertheussen IT collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy.

Bertheussen IT may hire agents and contractors (“data processors”) to collect and process personal data on Bertheussen IT’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Bertheussen IT, according to applicable data processor agreements. These agents and contractors may not use your personal data for their own marketing purposes. Such data processors might be third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers.

Bertheussen IT may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Bertheussen IT to legal liability. Bertheussen IT may also disclose your personal data to third parties when Bertheussen IT has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Bertheussen IT’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Bertheussen IT believes that such disclosure is necessary to protect Bertheussen IT’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Bertheussen IT.

For processing of personal data in relation to Bertheussen IT’s use of analytics, in relation to the placement of ads in our applications as well as in relation to your use of you accounts with social medias to log in with us, se chapters 8, 9 and 10 below.

As Bertheussen IT delivers applications used worldwide, we will store and/or transfer your personal data to our data processors and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.

5. Data retention and correctness

Bertheussen IT retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Bertheussen IT deletes all aforementioned data in its possession. Bertheussen IT does not verify the correctness of personal data.

You are at all times entitled to require the deletion of your personal data by sending an e-mail to support@wordfeud.com. If your account is terminated, either by you or by Bertheussen IT, your personal data will be deleted.

If your account is and remains inactive (for example if you have not used the services) for a continued period of 3 years, Bertheussen IT will delete your personal data as well as terminate your account.

Concerning your use of chat services in our applications; chat logs are deleted 72 hours after you have finished the game.

Even if data is changed or deleted, Bertheussen IT may still retain some of the data to resolve disputes, enforce Bertheussen IT user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

6. Safeguards

Bertheussen IT follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Bertheussen IT’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Bertheussen IT’s possession.

Personal data collected by Bertheussen IT is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Bertheussen IT maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Bertheussen IT’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.

7. Cookies

Our webpage wordfeud.com does not set cookies.

8. Ad serving technology

Some versions of our applications, such as Wordfeud Free, serve advertisements. Advertisements shown can be generic or tailored to the user (personalized).

We use ad serving technology from Google, Facebook and MoPub/Twitter.

Ads placed by Facebook

Personalized ads delivered by Facebook is based in your user terms with Facebook.

If you choose to log into our services using your Facebook ID, Facebook will place advertisements for you. Our apps do not require your log in with Facebook ID. It is optional for you to log in with Facebook ID. Bertheussen IT has no influence over ad placement conducted by Facebook and Bertheussen IT do not process your personal data in relation to ads placed by Facebook. Facebook’s processing of personal data is subject to terms entered into by you with Facebook and Facebook provide you as a Facebook user with settings for personal data and ads, on the Facebook platform. You can find more information on Facebook’s use of personal data here:
https://www.facebook.com/about/basics
and more information on their use of, and your settings with them, concerning use of personal data to tailor ads here:
https://www.facebook.com/about/basics/advertising.

Ads placed by MoPub/Twitter

Personalized ads delivered by MoPub is based on your consent.

If you consent, you will be presented with personalized ads delivered by MoPub/Twitter in some of Bertheussen IT’s applications. For more information visit MoPubs Privacy Policy here: https://www.mopub.com/legal/privacy/.
Section 1 will be especially relevant to you as Section 1 describes personal data that will be processed if you consent to personalized ads.

Ads placed by Google

Personalized ads delivered by Google is based on your consent.

If you consent, you will be presented with personalized ads delivered by Google in some of Bertheussen IT’s applications. For more information on how Google process personal data in relation to ad placement, visit Google’s site here: https://policies.google.com/technologies/partner-sites.
This page also informs you about how you can administer your ads personalization settings with Google.

Bertheussen IT is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

9. In-app analytics

Bertheussen IT uses Google Firebase Analytics to measure the usage of our applications. Google is our data processor for Firebase Analytics and Bertheussen IT has entered into a data processing agreement with Google.

Through Firebase Analytics we monitor and collect statistics on usage of our applications. We use data collected through Firebase Analytics to monitor our applications as well as to improve our applications.

We do not use first party cookies or first party identifiers in relation to Google Firebase Analytics, which means that we do not relate data collected through Google Firebase Analytics to users we can identify.

Our implementation of Firebase Analytics is limited to collection and our use of statistical and aggregated data.

You can read more about data collected through Firebase Analytics including Firebase Analytics’ use of Advertising Identifier and use of masked IP-addresses here:

10. Third party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. Bertheussen IT is not liable for any such third party terms and conditions and their use of your personal data. Bertheussen IT may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Bertheussen IT. Bertheussen IT is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Bertheussen IT is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies. Please note that certain Services that Bertheussen IT may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID or gaming network account. When you register to join or use the Services from a third-party gaming or social networking system, certain personally identifiable user and/or membership data may be transferred automatically to and from Bertheussen IT.

11. Miscellaneous

Please be aware of the open nature of certain social networking and other open features of the Services Bertheussen IT may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any Data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Bertheussen IT is not responsible for any personal data you choose to make public in any of these forums.

If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. Bertheussen IT takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times.

In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of Bertheussen IT, Bertheussen IT’s customer information may be transferred to Bertheussen IT’s successor or assign.

12. Changes to our Privacy Policy

Due to changes in relevant regulations and administrative practices as well as due to changes in our services, we may from time to time need to modify this Privacy Policy. An updated version will at all times be available here. Please review our Privacy Policy frequently.

Last update: 5 September, 2018