Effective Date: November 19, 2024

Constant Wave Technologies S.L. (“we”, “us”, “our”) is a company registered in Spain with CIF: ESB19408350. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our mobile and desktop games. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Table of Contents

1. Information We Collect

We collect information to provide better services to our users. The types of information we collect include:

Personal Data

  • Email address (when you contact us or create an account)
  • Username and profile information
  • Payment information (processed through secure third-party payment providers)

Usage Data

  • Game progress and achievements
  • In-game purchases and virtual currency transactions
  • Feature usage and interaction patterns
  • Game performance metrics
  • Session duration and frequency
  • Device information and settings

Technical Data

  • Device advertising ID
  • Operating system and version
  • Browser type and version
  • Device type and model
  • Time zone setting and location

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To provide and maintain our services
  • To improve our games and user experience
  • To personalize content and advertisements
  • To communicate with you about updates and changes
  • To prevent fraud and ensure security
  • To comply with legal obligations
  • To analyze usage patterns and optimize performance
  • To provide technical support

We process your information based on the following legal grounds:

  • Consent: When you explicitly agree to the processing of your data
  • Contract: When processing is necessary to fulfill our contractual obligations
  • Legal Obligations: When required by applicable laws
  • Legitimate Interests: When we have a legitimate business interest that doesn’t override your rights

4. Data Sharing and Disclosure

We may share your information with:

Third-Party Service Providers

  • Analytics providers (e.g., Google Analytics)
  • Advertising partners
  • Cloud storage providers
  • Payment processors
  • Customer support services
  • Court orders and legal processes
  • Government requests
  • Protection of legal rights

Business Transfers

  • In the event of a merger, acquisition, or sale of assets

5. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

  • Encryption of data in transit and at rest
  • Regular security assessments
  • Access controls and authentication
  • Regular backup procedures
  • Incident response plans

6. Your Rights

You have certain rights in connection with your personal information and how we handle it.

Those rights include:

Right of access: You have the right to request access to the personal information we hold about you. This allows you to receive a copy of the data we have collected and to check that we are lawfully processing it.

Right to correct personal information: If any of the personal information we hold about you is incorrect or incomplete, you have the right to request correction or completion. This ensures that your data is accurate and up-to-date.

Right of erasure: Also known as the “right to be forgotten,” you can request the deletion of your personal information when there is no compelling reason for us to continue processing it. This right applies under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

Account deactivation: You have the right to deactivate your account with us. This will stop any further processing of your personal information associated with the account, although we may retain certain data as required by law or for legitimate business purposes.

Data portability: You have the right to request the transfer of your personal information to another service provider in a structured, commonly used, and machine-readable format. This allows you to move, copy, or transfer your data easily between different services.

Restriction of processing: You can request that we limit the processing of your personal information under certain circumstances, such as when you contest the accuracy of the data or object to our processing activities. This means we will only store your data and not process it further until the issue is resolved.

Right to object: You have the right to object to the processing of your personal information based on our legitimate interests or for direct marketing purposes. If you object, we will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.

Direct marketing opt out: You can opt out of receiving direct marketing communications from us at any time. This includes promotional emails, newsletters, and other marketing materials. We will provide an easy way for you to unsubscribe from such communications.

Right to opt-out (USA): Residents of certain US states have the right to opt out of the sale of their personal information. If you exercise this right, we will not sell your personal data to third parties.

Right to lodge a complaint to the supervisory authority (EEA/UK/Canada): If you believe that our processing of your personal information violates applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority in your country of residence.

Residents of some US states may also designate an agent to make requests to exercise your rights as described above. This agent must be authorized to act on your behalf and may be required to provide proof of authorization.

To exercise any of these rights, please contact us at:

  • Email: info@constantwave.tech
  • Data Protection Officer: dpo@constantwave.tech

We will respond to your request within the timeframe required by applicable law. Note that some rights may be subject to limitations and exceptions under applicable laws. We may need to verify your identity before processing your request.

7. International Data Transfers

We transfer data internationally in compliance with:

  • EU Standard Contractual Clauses
  • Privacy Shield Framework (where applicable)
  • Adequate safeguards as required by GDPR

8. Children’s Privacy

8.1 Age Restrictions

We take children’s privacy seriously and comply with various international regulations regarding the collection of personal information from minors:

  • United States (COPPA): We do not knowingly collect personal information from children under 13 years of age without verifiable parental consent.
  • European Union (GDPR): For users in the EU, we do not process personal data of children under 16 years old without parental/guardian consent. This age may be lower in certain EU member states but will not be below 13.
  • United Kingdom (Age Appropriate Design Code): We implement special protections for users under 18, including privacy settings defaulting to high privacy.
  • Brazil (LGPD): Collection of children’s (under 12) data requires specific parental consent.

8.2 Parental Controls and Rights

Parents or legal guardians have the right to:

  • Review their child’s personal information
  • Request deletion of their child’s personal information
  • Refuse further collection or use of their child’s information
  • Provide or revoke consent for specific features
  • Control in-game purchases and social features

8.3 Collection and Use of Children’s Data

If we discover that we have collected personal information from a child without appropriate parental consent, we will:

  1. Immediately cease collecting any further information
  2. Remove the child’s personal information from our records
  3. Disable any features that may collect personal information
  4. Notify parents/guardians of the data collection

8.4 Special Protections

For games that may appeal to children, we implement:

  • Age-appropriate privacy settings
  • Restricted social features
  • Limited data collection
  • Clear privacy information in age-appropriate language
  • Parental controls for in-app purchases
  • Restricted third-party data sharing

When required, we obtain verifiable parental consent through:

  • Credit card verification
  • Government ID verification
  • Signed consent form
  • Direct contact with parent/guardian
  • Other legally acceptable methods

8.6 Contact Information for Parents

Parents/guardians can contact us regarding their children’s privacy at:

  • Email: privacy@constantwave.tech
  • Data Protection Officer: dpo@constantwave.tech

We will respond to all parental requests within 48 hours.

9. Cookies and Tracking Technologies

Please note: Cookies are currently disabled on our website. This means that no cookies, including essential, performance, functional, or targeting/advertising cookies, are being set or used at this moment. We will update our privacy policy and notify users if this changes in the future.

9.1 What Are Cookies

Cookies are small text files that are stored on your device when you visit our website. We and our authorized partners also use similar technologies such as pixels, web beacons, and local storage.

We categorize cookies based on their purpose and necessity:

9.2.1 Strictly Necessary Cookies (Always Active)

These cookies are essential for the website to function and cannot be switched off. They include:

  • User session management
  • Security features
  • Basic website functionality
  • Load balancing

These cookies do not store any personally identifiable information.

These cookies help us understand how visitors interact with our website by collecting anonymous information:

  • Analytics data (Google Analytics)
  • Error reports
  • Page load times
  • User behavior patterns

These cookies enable enhanced functionality:

  • Language preferences
  • Game settings
  • User preferences
  • Social media integration

These cookies are used for marketing purposes:

  • Behavioral advertising
  • Ad measurement
  • Audience profiling
  • Social media tracking

In accordance with EU law:

  • We obtain explicit consent before setting non-essential cookies
  • We provide granular cookie controls
  • Users can modify their consent at any time
  • We repeat consent requests annually or after significant changes
  • We maintain consent logs

Our cookie banner:

  • Appears on first visit
  • Remains visible until a choice is made
  • Provides clear accept/reject options
  • Links to detailed cookie information
  • Allows granular cookie selection
  • Is available in multiple languages

You can manage your cookie preferences through:

  • Our Cookie Preference Center
  • Your browser settings
  • Third-party opt-out tools

9.6 Duration of Cookies

We use two types of cookies based on their duration:

  • Session Cookies: Deleted when you close your browser
  • Persistent Cookies: Remain on your device for a specified period

9.7 Third-Party Cookies

Some cookies are placed by third-party services. We work with:

  • Analytics providers
  • Advertising networks
  • Social media platforms
  • Payment processors

For these cookies, please refer to the respective third parties’ privacy policies:

  • Google Analytics: [Link]

A detailed list of all cookies we use is available in our Cookie Preference Center, including:

  • Cookie name
  • Purpose
  • Duration
  • Provider
  • Category
  • Data collected

9.9 Do Not Track

We respect Do Not Track (DNT) signals. When DNT is enabled, we disable all non-essential cookies.

We regularly review and update our cookie practices. Changes will be reflected in:

  • This policy
  • Our Cookie Preference Center
  • Cookie consent notices

9.11 Contact Information

For questions about our cookie practices:

  • Email: privacy@constantwave.tech
  • DPO: dpo@constantwave.tech

10. Changes to This Privacy Policy

We will notify you of material changes to this policy through:

  • Email notification (if we have your contact information)
  • Notice on our website
  • In-game notifications

11. Contact Us

Constant Wave Technologies S.L. Calle Agustin de Foxa, 4 2B 28036 MADRID SPAIN Email: info@constantwave.tech

Data Protection Officer: Email: dpo@constantwave.tech

12. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority. In Spain, the competent authority is:

Agencia Española de Protección de Datos (AEPD) C/ Jorge Juan, 6 28001 Madrid