Privacy Policy

Methods of Processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data. Data processing is carried out using computers and IT tools, following organizational procedures related to the purposes indicated in this policy.

Place of Processing

The Data is processed at Haptic's operating locations and by the third-party service providers listed in this policy. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own, including the United States.

Retention Time

Unless specified otherwise, Personal Data shall be processed and stored for as long as required by the purpose for which it was collected and may be retained for longer due to applicable legal obligations or based on the User's consent.

Analytics

The services contained in this section enable Haptic to monitor and analyze web traffic and can be used to keep track of User behavior.

Advertising Measurement and Conversion Tracking

The services contained in this section enable Haptic to measure the effectiveness of its advertising campaigns and attribute conversions to specific ads.

Remarketing and Behavioral Targeting

This type of service allows Haptic and its partners to inform, optimize, and serve advertising based on past use of the Service by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.

Users may opt out of interest-based advertising by visiting the relevant opt-out section below in this document.

Handling Payments

Payment processing services enable Haptic to process payments by credit card, bank transfer, or other means. To ensure greater security, Haptic shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Haptic does not store or have access to full credit card numbers.

Registration and Authentication

By registering or authenticating, Users allow Haptic to identify them and give them access to dedicated services.

Infrastructure Monitoring and Error Tracking

This type of service allows Haptic to monitor the use and behavior of its components so its performance, operation, maintenance, and troubleshooting can be improved.

Email Communications

This type of service makes it possible to manage a database of email contacts to communicate with the User. These services may also collect data concerning the date and time when a message was viewed by the User.

Customer Support

Hosting and Backend Infrastructure

This type of service has the purpose of hosting Data and files that enable Haptic to run and be distributed, as well as to provide a ready-made infrastructure to run specific features of the Service.

Traffic Optimization and Distribution

Legal Basis of Processing

Haptic may process Personal Data relating to Users if one of the following applies:

• Consent: Users have given their consent for one or more specific purposes, including analytics and advertising features.
• Performance of a contract: Processing is necessary for the performance of an agreement with the User, such as providing game server hosting, processing payments, and managing User accounts.
• Legitimate interests: Processing is necessary for legitimate interests pursued by Haptic, such as security, fraud prevention, error monitoring, and service improvement.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which Haptic is subject.

Retention

Personal Data collected for purposes related to the performance of a contract between Haptic and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of Haptic's legitimate interests shall be retained as long as needed to fulfill such purposes. Haptic may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn, or whenever required to fulfil a legal obligation.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

The Rights of Users Based on the GDPR

Users may exercise certain rights regarding their Data processed by Haptic. In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by Haptic, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, Haptic will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from Haptic.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details About the Right to Object to Processing

Where Personal Data is processed for the purposes of the legitimate interests pursued by Haptic, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification.

How to Exercise These Rights

Any requests to exercise User rights can be directed to Haptic through the contact details provided in this document. Such requests are free of charge and will be answered by Haptic as early as possible and always within one month, providing Users with the information required by law.

International Data Transfers

Haptic is based in the United States. Data is processed by service providers located primarily in the United States and France (Crisp). Users in the European Union should be aware that their Data is transferred to the United States for processing. Haptic relies on the service providers' compliance mechanisms (such as Standard Contractual Clauses) to ensure adequate protection of transferred Data.

Notice at Collection

The following provides notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that information.

Sharing Disclosure

Haptic shares personal information with Google LLC for cross-context behavioral advertising purposes through Google Analytics and Google Ads. Under California law (CCPA/CPRA), this constitutes "sharing" of personal information. The categories of information shared include identifiers (hashed email addresses) and internet or electronic network activity information (browsing behavior, page views, purchase events).

Your Privacy Rights Under US State Laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• The right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information.
• The right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you.
• The right to request deletion of your Personal Information. You have the right to request that we delete any of your Personal Information.
• The right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity, provided that this is technically feasible.
• The right to opt out of the Sale or Sharing of your Personal Information. You have the right to opt out of the sharing of your Personal Information for cross-context behavioral advertising.
• The right to non-discrimination. We will not discriminate against you for exercising your privacy rights.

Additional Rights for Users Residing in California

In addition to the rights listed above, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising.
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.

Additional Rights for Users Residing in Virginia, Colorado, Connecticut, Texas, Oregon, and Other Covered States

In addition to the rights listed above, you have:

• The right to opt out of the processing of your Personal Information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• The right to freely give, deny, or withdraw your consent for the processing of your Sensitive Personal Information.

How to Exercise Your Privacy Rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. For us to respond to your request, we must know who you are and be able to verify your identity. We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law.

We honor Global Privacy Control (GPC) signals. If your browser or device sends a GPC signal, we will treat it as a valid request to opt out of the sharing of your Personal Information for cross-context behavioral advertising.

Legal Action

The User's Personal Data may be used for legal purposes by Haptic in Court or in the stages leading to possible legal action arising from improper use of Haptic or the related services. The User declares to be aware that Haptic may be required to reveal personal data upon request of public authorities.

System Logs and Maintenance

For operation and maintenance purposes, Haptic and any third-party services may collect files that record interaction with the Service (system logs) or use other Personal Data (such as the IP address) for this purpose.

Information Not Contained in This Policy

More details concerning the collection or processing of Personal Data may be requested from Haptic at any time. Please see the contact information at the beginning of this document.

Changes to This Privacy Policy

Haptic reserves the right to make changes to this privacy policy at any time by notifying its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. Should the changes affect processing activities performed on the basis of the User's consent, Haptic shall collect new consent from the User, where required.

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information, including a personal identification number, that allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Haptic (or third-party services employed by Haptic), which can include: IP addresses, URI addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer, the country of origin, the features of the browser and the operating system, the time details per visit, the path followed within the Service, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Haptic who, unless otherwise specified, coincides with the Data Subject.

Data Controller (or Owner)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. Unless otherwise specified, the Data Controller is Haptic, LLC.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Tracker

Tracker indicates any technology (e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting) that enables the tracking of Users, for example by accessing or storing information on the User's device.

Sharing (California Definition)

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, as defined by the California privacy laws.

Targeted Advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests, as defined by applicable US state privacy law.