Last amended on 01 of January 2019
1. General information
1.1 The company “GoRMBGames – RMB INVESTMENT COMPANY INC” having a principal place of business at 17150 North B Road #2516, Sunny Isles Beach, Florida, 33160, the United States (“we”, “us”, or “our”) collects from individual users, including children under the age of 16, (“you” or “your”) certain personal data through the website http://gormb.games and the related mobile applications (collectively, “GoRMBGames”).
1.2 GoRMBGames is primarily targeted at children and provides educational games for children.
2. Kinds of personal data collected by us
2.1 Taking into account that GoRMBGames is primarily targeted at children, we respect strictest data protection principles.
2.2 When you use GoRMBGames, we do not collect any personal data from you. Our analytics functionality may have access to your IP address. However, we neither store nor use or access your IP address for any purposes. Your IP address is not used, in any manner, including in combination with other information, to identify you.
2.3 The personal data listed below may be provided by you voluntarily:• When you send us feedback or contact us via email or the contact form available on GoRMBGames, we collect your (i) name, (ii) email address, and (iii) any other personal data you decide to provide us. We delete such personal data from our databases as soon as we reply to your message. • When you subscribe for a newsletter, we collect your email address. Please note that, if you are under the age of 16, the newsletter is delivered only after obtaining verifiable parental consent.
2.4 We shall not, in any manner, make your personal data public.
2.5 Sensitive data. We do not collect, under any circumstances, any sensitive data from you, such as your health information, opinion about your religious and political beliefs, ethnic origins, membership of a professional or trade association, or information about your sexual orientation.
3. Kinds of non-personal data collected by us
3.1 When you use GoRMBGames, we may collect your non-personal data. The non-personal data includes analytics data, such as your activity on GoRMBGames, the browser types used by you, operating systems, and the URL addresses of websites clicked to and from GoRMBGames. The non-personal data collected by us does not allow us to identify you in any manner.
3.2 Aggregated data. We do not aim to aggregate your personal data and non-personal data. In case your non-personal data is aggregated with certain elements of your personal data in the way that allows us to identify you, we will treat such aggregated data as personal data.
3.3 Purposes of non-personal data. The non-personal data is used to analyze what kind of users visit GoRMBGames, how they find it, how long they stay, from which other websites they come to GoRMBGames, what pages they look at, what functionalities of GoRMBGames they use, and to which other websites they go from GoRMBGames. We use the non-personal data to improve our business activities and provide you with the best possible services.
4. The purpose of collection of your personal data
4.1 We use your personal data only for the purposes for which such personal data is provided:
• Your email address, name, and other personal data (if any) submitted through the contact form are used to reply to your requests on a one-time basis. After we reply to your request, we immediately delete such personal data.
• Your email address provided for subscribing to our newsletter is used to deliver our newsletter and provide you with advertisements of products and services, which may be of interest to you.
4.2 In certain exceptional cases, the personal data collected by us may also be used for audit and security purposes.
4.3 Legal grounds for data processing. Depending on the circumstances in which you provide your personal data to us, the collection and processing of your personal data by us is carried out on the basis of one of the following legal grounds:
• Pursuing our legitimate business interests (e.g., analyzing the usage of GoRMBGames);
• If you have provided us with your explicit consent; or
• If we are required by law to do so.
5. Protection of your personal data
5.1 We will put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of your personal data. We use organizational and technical security measures to protect all types of personal data, such as limited access to your personal data by our staff, secured networks, and encryption.
5.2 Security breaches. Please note that, due to the inherent risks of using the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances beyond our reasonable control. In case a personal data breach occurs, we will inform the relevant data protection authority without undue delay and immediately take reasonable measures to mitigate the breach, as stipulated in the applicable law.
6. Disclosure of personal data to third parties
6.1 In certain situations, we may disclose your personal data to third parties. Such a disclosure is limited to the situations when the personal data is required for the following purposes:
• Ensuring the operation of GoRMBGames;
• Pursuing our legitimate interests;
• Carrying out our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior explicit consent.
6.2 Your personal data may be disclosed to third parties that provide professional, technical, and other types of support to us, including:
• Our hosting and data storage providers (e.g. https://cp.freehostia.com, www.google.com);
6.4 We may respond to lawful requests from U.S. public authorities to disclose information about the users of GoRMBGames to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
6.5 We may share aggregated or anonymized information and non-personal data with third parties for the purposes of developing services that may be of interest to you.
6.6 With the exception of the cases in this Section 6, we do not disclose, without your prior verifiable consent, or sell your personal data to third parties and we do not intend to do so in the future.
7. Transfer of personal data outside the EEA
8. Exercising your rights
8.1 We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date.
8.2 We provide you with the possibility to exercise your rights regarding your personal data.
You can request us to:
• Access your personal data that we retain;
• Move your personal data to another entity;
• Delete your personal data from our systems;
• Object and restrict processing of your personal data;
• Withdraw your consent;
• Process your complaint.
8.3 If you would like to exercise your rights listed above, please contact us by email at email@example.com. We may ask you to provide us with an identifying piece of data, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 1 week.
8.4 Launching a complaint. If you would like to launch a complaint about the way in which your personal data is handled, we kindly ask to contact us first. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
9. Retention period
9.1 Your personal data will be kept for as long as is necessary to provide you with the requested service. For instance, if your personal data is collected to deliver the newsletter, your personal data will be kept until you unsubscribe from the newsletter service; if you contact us by using the contact form, we will retain your personal data only until we reply to your enquiry.
9.2 When your personal data is no longer necessary to deliver the requested service or you cease using GoRMBGames, we will immediately delete your personal data, unless we are required by the applicable law to retain such personal data for a certain period of time.
10.1 We will seek explicit prior consent from you (if you are above the age of 16) or you parent or guardian (if you are under the age of 16) in the following cases:
• Before using your personal data for newsletter delivery purposes;
• Before responding to you more than on a one-time basis;
10.2 We provide the parents or guardians of children under the age of 16 with an option to agree to the collection and use of the child’s personal data without consenting to the disclosure of the personal data to third parties. 10.3 If a person under the age of 16 has provided us with personal data without obtaining parental consent in advance, the parent or the guardian may contact us by email at firstname.lastname@example.org and request us to destroy or de-identify the personal data.
11.1 GoRMBGames may contain links to third-party websites and services (e.g., Facebook, YouTube, and Instagram). We are not responsible in any manner for the privacy practices of those websites and services. Please review carefully the applicable privacy policies before visiting the third-party websites and services.
12.2 There are two types of cookies, namely, persistent cookies and session cookies. Persistent cookies remain valid until their expiration date, unless deleted by the user before that date. Session cookies will be stored on a web browser and will remain valid until the moment when the browser is closed.
14. Contact details
15. Last amendment