Last updated: May 22, 2024
Conwordable is an online puzzle game located at the domain address https://conwordable.com/ that allows users to combine various elements to create new items and discover more complex combinations (“Online Game”).
This Privacy Policy explains how we manage the personal data that we collect, hold, use and disclose and how to contact us if you have any further queries about our management of your personal data.
This Privacy Policy applies to you only to the extent that the collection and handling of your personal data is subject to the Privacy Act 1988 (Cth) (“Privacy Act”).
The following Privacy Policy is intended to inform you in particular about the type, scope, purpose, duration, and legal basis for processing your Personal data under our control or in conjunction with others.
We also inform you below about the third-party components (referred below to as the “Third-party Cookies”) we use to optimize our Online Game and improve the user experience, which may result in said third parties also processing data they collect and control.
By using our Online Game, you agree to the collection and use of information in accordance with this Privacy Policy.
Definitions
Users’ Rights And Data
Data Processing
Links To Other Websites
Children's Privacy
How We Handle Complaints
Changes To Our Privacy Policy
Contact Us
The following definitions have the same meaning regardless of whether they appear in singular or in plural and whether they are capitalized or not:
Account means a unique account created for a user to access our Online Game or parts of our Online Game.
Application refers to Conwordable, an online puzzle game located at https://conwordable.com/ and developed by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to SENTY PTY LTD. For the purpose of the GDPR, the Company performs the Data Processing.
Cookies are small text files or other storage technologies stored on your computer by your internet browser. These cookies process specific information about you, such as your browser version, location data, IP address, etc. For more information about cookies and disabling them, consult them at https://www.allaboutcookies.org/manage-cookies/.
Country refers to Victoria, Australia.
Data Processing as per GDPR (The General Data Protection Regulation) as per Art. 4 No. 1 of Regulation (EU) 2016/679, refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.
Device means any device that can access the Online Game such as any computer, smartphone or tablet.
GDPR refers to EU General Data Protection Regulation.
Online Game refers to Conwordable, an online puzzle game located at https://conwordable.com/ and developed by the Company.
Personal Data or Personally Identifiable Information is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. The data will only be processed by us to the extent necessary and for the purpose of providing a functional and user-friendly Web Application, including its contents and services. Further information about the application of the Privacy Act can be found on the Office of the Australian Information Commissioner website at https://www.oaic.gov.au.For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Usage Data refers to data collected automatically, either generated by the use of the Online Game or from the Online Game infrastructure itself (for example, a page visit duration).
Website refers to Conwordable, an online puzzle game located at https://conwordable.com/.
You or User or Data Subject refer to any person accessing or using the Online Game, or a company, or other legal entity on behalf of which such person is accessing or using the Online Game, as applicable.
While using the Online Game, We may ask Users to provide Us with certain personally identifiable information that can be used to contact or identify You.Regarding the processing of data, users have the right to:
Confirmation of whether data concerning them is being processed, information about the data being processed, further information about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
Correct or complete incorrect or incomplete data (cf. also Art. 16 GDPR);
Request an immediate deletion of data concerning them (cf. also Art. 17 DSGVO), or, alternatively, if further processing is necessary as stipulated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
Receive copies of the data concerning them and/or provided by them and have the same transmitted to other providers (cf. also Art. 20 GDPR);
File complaints with the supervisory authority if they believe the Company is processing data concerning them in breach of data protection provisions (see also Art. 77 GDPR).
In addition, the Company is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR.
However, this obligation does not apply if such notification is impossible or involves a disproportionate effort.
Nevertheless, users have a right to information about these recipients.
Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the Company’s future processing of their data pursuant to Art. 6 Para.1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.
Usage Data is collected automatically when using the Online Game.
Usage Data may include information such as:
Your Device's Internet Protocol address (e.g. IP address),
browser type,
browser version,
the pages of our Online Game that You visit,
the time and date of Your visit,
the time spent on those pages,
unique device identifiers
and other diagnostic data.
When You access the Online Game by or through a mobile device, We may collect certain information automatically, including, but not limited to:
the type of mobile device You use,
Your mobile device unique ID,
the IP address of Your mobile device,
Your mobile operating system,
the type of mobile Internet browser You use,
unique device identifiers
and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Online Game or when You access the Online Game by or through a mobile device.
For the purpose of this Online Game, we use cookies to store the session information. Cookies are encrypted and secured. The session lifetime is 30 days after which the session expires.
Our Online Game may use cookies from companies with whom we cooperate for the purpose of improving our Online Game, advertising or analyzing.
You can decline the use of Cookies by changing the settings on your internet browser.
In addition, you can use your internet browser to delete cookies that have already been stored in it.
Please refer to the documentation of your internet browser to be able to do so.
Our Online Game uses cookies. If you prevent or restrict the installation of cookies, not all of the functions on our Online Game may be available.
The Company may use Personal Data for the following purposes:
To provide and maintain the Online Game, including to monitor the usage of our website.
To manage Your Account: to manage Your registration as a user of the Online Game. The Personal Data You provide can give You access to different functionalities of the Online Game that are available to You as a registered user.
To contact You: To contact You by email or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your enquiries to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Online Game users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Online Game, products, services, marketing and your experience.
We may share Your personal information in the following situations:
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Online Game, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your location and jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Online Game may give You the ability to delete certain information about You from within the Online Game.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Online Game
Protect the personal safety of Users of the Online Game or the public
Protect against legal liability
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
We use Plausible Analytics on our website. This web analytics service is provided by Plausible Insights OÜ, Västriku tn 2, 50403, Tartu, Estonia, Registration number 14709274.
Plausible Analytics is privacy-friendly web analytics that does not track, collect cookies or store personal data or personally identifiable information and is fully compliant with GDPR, CCPA and PECR.
We use a self-hosted version of Plausible Analytics hosted on Linode cloud infrastructure in Dallas, US.
For further information on Plausible Analytics's GDPR, CCPA and cookie law compliance and all the data points they collect, please refer to their data policy at https://plausible.io/data-policy.
We may use third-party advertising companies to serve programmatic ads when You visit our Online Game.
These advertising companies may use information about your visits to our Web Application and other websites in order to provide advertisements about goods and services of interest to you.
These advertising advertisements may appear on our Web Application and on other websites. These companies may employ cookies, clear GIFs and other tracking technologies to cause relevant ads to be displayed to you.
We may use Google Analytics on our website. This web analytics service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
For more information about how Google uses data when you use our Web Application, please refer to https://policies.google.com/technologies/partner-sites.
Through certification according to the EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
Google Analytics guarantees it will follow the EU's data protection regulations when processing data in the United States.
The Google Analytics service is used to analyse how our website is used. The legal basis is Art. 6 Para.1 lit. f) GDPR. Our legitimate interest lies in our Web Application's analysis, optimisation and economic operation.
Usage and user-related information, such as IP address, place, time, or frequency of your visits to our Web Application, will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymisation function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.
Google Analytics uses the data collected in this way to provide us with an evaluation of visits to our Web Application and what visitors do once there.
This data can also be used to provide other services related to the use of our website and of the internet in general.
Google Analytics states that it will not connect your IP address to other data.
In addition, Google Analytics provides further information with regard to its data protection practices at https://policies.google.com/technologies/partner-sites?hl=en, including options you can exercise to prevent such use of your data.
In addition, Google Analytics offers an opt-out add-on at https://tools.google.com/dlpage/gaoptout?hl=en in addition to further information.
This add-on can be installed on the most popular web browsers and offers further control over the data that Google Analytics collects when you visit our Web Application.
The add-on informs Google Analytics JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics.
However, this does not prevent information from being transmitted to us or other web analytics services we may use as detailed herein.
Our Online Game may contain links to other websites that are not operated by the Company. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Online Game does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us immediately.
If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
If you have any concerns or complaints about the manner in which we have collected or handled your personal data, please advise us of your concern or complaint in writing and send it to [email protected].
Your concern or complaint will be considered or investigated, and we will endeavor to respond to your complaint within 30 days.
It is our intention to use our best endeavors to resolve any complaint to your satisfaction.
However, if you are unhappy with our response, contact the Office of the Australian Information Commissioner, who may investigate your complaint further.
This Privacy Policy is effective from the 22th of May 2024.
This Privacy Policy may be updated from time to time. You can obtain a copy of the latest version at any time at https://conwordable.com/privacy.
For purposes of the Privacy Act and data protection laws:
Company’s Email address: [email protected]
Company’s Postal address:
ATTN: SENTY Pty Ltd for Conwordable.com
173A Melbourne Road, Rippleside VIC 3215, Australia.
