1. Introduction

This policy together with our Terms of Use (the “Terms”) applies to your use of the Explo app (the “Services”).

Our contact details are as follows:

Corporate name: Miðeind ehf.
Email address: contact@explowordgame.com
Postal address: Fiskislóð 31, 101 Reykjavík, Iceland.

2. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

Our privacy policy may change and if it does, these changes will be notified to you via the Service or our website at explowordgame.com/privacy-policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed, via the Services or via the contact methods detailed above, if your personal data changes during our relationship with you.

3. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity data.
• Contact data.
• Financial data.
• Transaction data.
• Device data.
• Content data.
• Profile data.
• Usage data.
• Marketing and communications data.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. You should not include any such special categories of personal data in any User-generated Content that you submit to the Services.

4. How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information you consent to giving us about you by using the Services.
• Information we collect about you and your device. Each time you use the Services, we may automatically collect personal data including device, content and usage data.

5. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you on the basis of the Terms.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We will ask for your express opt-in consent before we share your personal data with any third party for marketing purposes.

6. Transfer of your personal data

Whenever we transfer your personal data, we ensure that an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts.

7. Data security

All information you provide to us is stored on secure servers.

Where a password is used to enable you to use the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

8. Data retention

We retain your personal data for as long as is reasonably necessary in relation to the provision of the Services and our operations.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Services for a period of 12 months, we may treat the account as expired and your personal data may be deleted.

9. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Also, note that your game history within the Services can usually not be deleted as your games involve the participation of other players who may wish to retain their game histories.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.