Cookie and Privacy Policy Qugato
Last updated on: Monday 23 September 2024
Please note: Our Cookie and Privacy Policy are drawn up in Dutch and follow Dutch law. This is a translated version of our Cookie and Privacy Policy. If this translated version inadvertently differs from the Dutch version, the Dutch version is decisive.
Qugato, located at Kikkerbeet 21, 3824 WS Amersfoort, is responsible for the processing of personal data as described in this Privacy Policy.
We highly value the privacy of our Users and ensure that the personal information you share with us is treated with care.
Do you have any questions about our Privacy Policy? Please contact us at hello@qugato.com or visit our contact page for up-to-date contact information.
1. Definitions
The following definitions have the same meaning whether they appear in singular or plural.
- Qugato / We / Us / Our: The company Qugato, located at Kikkerbeet 21, 3824 WS Amersfoort, registered at the Chamber of Commerce under number 89899660.
- Agreement: The agreement between Qugato and the User or Customer regarding the provision of services as set out in these Terms and Conditions.
- Services: The interactive Games, Events, and all other services offered by Qugato to its Users through the App, Website, or other Channels.
- Game / App: The interactive games made available by Qugato for installation on the User’s devices.
- Website: The website of Qugato: https://qugato.com.
- Channels: All places where Qugato communicates, including but not limited to: our website, app, social media, offline advertising, etc.
- Account: A unique account created for the User to access the App or the profile on the Website.
- User: The natural person or entity using the Website, App, Games, and/or Content offered by Qugato, or purchasing such services.
- Personal Data: All information that can be used to identify an individual, such as name, address, email address, phone number, etc.
- Privacy Policy / Privacy Statement: The rules and procedures regarding the collection, use, and protection of personal data of the User.
- Consent: The explicit approval of the User.
- Cookies: Small files placed on your device by a website that track data about your use of the website.
2. Processing of Personal Data
Qugato processes your personal data when you use our Services or provide them to us yourself. Below is an overview of the Personal Data we process:
- First and last name
- Gender
- Phone number
- Email address
- Address details
- IP address
- Other personal data that you actively provide, for example via an account
- Location data
- Data about your activities on our website
- Browsing behaviour across various Channels
- Browser and device data
- Bank account number
3. Privacy of Minors
Qugato does not intend to collect data from visitors under the age of 16 unless they have parental or guardian consent. We encourage parents to be involved in their children’s online activities. Do you believe we have collected personal data of a minor without such consent? Please contact us at hello@qugato.com so we can delete this information.
4. Purposes and Legal Grounds for Processing
Qugato processes personal data solely based on one of the following legal grounds:
- Execution of an Agreement.
- Legal obligation.
- Consent of the User.
- Legitimate interest, such as improving our Services and conducting marketing activities.
Qugato processes your personal data for the following purposes:
- Handling payments.
- Sending newsletters (if Consent is given).
- To call or email you if necessary for our services.
- To inform you about changes to our Services.
- To provide you with the opportunity to create an account.
- Analysing behaviour on our Channels to improve them.
- Monitoring browsing behaviour to tailor our products and Services.
- Compliance with legal obligations such as tax filing.
5. Automated Decision-making
Qugato uses automated processes, for example, by using Firebase to analyse game data. These processes do not have significant legal or similar consequences for you.
We use automated systems to perform statistical analyses of user behaviour. However, these data are not used to make individual decisions with legal or similar consequences for you. We do not engage in profiling. We will inform you if this changes.
6. Social Media and External Servicesten van derden
Qugato does not sell your data to third parties and only provides them if necessary for the execution of our Agreement with you or to comply with a legal obligation. With companies that process your data on our behalf, we conclude a data processing agreement to ensure the same level of security and confidentiality of your data. Qugato remains responsible for these processing operations.
Qugato enables you to create an account and log in to use the App, or parts thereof, via third-party social media services.
If you choose to register via or otherwise grant us access to third-party social media services, we may collect personal data already associated with your account on that third-party social media service, such as but not limited to your name, email address, activities, or contact list associated with that account.
If you choose to provide such information and personal data during registration or otherwise, you give Qugato permission to use, share, and store it in a manner consistent with this Privacy Policy.
7. Data Processing in the App
During the use of the App, we may collect information with your prior consent to enable features of our App, including:
- Information about your location.
- Images and other information from the camera and photo library of your device.
We use this information to enable features in the app and to improve and personalise the App. The information may be uploaded to the servers of Qugato and/or the servers of a service provider or stored on your device.
You can enable or disable access to this information at any time via your device settings.
8. Retention Periods
Qugato does not retain your data longer than necessary.
We apply the following retention periods for different categories of Personal Data:
- Account data (such as name, email address): Retained as long as the Account is active. Accounts that have been inactive for two years will be deleted unless there is a legal obligation to retain this data for longer.
- Financial data (such as bank account numbers): Retained for a period of 7 years in accordance with legal obligations from the Tax Authority.
- Location data: Location data is deleted or anonymised as soon as it is no longer necessary for the functioning of the Service.
- Data for marketing purposes: Retained until you unsubscribe from our marketing communications. After unsubscribing, these data will be deleted within 1 month.
9. Sharing with Third Parties
Qugato only shares personal data with third parties if this is necessary for the execution of the Agreement or to comply with legal obligations. If data is transferred outside the EEA, we ensure appropriate safeguards, such as EU model contracts.
We share personal data with third parties such as hosting providers and payment processors insofar as necessary for the provision of our Services. With these parties, we conclude data processing agreements to ensure that your data is processed securely and in accordance with the GDPR.
10. Cookies and Tracking Technologies
Qugato uses functional, analytical, and tracking cookies. Tracking technologies used include beacons, tags, and scripts to collect, track, and improve and analyse our service.
At your first visit to our Website, we informed you about these cookies and requested your Consent for placing them.
We use cookies with purely technical functionality. In addition, we place cookies that track your browsing behaviour so we can offer tailored content and advertisements.
You can opt out of cookies by setting your internet browser to no longer store cookies. In addition, you can also delete all previously stored information via your browser settings.
We process the data collected by cookies based on your Consent, as required by the GDPR. This also applies to cookies that may be placed on our website by third parties, such as social media companies and advertising partners.
On the website of the Data Protection Authority, you can read more about Cookies.
11. User Rights
You have the right to view, correct, or delete your personal data. In addition, you have the right to restrict or object to the processing of your personal data, as well as the right to data portability. This means that you can submit a request to us to send the personal data we hold about you in a computer file to you or another organisation specified by you.
You can send a request for access, correction, deletion, or transfer of your personal data to hello@qugato.com.
To ensure that the request for access has been made by you, we ask you to include a copy of your ID with the request. Please make your passport photo, MRZ (machine-readable zone, the strip with numbers at the bottom of the passport), passport number, and Citizen Service Number (BSN) black in this copy. This is to protect your privacy. We will respond to your request as quickly as possible, within four weeks.
Qugato also wants to inform you that you have the option to file a complaint with the national supervisory authority, the Data Protection Authority.
12. Security
Qugato takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure, and unauthorised modification.
We apply appropriate security measures such as encryption and access restrictions.
Qugato maintains an internal register of all processing activities we carry out in accordance with Article 30 of the GDPR. This register includes the categories of personal data processed, the purposes of the processing, and the security measures we apply.
In the event of a data breach affecting your personal data, we will inform you and the relevant supervisory authority (Data Protection Authority) as soon as possible, as required by the GDPR.
If you believe that your data is not properly secured or there are indications of misuse, please contact us at hello@qugato.com.
13. Changes to the Privacy Policy
Qugato reserves the right to amend this privacy policy. Changes will be published on our Website. Users are encouraged to regularly consult this privacy policy for updates.
14. Contact
For questions about this Privacy Policy, you can reach us at hello@qugato.com or visit our contact page for more information.