This Privacy Policy shows how your personal data is processed by IndieGala and/or the third parties IndieGala is working with. The current Policy may be changed from time to time, so please make sure you check it regularly for updates.

IndieGala SRL, with its parents, affiliates and subsidiaries (also referred in this Privacy Policy as “IndieGala”, “us”, “our” or “we”), owns, operates, or provides access to, interactive websites and other online interactive features and services, including, but not limited to, emails, newsletters and promotional giveaways (collectively named as “Services”). This Privacy Policy applies to all information collected about you by IndieGala, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise noted in this Privacy Policy, IndieGala is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)), which means that we decide how and why the information you provide to us is processed. This Policy explains how we use the information you provide to us to be able to continue to provide the Services. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

• - Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
• - Browsing history including the websites or other services you visited before and after interacting with the Services.
• - Searches for and interactions with e-commerce opportunities, such as offers contained in the Services
• - Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• - Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• - Information collected through the use of cookies, Javascript, pixel tags, and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
• - Device type, settings and software used.
• - Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
• - Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• - Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
• - Local Shared Objects, and Local Storage, such as HTML5.
• - Embedded Scripts which are programming codes designed to collect information about your interactions with the Service by temporarily downloading onto your device from our web server or a third party with whom we work.  Embedded scripts are only active while you are connected to the Service and are deleted or deactivated thereafter.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

By "Personal data" we mean information about any individual or from which any individual is directly or indirectly identifiable. This inlcudes your personal details (e.g., name); demographic data (e.g., age); contact details (e.g., address); records of your consents; purchase details; information about your interactions with our content or advertising; and any views or opinions you provide to us. We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.

By “Process”, “Processing” or “Processed” in the context of your personal data we mean anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

There are three types of personal data we or our partners may collect from you:

1. 1. Personal information which is provided voluntarily by you to us:
   • - personal data you provide when registering an account on our web platform;
   • - personal data you provide when you subscribe to our email newsletter and/or push notifications;
   • - personal data you provide when you participate in a giveaway offer we organize;
   • - any other personal data you chose to send to us via email or postal service.
2. 2. Personal information we collect automatically:
   • - information about your computer and your position. This may include IP address, geo-location, operating system, number of visits and/or page views, referral page and browsing history on our website;
   • - information about the purchases made on this website or, in some cases, made on third parties (e.g. if you connect your Steam account to your IndieGala account and your Steam privacy settings are set to public, we may see the list of games you own on Steam or on which groups you are part of);
   • - information about the giveaways you've participated in on our site or on third party partners.

3. 3. Online Behavioral Advertising (“OBA”) data collected by us or third parties we work with.

   We may use analytics software (e.g. Google Analytics) to collect data and to better understand your behaviour on our site and your commercial preferences. This software may record information such as how often you use our website, the events that occur within the website, which product pages you visit or which products you buy, aggregated usage, performance data, and where you reached our site from.

   Certain third parties (Google AdSense or Facebook) may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.

   These third parties may use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on the Services, the third party may use cookies to later serve you an advertisement for a particular product or service related to the viewed article. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel.

   The specific providers we use for OBA are subject to constant change. Below you can find a list of some of the providers we use most often:

   • - IndieGala
   • - PubNub
   • - Incapsula
   • - Google Analytics
   • - Facebook
   • - Twitter
   • - YouTube
   • - Google+
   • - Reddit
   • - Linode
   • - Amazon Web Services

There are various reasons for which we collect your personal information.

1. 1. To create an account for you on our website:

   When an account is created for you on your website, your purchases are more secure as they are password protected and have extra security measures added that will prevent malicious users to access your orders. We will also use this information to better administrate your account, improve your experience on the website by adding new features and services, to send you statements and invoices and/or verify that you satisfy the age restricition for certain products.

2. 2. Direct and third party marketing content.

   We may Process your User Information to contact you via email or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. We may also send you third party promotional content from one or more of our business partners.

   You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

We may disclose your User Information to other entities for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

• - legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• - outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
• - third party Processors (such as analytic providers; data centers, payment gateways; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9;
• - any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
• - any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
• - any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
• - any relevant third party provider, where our Channels use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
• - third party developers for whom IndieGala processes payments for. IndieGala may provide your email address to these third party developers so they may deliver the final version of the game you purchased.
• - any sponsors of promotional giveaways, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For promotional giveaways, please read the official rules or terms and conditions carefully before you submit your information;
• - to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, analytics providers and retailers).

Certain functionalities on the Service permit interactions that you initiate between the Service and certain third party services (“Third Party Features”). Examples of Third Party Features include "liking" or "sharing" content over social media platforms through our Service or linking your IndieGala account to a third party service such as Steam. If you use Third Party Features, both IndieGala and the third party may have access to certain information about you and your use of our Service and the third party service. For example, if you link your IndieGala account to Steam, we may receive information related to your Steam account for the duration of the linking, including information about the games you own on the Service. Similarly, if you post information on a third party service that references our Service (e.g., by using a hashtag associated with IndieGala in a tweet or status update), your post may be used on or in connection with our Service or that third party service. We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein or any information third parties obtain through your use of Third Party Features. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding.

With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where IndieGala advises users of the possibility of such disclosure at the time they take the survey, IndieGala reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

Also, in order to store your personal data securely, we user third party software and databases that helps us to operate our store. This means that your data is safely stored (therefore also shared with) on third parties databases. The following list shows the current providers we use for this purpose but this list is subject to change at any time.

1. • Data analysis provider:
   • - Google Analytics (View Privacy Policy)
2. • Email sending provider:
   • - Amazon Web Services (View Privacy Policy)
   • - Google App Engine (View Privacy Policy)
3. • Payment gateways:
   • - PayPal (View Privacy Policy)
   • - Ingenico (View Privacy Policy)
   • - Razer zGold (View Privacy Policy)
   • - Coinbase Commerce (View Privacy Policy)
4. • Data storage providers:
   • - Google App Engine (View Privacy Policy)
   • - Linode (View Privacy Policy)
5. • Customer support provider:
   • - Sales Force(View Privacy Policy)
6. • Digital product provider:
   • - Genba (View Privacy Policy)
7. • Monetization providers:
   • - Google AdSense (View Privacy Policy)

Due to the international nature of our business, we may need to transfer your User Information to third party providers as noted in the above sections, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

In certain situations, IndieGala may also be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are an European individual with a privacy related complaint, concern or question about IndieGalas’ privacy practices, please contact us by writing to dpo@indiegala.com (must include “Privacy Policy” in the subject line) and we will respond within a reasonable timeframe after receiving your request.

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.

The data we collect from the subjects indicated in this privacy policy, according to the indications of the relevant legislation, with particular regard to the security measures provided by the GDPR (Article 32) for their processing by means of computerized tools, manual and automated tools and with strictly related logic to the purposes indicated in above and in any case so as to guarantee the security and confidentiality of the data.

In compliance with applicable regulations, a system of anti-spam verification on the communication between users is active. The data entered may be verified for the sole purpose of identifying illegal activities or contents that do not comply with the IndieGala Terms of Service, but will not be processed or communicated for commercial or promotional purposes.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

Your account information and purchase history is kept on our systems for as long as you have an account on our system, then legally for a further 12 months after any account closure.

Newsletter subscriptions are kept as long as you continue to consent to receive our newsletter.

Finally, we remind you that the data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which has been implemented through the EU Directive 2017/541 on anti-terrorism regulations.

You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.

If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.

You may directly take steps to change your preferences as follows:

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some parts of the Service, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off by adjusting the permissions in your browser or mobile device. Please note that your opt out is limited to the browser and device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing or IndieGala’s ongoing business relations.

Unlinking your IndieGala Account from Third Party Services. If you have linked your IndieGala account with certain third party services, such as Steam, you may unlink your accounts at any time by visiting your IndieGala account settings. Please note that unlinking your accounts will not affect any information previously shared through the linking, and IndieGala may continue to use and share that information in accordance with this Privacy Policy. IndieGala is not responsible for any third party data practices and we recommend that you carefully review their online policies. Steam (which is owned and operated by Valve Corporation) has a privacy policy available here.

OBA. European Union and Swiss residents should visit the European DAA by clicking here. Canadian residents should visit the DAA of Canada by clicking here. U.S. residents and residents of all other countries or territories not listed above can click here for the DAA site to learn more about the use of cookies, your opt-out choices, and more. For information about the DAA’s opt out program for mobile apps, click here. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). IndieGala is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Cookies and Pixel Tags. We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. For more information, please see our Cookie Policy. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us via email at dpo@indiegala.com. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

• 1. Data Controller

  The data controller is IndieGala S.R.L. in person of its legal representative pro-tempore, with registered office located in Rome (IT), Via Bolzano, 15, VAT ID: IT 11660511004.

  The data controller uses a Data Protection Officer (DPO) to monitor the protection of your personal data.

  For any request related to your personal data, please see the DPO contact details below.

• 2. Data Protection Officer and contact details

  The person in charge of data protection (Data Protection Officer) pursuant to art. 37 of the GDPR is IndieGala's Legal Manager - Pasquale Basso.

  We remind you that you can contact the DPO at any time and send any question or request regarding your personal data and respect your privacy by writing to dpo@indiegala.com

We may change this Privacy Policy from time to time and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.