Privacy Policy

This Privacy Policy applies to the processing of personal data by TRIPLE J SOFTWARE DEVELOPMENT, S.L.(hereinafter “TRIPLE J” or “the Company”) on its websites, app and any other electronic medium or digital platform on which the Company processes personal data.

1. Data controller

TRIPLE J SOFTWARE DEVELOPMENT, S.L., with tax ID (NIF) ESB44831675, address Campus Universitario de Espinardo, 7 — Edif. CEEIM, 30100 Espinardo, Murcia (Spain), and email address legal@playimprisoned.com, is the controller of the data provided. We inform you that this data will be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

2. Legal basis for processing

The legal basis for processing your data is the consent obtained from the user. By ticking the corresponding box, users expressly, freely and unambiguously accept that their data is necessary for the provider to handle their request. Users guarantee that the personal data they provide is accurate and are responsible for communicating any changes to it.

All data requested through the web service is mandatory, as it is necessary to provide the service. If not all the data is provided, we cannot guarantee that the information and service provided will be fully tailored to your needs.

The legal bases for processing data under Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) are:

Collection of data through the website’s forms; Art. 6.1(a): the data subject has given consent to the processing of their personal data for one or more specific purposes.
Receipt of commercial communications after ticking the corresponding box or subscribing to the newsletter; Art. 6.1(a): the data subject has given consent to the processing of their personal data for one or more specific purposes.
Performance of a contract between the customer and the controller for the sale of products or the provision of a service; Art. 6.1(b): processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Invoicing of the products sold or the service provided to the customer; Art. 6.1(c): processing is necessary for compliance with a legal obligation to which the controller is subject.

3. Data we collect

Account and gameplay: username, hashed password, email address, date of birth (age verification), character data, progression, inventory and gameplay logs.
Launcher: unique installation ID, launcher and client versions, operating system, language, download and patch events, integrity errors and technical diagnostics.
Community and forum: messages, comments, posted content and moderation reports.
Newsletter: email address and, if you provide it, preferred language.
Browsing: IP address, device identifier, user-agent, pages visited, time spent and interaction events.
Cookies and similar technologies: see the Cookie Policy.

4. Purposes of processing

The purpose is to maintain a business relationship with users of the Company’s websites, app and any other electronic medium or digital platform. The processing operations envisaged are:

Creating and managing your player account and giving you access to the game and the forum.
Operating the launcher: delivering patches, verifying integrity and authenticating your session.
Maintaining the security of the service, preventing cheating, fraud and abuse, and enforcing community rules.
Handling enquiries and requests you send us.
Sending you the newsletter if you have subscribed, and operational communications about the service.
Producing aggregated statistics on the use of the website and the game in order to improve them.
Sending commercial and advertising communications about our products and services by any electronic or physical means, present or future, that allows commercial communications to be sent, where the user has consented to this.
Complying with applicable legal obligations.

5. Data retention

Data will be kept for as long as there is a mutual interest in maintaining the purpose of the processing. When it is no longer necessary for that purpose, it will be deleted using appropriate security measures to ensure its complete destruction. Personal data provided by the data subject will be retained even after they have requested its erasure, with its processing restricted solely to compliance with legal obligations and/or the exercise or defence of claims.

Account and gameplay data: while the account is active and, once it is closed, for the limitation period of any claims arising from the relationship.
Forum: while the content remains published or is relevant to moderation.
Newsletter: until you withdraw your consent.
Technical and security logs: up to 12 months, unless a longer retention period is required by law.
Accounting and tax data: for the periods required by applicable law (generally 6 years).

6. Your rights when you provide us with your data

Users have the following rights:

Right of access, Article 15 GDPR.
Right to rectification, Article 16 GDPR.
Right to erasure (right to be forgotten), Article 17 GDPR.
Right to restriction of processing, Article 18 GDPR.
Right to data portability, Article 20 GDPR.
Right to object, Article 21 GDPR.

These rights allow you:

To know whether or not we process your data.
To access the personal data we hold about you.
To rectify any of your data that is incorrect.
To request the erasure of your data or withdraw the consent you have given us.
To request the restriction of the processing of your data, in which case it will only be retained in accordance with current legislation.
To the portability of your data: it will be provided to you in a structured, commonly used format. We can also send it to a new controller of your choice. This only applies in certain cases.

You also have the right to lodge a complaint with the supervisory authority, www.aepd.es, if you consider that the processing does not comply with current legislation.

To exercise their rights, users must sufficiently identify themselves in their request, by electronic means or, failing that, by means of a duly signed request. However, if the controller has reasonable doubts about the identity of the natural person making the request, it may ask for the additional information necessary to confirm their identity. Requests must be addressed to:

7. Recipients of your data

The Company expressly informs users and guarantees that their personal data will under no circumstances be disclosed to third parties, except where there is a legal obligation or where it is necessary for carrying out and fulfilling the purposes of the processing.

Any data supplied to our service providers (accounting and administrative advisers, etc.) is provided under the data processing agreement required by current data protection legislation.

Should any disclosure of personal data take place, the express, informed and unambiguous consent of users will be requested beforehand.

We may rely on data processors that access data on our behalf:

Hosting and CDN providers.
Email and newsletter providers.
Web analytics providers.
Anti-fraud and anti-cheat services.
Support and communication platforms.

All processors are bound by a contract in accordance with Art. 28 GDPR.

8. Minors

The service is not intended for children under the age of 14. If you are between 14 and 18 years old, you must first obtain permission from your parents, guardians or legal representatives, who will be held responsible for all acts carried out by the minors in their care. If we detect that a minor has registered without proper authorisation, we will suspend the account.

9. Security measures

In accordance with current personal data protection legislation, the provider complies with all the provisions of the regulations on the processing of personal data and with the principles described in Article 5 GDPR.

We guarantee that appropriate technical and organisational policies have been implemented to apply the security measures established by the GDPR and the LOPDGDD in order to protect users’ rights and freedoms, and that users have been given the appropriate information so that they can exercise them.

10. International data transfers

The data we collect is stored within the European Economic Area. Should it be transferred to and processed in a country outside the European Economic Area, an adequate level of protection of personal data is guaranteed by applying the safeguards required by the GDPR: adequacy decisions, the European Commission’s Standard Contractual Clauses and, where appropriate, additional technical and organisational measures, always informing users in advance.