About this Privacy Policy

Digleefy is committed to protecting the privacy and security of our users and being transparent about how we process information about you. This Privacy Policy describes how we process your Personal Information and how you can exercise your privacy rights.

Digleefy´s services allow our users to play and host games and invite others to join a game. Digleefy acts as a data processor for Personal Information in user content, and for Personal Data that we may otherwise collect and process on behalf of our Users on the platform. 

1. About Us

Digleefy is a platform created to promote game-based learning. We exist to challenge ways of learning and absorbing knowledge by applying our methodology combined with storytelling and problem-solving skills. We cater to audiences from enterprises, educational sector, travel-and location as well as public users. More information about our company and products may be found at www.Digleefy.no

2. Personal Information we process

The Personal Information we process depends on the context of your interactions with Digleefy, your account settings, if any, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

Information you provide to us: You may provide certain Personal Information to us when you sign up to a Digleefy game, use our services, consult with our customer service team, or communicate with us in any other way. This information may include:

• Contact details such as your name, e-mail address, mailing address, telephone number and job title of the contact person of Users (for example businesses or educational institutions);
• Account log-in credentials such as your email address or username and password when you sign up for an account with us;
• Account holder information such as your location, interests, picture, organization, title/position, age, and who you interact with by using the Services.
• Troubleshooting and support data, which is data you provide, or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry; and
• Payment information and other financial information that we/our payment processors need in order to provide the Services.
• Communication data. Several of our Services let you share information with other people, and you have the control over what you share and with whom you share. For example, when signed in and interacting with certain Digleefy Services, such as leaving comments on the Websites, or in games, you may disclose Personal Information to us and the general public. We strongly advise that you limit the disclosure of Personal Information through, for example, comments. Remember, when you share Personal Information publicly, for example through the comment section on our Website, the information you disclose may become publicly available and accessible through search engines. If you disclose Personal Information through comments or other interaction with our services is processed by Digleefy as a data processor.

Information we collect automatically: In some (but not all) countries, including countries within the EEA, this information is considered Personal Information under applicable data protection laws. Service Usage Data may include:

• Browser or device information which is collected through your device, such as Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and version of the Services (such as the App) you are using.
• Usage data which is collected whenever you interact with our Service. This may include the dates and times you access the Services and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Service. This information allows us to improve the content and operation of the Service and facilitate research and analysis of the Service.
• Log data whereby our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP-addresses and your activity in the Services (such as the date/time stamps associated with your usage, participation in games, results, pages and files viewed, searches and other actions you take (for example, which features you used)). We may also access metadata and other information associated with files that you upload into our Service.
• Cookies which allow us to collect information such as browser type and other anonymous traffic data. Please see our cookie policy for more information on our use of cookies.
• Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of our Users, measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.
• Analytics, meaning the use of third-party analytic services, such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information we collect from other sources: From time to time, we may collect Personal Information about you from other sources, such as our Partners, integrations or other third parties, for example where you have given permission to the third party to share your information with us.

3. Use of Personal Information

We may use your Personal Information which we collect for the purposes and on the legal bases identified below:

• Provide the Services. This means using your Personal Information in order to provide the Services’ functionality to you, such as arranging access to an account, responding to your inquiries, and to allow you to utilize our various Service features, such as notifying you when a (new) Digleefy game is shared with you. We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
• Enable you to use certain features. We may automatically process your Personal Information, in reliance of our legitimate interest, in order to enable you to use certain features of our Services, for example to make a comment, join a group or “follow” a specific user. Note that some of these features are only available as part of a subscription plan. If you want to remove your Personal Information in these cases, you can normally do this yourself through your account.
• Communicate with you. We may need to communicate with you about your account and provide you with customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Services. We may also send you system alert messages in reliance on our legitimate interests in administering the Services and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, security or compliance notifications, information about new features, version updates, releases, abuse warnings, and changes to this Privacy Policy.
• Support and improve the Service. Your Personal Information may be used to provide, support and improve the Services in order to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to the “Personal Information Disclosure” section below.
• Prevent abuse and misuse of the Service. In order to protect against misuse or abuse of our Services, protect the rights of our Users, ensuring compliance with our T&Cs and applicable law, and to pursue available remedies, we may use your Personal Information as is reasonably necessary. For example, we may periodically review the content which our Users submit or display in order to ensure that such content complies with our T&Cs, including through automated filtering mechanisms. This benefits all Users who comply with our T&Cs, as it reduces abuse and helps us maintain a reliable platform. We use your Personal Information for this purpose in reliance on our legitimate interest to safeguard from abuse and misuse of the Service.
• Comply with legal obligations. We may use your Personal Information in order to comply with requests by public authorities, court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms. This includes Personal Information necessary to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests, and Personal Information necessary to prosecute and defend a court, arbitration, or similar legal proceeding.
• Optimization and personalization of the Service. Personal Information may be used to provide you with suggestions and provide you with tailored features within our Services that optimize and personalize your experience. For example, on the Websites, we may display certain categories of games, games you have previously played, your location, district or preferences. Such use of your Personal Information is in reliance on our legitimate interests in administering the Service and providing certain features.
• Data analytics. Your Personal Information may be used to perform data analytics in reliance on our legitimate business interests in improving and enhancing our products and services for our Users. For example, we use analytics data to enable product recommendation, audience segmentation, and predicted demographics features for our Users.
• Personalization of the Service. Personal Information may be processed in order to personalize the Service, content and advertisements we serve to you in reliance on our legitimate interests in supporting our marketing activities and providing certain features within the Service.
• Marketing. We may use your Personal Information to serve you marketing information, product recommendations and non-transactional communications (such as email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences and this Privacy Policy. We will not send you unsolicited written marketing.
• Allowing you to participate in sweepstakes, contests and similar promotions. We may offer you the opportunity to participate in sweepstakes, contests and similar promotions. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. Participation in these activities is fully optional, and subject to separate `just in-time´ notice as required. 
• Aggregated and anonymized data. User’s Personal Information may be used to combine and anonymize data about our Users and our User’s use of the Service in order to create aggregate, anonymized statistics which we may use to provide certain features within the Service and for promoting and improving the Service in reliance on our legitimate interests.

4. Third-Party websites

The Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

 

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

5. Your Data Protection Rights

Depending on the country in which you reside, you may have one or all of the following data protection rights:

• Access. You have the right to know which of your Personal Information we process.
• Rectification. You may ask us to rectify any error in your personal data.
• Erasure (the right to be forgotten). You may ask us to erase your Personal Information, which request we will respect and comply with.
• Restriction. You may ask us to restrict the processing of your Personal Information.
• Object. You may object to the processing of your Personal Information.
• Data portability. You may ask us to provide you or others with your Personal Information in a structured, commonly used and machine-readable format.
• Complaint to data protection authority. You may lodge a complaint with your applicable data protection authority regarding our collection and use of your Personal Information. Contact details for data protection authorities within the EU and EEA are available here.
• Right to withdraw your consent. If Personal Information is collected or processed on the basis of consent, or if you have, for example, consented to receiving marketing emails from Digleefy, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Exercise your rights.

You may correct and/or delete Personal Data linked to your account yourself, in the user settings on your account page. If you wish to exercise any of the other privacy rights that applies to you, you can do this by reaching out to us on privacy@Digleefy.no

If we receive an email from you, we may ask you to verify your identity to comply with applicable law, and in order to help us respond efficiently to your request.

6. Personal Information Disclosure

We do not share your Personal Information with third parties outside of Digleefy except in the following limited circumstances:

1. Affiliates. We may share and disclose your Personal Information with the companies in the Digleefy Group, for our legitimate business purposes or to provide services that may include one or more of our Group Companies.
2. Service providers. Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this Privacy Policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions. Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content. 
3. Advertising partners: Digleefy may cooperate with third party advertising platforms and social media channels to promote our Services, both on our Websites and third-party websites. To this effect, we may share limited Personal Information of our Users to achieve this purpose. For example, we and our third-party advertising partners may use cookies, pixels and web beacons and similar technologies to gather information about your activities on the Website and other websites to provide you with advertising based on your browser activities and interests. For further information, please see our Cookie Policy.
4. Public institution(s). Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
5. A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
6. Any other person with your consent.

We may also share anonymized, aggregated information with selected third parties for statistical purposes. Where we use any third parties to provide services on our behalf, and such third parties process your Personal Information, we enter into data processing agreements to ensure that such third parties comply with high levels of confidentiality and best practices with regards to privacy and data security standards. We regularly review these standards and practices and maintain a list of all sub-processors used for the services covered by this Privacy Policy.

7. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@Digleefy.no.

Digleefy accounts require a username and password to log in. Users must keep their username and password secure, and never disclose it to a third party. Because the information in a User’s Digleefy account is private, account passwords are hashed, which means we cannot see a User’s password. We cannot resend forgotten passwords either. We will only provide Users with instructions on how to reset them.

8. International Transfers

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. This may involve countries where the data protection, privacy rights and other laws may not be as comprehensive as in your country. Whenever we transfer your information, we take steps, including preventive measures, to make sure your data is always safe.

For all international transfers, both within the Digleefy Group or to our sub-processors, we ensure that the recipient of your Personal Information offers an adequate level of protection by entering into appropriate back-to-back agreements with our sub-processors. All international transfers are made on the basis of the EU Commission approved standard contractual clauses (“SCCs”).

 

Digleefy maintains strict organizational and technical measures to protect Personal Information stored on our, and our trusted third parties’, servers. Access to any Personal Information we process in order to provision the Services is limited through login credentials, multi-factor authentication, access on a need-to-know basis and restricted access to administrative accounts for the employees who require access in order to perform their duties towards you, such as providing support services.

 

If you want to know more about Digleefy´s international transfers and the measures we take to keep your Personal Information safe, please reach out to us on privacy@Digleefy.no.

 

9. Retention of Data

We never retain Personal Information longer than necessary for the purposes for which Personal Information was collected. We retain Personal Information where we have an ongoing legitimate business or legal obligation to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data;
• Whether the data is necessary to provide our Service;
• Whether our Users have the ability to access and delete the data within their Digleefy accounts; and
• Whether our Users would reasonably expect that we would retain the data until they remove it or until their Digleefy accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

 

10. Changes to this Policy

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Websites. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you.

11. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on privacy@Digleefy.no, or by postal mail to:

Digleefy Escape AS

Hjalmar Wessels Vei

1721 Sarpsborg

12. Definitions

The following definitions applies to this Privacy Policy:

“Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.

“Control” means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term “Controlled” shall be construed accordingly.

“EEA” means the European Economic Area.

“EU” means the European Union.

“Digleefy” means Digleefy Escape AS, organization number 926 317 512, located at Hjalmar Wessels Vei 10, 1721 Sarpsborg, Norway.

“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

“Privacy Policy” means this Digleefy privacy policy.

“Services” means the Digleefy services, including any software, that are available on our platform.

“Service Usage Data” means information we gather automatically through your use of the Services and as further detailed in the “Personal Information we process” section below.

“Third Country” means any non-EU/EEA country

“User”, “you” and “your” means any person or entity that uses our Service(s).

“Visitor” means, depending on the context, any person who visits any of our Digleefy Websites, offices, or otherwise engage with us at our events or in connection with our marketing or recruitment activities.